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Injury, Illness, Prevention Program

SAFETY POLICY AND PROCEDURES MANUAL

INDEX SECTION # PAGE # 1. SAFETY ORGANIZATION Foreword ...................................................................................................... 1 Supervisor's "Acknowledgment of Receipt" (form)....................................... 2 Safety & Health Policy ................................................................................. 3 Program Objectives ..................................................................................... 4 2. ASSIGNMENT OF RESPONSIBILITY Executive Management ............................................................................... 5 Safety Coordinator ................................................................................. 6 & 7 Job Superintendent ...................................................................................... 8 Foremen ............................................................................................... 9 & 10 Employees ................................................................................................. 11 3. DISCIPLINARY PROGRAM Disciplinary Policy .............................................................................. 12 & 13 Guidelines for Supervisors ......................................................................... 14 Safety Violation Notice (form) .................................................................... 15 4. SAFETY ORIENTATION New Employee Orientation ........................................................................ 16 Safety Orientation Guideline ............................................................... 17 - 21 Orientation Checklist (form) ....................................................................... 22 Employment Documents ............................................................................ 23 Code of Safe Practices (sign. form) ........................................................... 24 Employee Acknowledgement (form) .......................................................... 25 5. EMPLOYEE RECOGNITION Encourage Positive Performance .............................................................. 26 Accident Prevention Campaign .......................................................... 27 - 31 Accident Prevention Campaign (form) ....................................................... 32 6. EMERGENCY PROCEDURES Emergency Plan .................................................................................. 33 - 40 Fire Prevention Plan ............................................................................ 41- 44 Earthquakes ............................................................................................... 45 Emergency Telephone List (form) .............................................................. 46 Fire & Emergency Plan Checklist (form) .................................................... 47 List of Emergency Equipment .................................................................... 48 Emergency Coordinators ........................................................................... 49

INDEX (cont.) 7. ACCIDENT/LOSS REPORTING PROGRAM Accident Reporting Procedures .......................................................... 50 - 51 Serious Emergency Reporting ................................................................... 52 Handling Non-serious Accidents ................................................................ 53 First Aid Treatment ............................................................................... 53 - 56 Company Property/Equipment Damage .................................................... 57 Reporting Forms/Format ............................................................................ 58 Recordkeeping ........................................................................................... 59 OSHA Recordable Injuries (Definition) ............................................... 60 - 64 8. ACCIDENT INVESTIGATION Introduction ................................................................................................ 65 Accident Investigation Procedure ....................................................... 66 - 68 Accident/Incident Investigation Report ....................................................... 69 9. SAFETY MEETINGS FOREMAN'S SAFETY MEETING Safety Meeting Format ............................................................ 70 - 72 Minutes, Foreman's Safety Meeting (form) ..................................... 73 Agenda, " " " (form) ....................... 74 TAILGATE SAFETY MEETINGS Objectives and Procedure ................................................................... 75 - 76 Tailgate Safety Meeting (form) ................................................................... 77 10. SAFETY INSPECTIONS - HAZARD CONTROL Jobsite Safety Inspections ......................................................................... 78 Hazard Recognition and Control ......................................................... 79 - 80 Employee Participation .............................................................................. 81 Job/Task Observation Guide ..................................................................... 82 Jobsite Safety Inspection (form) ................................................................ 83 Request for Corrective Action (form) ......................................................... 84 11. EMPLOYEE SUGGESTIONS Employee Safety & Health Suggestions .................................................... 85 Employee Safety & Health Suggestion (form) ........................................... 86

INDEX (cont.)

12. JOB SAFETY TRAINING Safety Training of Supervisors ................................................................... 87 Safety Training of Employees ............................................................. 87 - 88 Safety Communication ............................................................................... 88 (Bulletin Boards, Suggestions, and Meetings) Safety Training Outline/Guide .................................................................... 89 Safety Training Log (form) ......................................................................... 91 Initial Training Record (form)...................................................................... 92 Employee Safety Training Record (form) ................................................... 93 Job Safety Analysis .................................................................................... 94 Job Safety Analysis (form) ......................................................................... 95 13. OSHA REFERENCES OSHA Reports .................................................................................... 96 - 97 Posting Requirements Checklist ................................................................ 98 Safety Information and Resources ............................................................. 99 14. HAZARD COMMUNICATION Hazard Communication Program ................................................... 100 - 109 MSDS Sample Letters ..................................................................... 110 - 113 Material Safety Data Sheets (MSDS) .............................................. 114 - 115 Glossary of MSDS Terms ................................................................ 116 - 120 PROPOSITION 65 SAFETY PROGRAM ................................................... 121 - 125 15. EMPLOYEE HEALTH Employee Physical Exams ...................................................................... 126 Alcohol ..................................................................................................... 127 Confidentiality of Records ........................................................................ 127 Employment During Absence .................................................................. 127 Authorization for Medical Treatment (form) ............................................. 128 16. PERSONAL PROTECTIVE EQUIPMENT (PPE) Mandatory Equipment (PPE) ................................................................... 129 Selecting PPE ................................................................................. 130 - 131 Selection Guidelines ................................................................................ 131 Facial Hair Policy ..................................................................................... 132 Foot Protection ......................................................................................... 132 Safety Belt/Harnesses ............................................................................. 132 Hearing Protection .......................................................................... 132 - 133 Respiratory Protection ............................................................................. 134 Eyewear/Protection Policy ....................................................................... 135 Stereophonic Headphones ...................................................................... 136 17. FALL PROTECTION PROGRAM .............................................................. 137 - 143

INDEX (cont.)

18. ELECTRICAL SAFETY ELECTRICAL SAFETY GUIDELINES Electrical Safety Guidelines ................................................. 144 - 147 Electrical Equipment ..................................................................... 148 Inspection & Repairs ..................................................................... 149 Assured Grounding Program ........................................................ 150 ELECTRICAL LOCK & TAG OUT SAFETY Lock & Tag Out Procedures - General ......................................... 151 Construction Lockout/Tag Out ............................................. 152 - 153 Enforcement/Inspection ................................................................ 154 Supervisor's Responsibility ........................................................... 154 19. RESPIRATORY SAFETY Respiratory Protection Program ...................................................... 155 - 157 Respirators and Their Limitations ................................................... 158 - 160 Respiratory Fit Testing ............................................................................. 160 Equipment Maintenance .......................................................................... 161 Employee Training ................................................................................... 161 Program & Site Evaluation ....................................................................... 162 20. WELDING SAFETY Oxygen - Fuel Gas .......................................................................... 163 - 164 Electric Arc Welding ................................................................................. 165 Welding Equipment .................................................................................. 166 Welding Procedures ................................................................................. 167 Toxic Substances ..................................................................................... 168 Confined Space Welding ......................................................................... 169 21. FIRE & SAFETY WATCH Fire Watch Instructions ................................................................... 170 - 171 Safety Watch Instructions ............................................................... 172 - 173 22. EXCAVATION AND TRENCHING Policies and Procedure ................................................................... 174 - 183 23. HEARING SAFETY Hearing Conservation Program ...................................................... 184 - 185 Work Requiring Hearing Protectors ......................................................... 186 24. CONFINED SPACE ENTRY PROGRAM Policies and Procedures ................................................................. 187 - 199

Index (cont.) 25. SCAFFOLD SAFETY PROGRAM ............................................................. 200 - 203

26. FLEET SAFETY POLICIES AND PROCEDURES ..................................... 204 - 214 27. FORKLIFT SAFETY Operating Rules and Procedures.................................................... 215 - 216 Elevating Employees ............................................................................... 217 Rules for Elevating Employees ................................................................ 218 EQUIPMENT INSPECTION PROGRAM........................................ 219 - 220 28. MEDICAL EXPOSURE CONTROL PROGRAM ....................................... 221 - 232 29. PROCESS SAFETY MANAGEMENT PROGRAM ................................... 233 - 240 30. CONTRACTOR SAFETY GUIDELINES ................................................... 241 - 244 31. WORKPLACE SECURITY PROGRAM ..................................................... 245 - 256

COMMERCIAL SCAFFOLD, INC.

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SAFETY POLICIES AND PROCEDURES FORWARD This manual has been developed for the protection of all employees and to help keep Commercial Scaffolding of Ca, Inc. free of accidents and injuries. It can only serve you if you use it. Each foreman and Superintendent are required to read it through and sign the form on the next page and return it to the Safety Coordinator. This manual has been developed to meet the safety requirements outlined in the CAL/OSHA Construction Safety Orders and in particular Section 1509, Accident Prevention Plan, which incorporates the requirements of Section 3203 of the General Industry Safety Orders, and the safety program requirements under SB198. Applicable to all Federal Standards: This safety program also meets or exceeds the requirements of the applicable

FED/OSHA Standards for Construction and other applicable sections of FED/OSHA i.e., Hazard Communication, Respiratory Protection, and other elements as noted in this manual.

Where this manual may refer to CAL/OSHA for compliance, the section can

also be said to comply with FED/OSHA standards. Set forth in this manual is a set of instructive safety rules and procedures for you to use to enhance safety performance on your job. It covers many fundamentals of accident prevention, but no single manual can be complete, and from time to time new rules or revised rules may become necessary. These new rules or revisions will be issued to you to insert into this manual. If you have any questions, ask your immediate supervisor or the Safety Coordinator for assistance. Failure to comply with the safety rules or policies may result in disciplinary action or possible discharge from your job. It is important that all members of management provide the leadership necessary to comply with safety requirements willingly and "set a good example for others". Believe that safety serves your best interests. If you have any questions, voice them at the right time and place, but don't hamper the program by complaining and balking when it only will do harm. More than anything else, safety is an attitude. The most effective training for all concerned is the day to day example we set for one another.

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SAFETY POLICIES AND PROCEDURES MANUAL SUPERVISOR'S ACKNOWLEDGEMENT OF RECEIPT I acknowledge receipt of the COMMERCIAL SCAFFOLD, INC. SAFETY POLICIES AND PROCEDURES MANUAL. As a condition of continued employment I agree to read and study this manual in order to acquaint myself with these rules and regulations and to follow them to the best of my ability. Signature (Foreman/Superintendent) Date _______ Please print your name above.

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SAFETY & HEALTH POLICY It is the policy of COMMERCIAL SCAFFOLD, INC. to provide a safe and healthful workplace for our employees and to observe all State and Federal Laws and Regulations. We have and will continue to maintain a safety and health program designed to train our employees to follow safe practices and to recognize and correct unsafe working conditions. Safety is a part of each employee's job. Active participation and adherence to the Safety Program is a condition of each employee's employment. No employee is required to work at a job that he or she knows is not safe. Therefore, we must work to make every workplace safe by detecting and correcting unsafe working conditions, as well as the detection of unsafe work practices. Our Safety Policy has equal importance with COMMERCIAL SCAFFOLD, INC. policies of providing the best quality and most productive construction service in the industry. It is our goal to completely eliminate accidents and injuries. Because of the many different hazards of our construction industry, we must maintain a constant safety awareness to achieve this goal. Timothy Trask General Manager

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PROGRAM OBJECTIVES The success of the COMMERCIAL SCAFFOLD, INC. SAFETY AND HEALTH PROGRAM depends on the sincere, constant, and cooperative effort of all company officials, management, and employees. Their active participation and support of the safety program and implementation of its procedures will make it a success. Annual review: The following objectives and goals have been established to gauge the success of our program, as a minimum guideline, and will be reviewed annually by the Safety Coordinator to evaluate the company's safety performance: Objectives: 1. To provide a safety and health program consistent with good operating practices

and maintain compliance with applicable safety and health regulations. 2. To reduce the number of accidents to an absolute minimum, surpassing the best

experience of others in our field of operation: Initially we will look for a 10% reduction in the number of "recordable" (OSHA) injury/illness cases from the prior years experience.

3. To create an attitude of safety consciousness in management, supervision, and

employees: We will establish a spirit of cooperation and teamwork throughout all operations regarding all health and safety matters.

The successful implementation of this manual will largely depend on the enthusiasm and common sense of each job superintendent and foreman.

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ASSIGNMENT OF RESPONSIBILITY EXECUTIVE MANAGEMENT Executive management, President and Vice Presidents, will oversee the administration of the safety and health program of the company. Each member is committed to providing a safe and healthful place of employment for all employees. In addition, it is the primary goal of the company's administrative management to comply with all applicable State, Federal, and local safety and health regulations. Executive management will oversee the administration of the safety and health program. They will rely on the involvement and participation of all management representatives to fulfill their individual responsibilities in the administration, coordination, and implementation of the Company safety and health program: Foremen, General Foremen, Superintendents, Safety Coordinator, and Safety Consultants. It is without question that executive management would hope that all employees comply with the company safety and health program voluntarily. However, as they will be held accountable by the various governmental regulations, they must also hold all employees accountable. Should any individual fail to comply with their responsibility for the safety and health of their workforce, they will be held accountable within the guidelines and restrictions of the disciplinary program outlined within this program.

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SAFETY COORDINATOR RESPONSIBILITY The Safety Coordinator will advise company management as well as job superintendents, foremen, and employees of unsafe conditions, and problems related to accident prevention and recommendations for safety and health. The Safety Coordinator will assist and advise management and supervision in how best to provide a safe work environment, necessary safety equipment needed on the job, safety training that may be required, or sample safety inspections in the interest of accident prevention. The Project Manager will be the on site Company Safety Coordinator for a project. In the absence of the Safety Coordinator, the responsibilities of the Safety Coordinator will be coordinated by the Corporate Safety Representative, Tim Trask. The Safety Coordinator is responsible for the administration of the company Safety Program. Duties include but are not limited to the following activities: 1. The development and administration of the company safety and health program. 2. Development of methods and procedures for the implementation of the program. 3. Provide support and direction in the training and development of personnel. 4. Monitor the implementation of the program and develop means of accountability for

the enforcement of the program. 5. Chair and conduct the monthly foreman's safety meetings by assuring the advance

coordination of agenda materials, making presentations of essential loss control information, and following through on resolutions and recommendations made. The Safety Coordinator will publish and distribute the minutes of the meeting to appropriate management staff.

6. Assist foremen in the investigation of accidents and document findings. 7. Review the foremen's accident investigations and monitor corrective action

necessary to prevent recurrence. 8. Periodically attend "tailgate" safety meetings and maintain records of and review

safety reports submitted by foremen. 9. Assist in the preparation of safety and health bulletins, posters, and publicity as

needed. 10. Insure that first aid facilities, requirements, and emergency transportation are in

compliance with the applicable laws and requirements. 6


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11. Make periodic safety inspections of the job sites, and initiate the corrective action

necessary to eliminate or control the unsafe conditions and/or unsafe acts observed.

In the event of a serious hazard posing imminent danger to any worker, the Safety

Coordinator shall have the authority to "STOP" that phase of work. 12. Prepare monthly reports on job site surveys, "tailgate" safety meetings, and review

accident statistics to evaluate accident causes and to compare severity and frequency rates against accepted norms and the prior record.

13. Assist foremen in the development of job site emergency procedures. 14. Accompany OSHA Compliance and Safety Engineers during their inspections of

any job site and document results. 15. Assist company management in the review of accident reports to ensure that they

are timely and contain an unbiased and thorough evaluation of each incident/accident.

16. Administer the processing of CAL OSHA permits or citations for the company that

may be necessary. 17. When requested by management, review and recommend provisions for

compliance with CAL OSHA standards in plans and specifications for new construction bids, repairs, or modifications of client or company projects. Determine the need for and recommend types and sources of safety equipment essential for specified hazardous jobs.

18. Fully utilize all assistance available from Federal and State labor departments,

insurance carriers, and safety councils on matters pertaining to safety and health. 19. Investigate accidents, especially those which result in serious or fatal injures to

employees or the public where significant liability claims may be made against the company.

20. Actively participate in community efforts of safety professionals and citizen groups

striving to promote accident prevention. 21. Establish and maintain an effective driver training and licensing program for drivers

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SUPERINTENDENT Each Superintendent has the full responsibility and authority for maintaining a safe and healthful working condition within their jurisdiction. Taking actions to provide safe work environments, procedures and equipment for the employees at the highest level possible rests with the Superintendent. Each Superintendent shall: 1. Insure that the policies and procedures set forth herein are complied with by all

personnel under their direction. 2. Provide the necessary leadership and positive direction essential in maintaining

firm safety and health policies. 3. Devote a portion of job meetings to review job site losses (industrial accidents and

liability claims) and discuss plans to bring about a safer job site. 4. Call upon the Safety Coordinator for any assistance needed to promote effective

safety and health policies. 5. Hold foremen accountable for the prevention of injuries, collisions and liability

claims incurred by their employees. 6. Attend the Foreman's (Supervisors) Safety Meetings when held and participate in

the promotion of safety awareness.

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FOREMAN'S SAFETY RESPONSIBILITY Each foreman has the full responsibility for the safe actions of their employees under their control and the safe performance of machines and equipment within their operating area. The full potential of an effective safety program can only be realized when all levels of supervision cooperate in all phases of the program. The following is a list of responsibilities of each Foreman: 1. Each foreman shall assume full responsibility and authority to enforce the

provisions of this SAFETY POLICY AND PROCEDURES MANUAL. 2. Each foreman shall assume full responsibility for the safe and healthful working

areas for his employees while they are under his jurisdiction. 3. Each foreman shall be fully accountable for preventable injuries, collisions, and

liabilities caused by his employees. 4. Each foreman shall make sure the necessary safety equipment and protective

devices for each job are available, used, and maintained properly. 5. Each foreman shall take the initiative in recommending correction of deficiencies

noted in work procedures, equipment, facilities, employee job training, or attitudes that adversely affects our efforts to control accidents and injuries.

6. Each foreman shall be firm in the enforcement of work policies by being impartial in

taking disciplinary action, as defined in this MANUAL against those who fail to conform. And at the same time each foreman is encouraged to be prompt with positive recognition to those who perform well.

7. Each foreman shall ensure that each employee is fully trained for the job he is

assigned to do, that each employee is familiar with published procedures and work rules, and that each employee certifies in writing that he or she understands compliance is mandatory.

8. Each foreman shall ensure that each new employee receives, reads, and

understands the COMMERCIAL SCAFFOLD, INC. SAFE PRACTICES CODE. A copy of the Code, signed by the new employee, shall be forwarded to the Safety Coordinator. A copy of the Code, signed by the employee, must be given to the employee.

9. Each foreman shall continually observe and evaluate job site conditions and work

procedures to detect and correct any unsafe conditions and/or unsafe work practices.

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10. Each foreman shall hold a "tailgate" safety meeting at the start of each job and at

least once every other week thereafter. It is the foreman's responsibility to complete and send the TAILGATE SAFETY MEETING report form for each meeting to the Safety Coordinator. The foreman shall conduct the Safety Meeting in accordance with the guidelines set forth in the section on Tailgate Safety Meetings.

11. It is the foreman's responsibility to assist the Project Manager/Superintendent

before beginning work, the procedures to be followed in the event of a medical emergency. MAKE SURE THAT YOU HAVE ESTABLISHED PROCEDURES THAT WILL WORK AT ANY TIME THAT EMPLOYEES ARE ON THE JOB, DAY OR NIGHT, WEEKENDS, OR HOLIDAYS.

12. It is the foreman's responsibility to assist the Project Manager/Superintendent

before beginning work to determine the procedures to be followed in the event of a medical emergency, and who to contact at the site to get emergency medical assistance, paramedic, or physician treatment and transportation. The foreman must advise all of his employees of these procedures. A list of preferred doctors and medical treatment centers furnished by our insurance carrier is available to you from the office.

13. Each foreman shall post all emergency telephone numbers, including the police

and fire departments, in the tool box, change room, and/or job site trailer/office. Employees shall also be advised of the nearest telephone location.

14. It is the foreman's responsibility to post or otherwise inform each employee of

COMMERCIAL SCAFFOLD, INC. "Workers Compensation Insurance" carrier and "Policy Number".

15. Should an employee have a work related injury or illness, it is the responsibility of

the foreman to investigate the claim and provide the necessary "Employee Report of Injury" form to the employee when informed of the injury or illness.

16. Each foreman shall fully cooperate with the Safety Coordinator, Insurance

Company Safety Personnel, Clients' Safety Department, and OSHA Compliance Officer's in shutting down operations considered to be an imminent danger to employees or in removing personnel from hazardous jobs when they are not wearing or using prescribed protective equipment.

17. Attend the Foreman's (Supervisors) Safety Meetings when held and participate in

the promotion of safety awareness. 18. Each foreman should encourage their employees to participate in the recognition,

correction, or reporting of any safety or health problems without fear of reprisal.

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EMPLOYEE RESPONSIBILITIES All employees are required, as a condition of employment, to develop and exercise safe work habits in the course of their work to prevent injuries to themselves, their fellow workers, and conserve material resources and time. The items listed below are part of the employee responsibilities as outlined by CAL OSHA: 1. Promptly report to their supervisor all accidents, near misses and injuries occurring

within the course of their employment. 2. Cooperate with and assist in investigation of accidents to identity correctable cause

and to prevent reoccurrence. 3. Promptly report to their supervisor all unsafe actions, practices, or conditions they

observe. 4. Become familiar with and observe approved safe work procedures during the

course of their work activities. 5. Keep work areas clean and orderly at all times. 6. Avoid engaging in any horseplay and avoid distracting others. 7. Obey all safety rules and follow published work instructions. 8. Wear protective equipment when working in hazardous areas or jobs, and/or as

required by supervision. 9. Inspect all equipment prior to use and report any unsafe conditions to your

immediate supervisor (foreman). 10. Submit any suggestions for accident prevention which may assist in improved

working conditions or work practices to your immediate supervisor.

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DISCIPLINARY POLICY INTRODUCTION This policy is intended to provide rules and guidelines for administering disciplinary action to employees who violate safety rules and procedures or who, by their record or actions, indicate a disregard for safety and/or company policy. Safety related disciplinary action will be administered through the Safety Coordinator. PURPOSE The purpose of this policy is to enhance safety awareness in all employees, and to motivate them to perform their work safely, in accordance with established safety rules, procedures, and instructions. CIRCUMSTANCES LEADING TO DISCIPLINARY ACTION Listed below are conditions that could be considered for disciplinary action under the provisions of this policy: 1. Violation of a supervisor's safety related instructions. 2. Violation of established safety rules and/or procedures. 3. Violation of instructions on posted safety related signs. 4. Accumulation of an excessive number of injuries (3 or more within a 24 month

period). 5. Obvious unsafe actions as may be indicated by the improper use of equipment,

horseplay or practical joking, poor housekeeping practices, etc. 6. Lack of concern toward safety instructions and programs. The above circumstances are not intended to be all inclusive. Any other circumstances that indicate an employee's disregard for his own safety, the safety of others, or the neglect of proper care for company equipment, may also result in disciplinary action under the provisions of this policy. PROCEDURE: 1. This program is effective as of 1/1/95.

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2. The twelve (12) month period is a continuous period. 3. Whenever a foreman, superintendent, or general foreman observes a company

employee committing an unsafe act or creating or allowing a hazardous condition to exist, a Safety Violation Notice should be completed. A copy of the violation form should be retained in the employee's personnel folder, and each time a new violation form is received, the employee's file will be reviewed for previous violations. Where previous violations appear during a 12-month period, the sanctions listed below will be implemented.

4. The Safety Coordinator will investigate any violation of the safety procedures and

any accident where the cause is not clear. Their recommendation as to cause, preventable or non-preventable, will be made to the Company President.

5. If the employee feels they have been treated unjustly, they will be allowed to appeal

the decision. The appeal will be reviewed by the Company President, Safety Coordinator and employee's foreman.

EMPLOYEE SANCTIONS: The following sanctions apply for violations of safety procedures or involvement in a preventable accident:

A. First Incident - Verbal warning with documentation. B. Second Incident - Written warning with possible suspension. C. Third Incident - Disciplinary action up to and including discharge. D. Fourth Incident - Discharge.

SUPERVISION SANCTIONS: The above sanctions also apply to supervision who will also be subject to disciplinary action: when their employee receives some form of disciplinary action as noted above, or who show negligence in their implementation or enforcement of company policy. Any member of supervision may be subject to these disciplinary guidelines as an individual or as a member of management. The above disciplinary actions are a minimal guideline. Depending on the circumstances or the severity of the violation or incident, any level of discipline which is most appropriate for the time and action up to and including termination, employee or supervision, may be implemented by the company. Approved By: _______________________________ Timothy Trask General Manager

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GUIDELINES for SUPERVISORS' DISCIPLINARY ACTION As a member of management you will be in the position to enforce the Safety Policies in this manual. Many of us consider the acts of Discipline and Enforcement difficult and uncomfortable to administer. However you must remember that when it comes to a broken bone, a severed limb, or the death of our co-workers, it is impossible to place a value on these things. The first definition of "Discipline" in the dictionary is "Instruction". Another definition is "Training that corrects, molds, and perfects". The following statement was taken from the Dow Chemical Safety and Health Program will be the foundation of our Disciplinary Policy: "ASKING ME TO OVERLOOK A SIMPLE SAFETY VIOLATION WOULD BE ASKING ME TO COMPROMISE MY ENTIRE ATTITUDE TOWARD THE VALUE OF ONE'S LIFE."

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SAFETY VIOLATION NOTICE EMPLOYEE WARNING EMPLOYEE NAME DEPARTMENT DATE OF WARNING 1st/2nd NOTICE 3rd/4th NOTICE DATE OF VIOLATION TIME LOCATION & # SAFETY VIOLATION (explain) VIOLATION CONSIDERED TO BE: Extremely Serious Serious Minor Other COMMENTS WITNESS REPORTED BY ************* SUPERVISOR'S COMMENTS: SUPERVISOR'S SIGNATURE DATE EMPLOYEE'S COMMENTS: EMPLOYEE'S SIGNATURE DATE ***************************************************************** CORRECTION: What action has or will be taken to prevent recurrence? (List, then place an "X" by completed items & date.) SAFETY COORDINATOR DATE DEPT. MANAGER DATE COPIES TO: OFFICE (ORIGINAL) - SAFETY COORDINATOR - EMPLOYEE

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NEW EMPLOYEE ORIENTATION 1. All new workers will receive safety orientation, no later than the first work day on the

job. 2. The Safety Coordinator and/or Superintendent/Foreman will provide the orientation.

The orientation will be documented on the "Orientation Checklist for New Employees" form.

3. Each person assigned to a job must sign the indoctrination form upon receiving

instruction from the foreman. 4. The responsible foreman must also sign the forms signifying the employee was

given orientation. 5. In addition to orientation material made available, each foreman must explain the

safety criteria of their individual job site. 6. A signed copy of the new employee orientation form will be maintained at the job

site with copies sent to the office. New Employee Checklist Instructions The job superintendent, foreman, or job secretary should complete the following form indicating they have explained company policy, programs, procedures, and requirements as indicated, to the new employee prior to the employee beginning their job assignment. The enclosed form is used as a matter of personnel policies and procedures and are part of the overall program. By using this checklist, you ensure the new employee is properly instructed on the safety rules that apply to their job assignment.

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EMPLOYEE SAFETY ORIENTATION GUIDELINE Each foreman is responsible to discuss with each new employee the following items in their entirety. Each of the following elements should be reviewed with each employee personally by either reading or general discussion, unless other means are available.


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I. Company Safety Policy, located in the front of the Safety Manual.

II. Employee responsibilities for safety.

All employees are required, as a condition of employment and as outlined in the CAL OSHA regulations, to develop and exercise safe work habits in the course of their work to prevent injuries to themselves and their fellow workers. It is the policy of COMMERCIAL SCAFFOLD, INC. that all employees shall:

A. Immediately report to their superior, all accidents, near misses and injuries, no matter how slight occurring within the course of their employment.

B. Cooperate with and assist in investigation of accidents to identify correctable

cause and to prevent re occurrence.

C. Promptly report to their supervisor all unsafe actions, practices, or conditions they observe.

D. Become familiar with and observe approved safe work procedures during

the course of their work activities.

E. Keep work areas clean and orderly at all times.

F. Avoid engaging in any horseplay and avoid distracting others.

G. Obey all safety rules and follow published work instructions.

H. Wear personal protective equipment when working in hazardous operations area, and/or as required by the foreman.

I. Inspect all equipment prior to use and report any unsafe conditions to their

immediate superior.

J. Submit any suggestions for accident prevention to their immediate superior which may assist in improved working conditions or work practices.

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EMPLOYEE SAFETY ORIENTATION GUIDELINE (Continued)

III. Use of Company Equipment: The company has established special guidelines for the use of special equipment including vehicles, heavy equipment, forklifts, mobile cranes, etc. Only trained and authorized employees are permitted to operate this and other large equipment.

IV. First Aid Equipment: First Aid supplies are kept in each foreman's truck and/or in the job office. Should you have an injury, no matter how slight, report it to your foreman immediately. With minor injuries it is important to reduce the potential of infection or more serious complications by reporting the incident immediately. First Aid can then be given to minimize any serious problem.

V. First Aid Responders: Each foreman will receive first aid training. All employees are encouraged to become first aid trained as a benefit to themselves and their families.

VI. Personal Protective Equipment:

A. Safety Glasses and Hard Hats: it is a company policy that all employee wear safety glasses and hard hats on all job sites within the work area. Most customers have a similar policy and strongly enforce this policy. It is therefore of primary importance for both, the employee and the company, to adhere to this program.

B. Hearing Protection: On some job locations the noise level exceeds the

OSHA permissible levels. This is the exception rather than the rule in most cases. However, hearing protection is required to be worn anytime when work around or with concrete work using a jackhammer or striker, when using a powder activated stud gun, or any other similar equipment. Your foreman has a supply of hearing protection equipment. Follow the manufacturers instructions for the proper use, fit, and sanitation requirements.

C. Respiratory Protection: Many jobs require the use of respiratory equipment

and require that the employee be clean shaven with all facial hair removed. The exception is that a moustache is permitted provided that it does not interfere with a proper seal of the respirator.

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EMPLOYEE SAFETY ORIENTATION GUIDELINE The company requires the use of dust respirators in any dusty environment. All

welders are required to wear respirators outside in well ventilated areas, and air supplied respirators when in any confined space.

VII. Special Clothing:

When working on most job sites it is mandatory that employees wear suitable work shoes. COMMERCIAL SCAFFOLD, INC. does not require that employees wear "safety shoes" although you are encouraged to do so. Some jobs may require special work clothes, coveralls, or rain gear. The company will normally provide these items. Your foreman will inform you of these requirements when the occasion arises.

VIII. Employee Conduct: COMMERCIAL SCAFFOLD, INC. has established and endorsed various rules and regulations for the safety of their employees. However, sometimes it is necessary to impose sanctions or restrictions on an employee who is not following proper work procedures, safety procedures or other elements of company policy. The foreman is held accountable for his employee's proper work performance. Thus, it is the foreman's responsibility to hold the employee accountable for their performance. Each employee's voluntary compliance with these rules will assist the company in providing a safe and productive job site. On the other hand, the rules and regulations will be strictly enforced.

IX. Alcohol and Drug Abuse Policy: The company has established an "alcohol and non-prescription drug abuse policy" for the protection of it's workforce and resources. No one is permitted on a job site who may be using, selling, or handling alcohol or drugs. Employees suspected of being "under the influence" are subject to search and screening. Most customers who the company does work with, have similar if not more stringent policies than COMMERCIAL SCAFFOLD, INC.. The policies will be strictly enforced.

X. Tailgate Safety Meeting: On every other Monday morning (bi-weekly), or more frequently as designated by the Superintendent, at the beginning of the shift, your foreman will conduct a "Tailgate Safety Meeting". This is a company policy based on the requirements of CAL/OSHA.

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EMPLOYEE SAFETY ORIENTATION GUIDELINE (Continued) However, the company looks at these meetings as a key link in safety communication. All employees are required to be in attendance for these meetings. Employees are encouraged to assist in communicating safety issues with their foreman at this time, if they have not already done so.

XI. Hazard Communication: The use of hazardous chemicals is required for some jobs. Some customer job site locations, may even manufacture chemicals that are hazardous. On any job site where it is known to have hazardous chemicals, or employees are required to work with hazardous chemicals, the employees will be instructed in the "Hazard Communication Training" program. The purpose of the program is to inform and train employees how to safely work with hazardous chemicals.

XII. Special Chemical Hazards: Certain chemicals used or manufactured on a job site are "extremely hazardous". Most employees will not be exposed to them during normal operations or work. Your foreman will provide you with special information to safely handle these chemicals should it be necessary that an employee work with the chemicals or on equipment that is exposed to them. These chemicals include: Asbestos, or Benzene. Each of these chemicals is a known or suspected carcinogen, and are regulated by OSHA. Working with these chemicals requires special precautions including reporting requirements, physical examination, use of personal protective equipment, and air monitoring.

XIII. Confined Space Entry: Some job sites may require an employee to work in an area termed a "confined space". These locations are special in that there are certain procedures and equipment required for the safety of the workers. COMMERCIAL SCAFFOLD, INC. has established minimum requirements for any work done in a confined space. Many COMMERCIAL SCAFFOLD, INC. customers have similar policies that must be followed. These policies and procedures will be reviewed with all workers involved in the job prior to the work beginning.

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EMPLOYEE SAFETY ORIENTATION GUIDELINE (Continued)

XIV. Special Training: Special safety training in the use of equipment, new procedures, new equipment, or other may be required periodically. Any employees involved in these jobs or equipment use will be required to complete this special training prior to beginning the job. One example of this is the use of a Self Contained Breathing Apparatus. Not all employees receive this training until the job requires it.

XV. Sanitation and Personal Hygiene: Each job site will be furnished with adequate sanitation facilities and a supply of drinking water. Portable toilet facilities are maintained by an outside contractor who service them regularly. Employees are encouraged to maintain good personal hygiene, especially after handling hazardous chemicals, paints or coatings, glue or epoxy cements, and other potentially harmful material. Washing facilities are available in various areas for cleaning your hands. Personal protective equipment and gloves may reduce the exposure.

XVI. Safety Rules: Read Company Safety Rules that apply to this job and employee.

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SAFETY ORIENTATION CHECKLIST ¨ 1. I - 9 Form for employment completed and signed (Proof of citizenship on file,

per attached requirements.) (Office Personnel also) ¨ 2. W-4 Form completed ¨ 3. Social Security Card presented. (Maintain copy in employee file) ¨ 4. Drivers' License (if applicable, presented and expiration date checked and

written on application) ¨ 5. References checked as on application. (All Personnel) ¨ 6. Reviewed job hours and starting time. ¨ 7. Overtime policy explained, as applicable. ¨ 8. Starting wages and explain Company pay days. ¨ 9. Wages adjustments explained (As applicable). ¨ 10. Holidays, sick time and vacation explained. (As applicable) ¨ 11. Smoking policy reviewed; designated areas reviewed. ¨ 12. Parking explained - on site or other. ¨ 13. Meals and break periods explained. ¨ 14. Explained where employee's restrooms are located. ¨ 15. Probationary period explained, as applicable. ¨ 16. Informed of labor laws (as posted) SAFETY & HEALTH PROGRAM ¨ 17. Discussed safety program and received copy of applicable safety rules for

the job or customer and company rules. ¨ 18. Reviewed and discussed the company INJURY AND ILLNESS

PREVENTION PROGRAM and applicable items for employee. ¨ a. The company Safety Policy ¨ b. "Code of Safe Practices" ¨ c. Disciplinary Policy & Enforcement Practices ¨ d. Accident Reporting Procedures ¨ e. Reporting Unsafe Conditions ¨ f. Proper Lifting Techniques ¨ g. Special Protective Equipment Requirements ¨ 19. Shown location of fire alarms, fire extinguishers, fire exits, and evacuation

plan. ¨ 20. Discussed job training requirements and how assignments are made,

reviewed job description and trained for this job (copy attached) ¨ 21. Provided safety glasses, gloves, etc. if required. ¨ 22. Discussed proper clothing for the job. ¨ 23. Given instructions regarding: ¨ A. Personal appearance; ¨ B. Proper Footwear. I have discussed and understood all above statements and instructions. DATE: SUPERVISOR: EMPLOYEE:

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EMPLOYMENT DOCUMENTS The new immigration law of 1986 requires that all employees hired after November 6, 1986 must provide proof of work eligibility. Applicants will be required to submit originals of one document from Group "A" or, one document from both Group "B" and Group "C". GROUP A GROUP B GROUP C U.S. Passport Social Security Card State Driver's License (Absent no-work endorsement) Certificate of U.S. U.S. Birth Certificate Other form of state or Citizenship or certificate local government I.D. establishing U.S. with photograph. nationality at birth. Unexpired foreign Other document approved Other document approved passport with by Attorney General by the Attorney General unexpired work authorizing employment authorizing employment authorization by the applicant in the in the U.S. endorsement of United States. the Attorney General 1-551 alien registration receipt card with photograph.

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CODE OF SAFE PRACTICES The purpose of the Code of Safe Practices is to assist you in making safety a regular part of your work habits. This is a guide to help identify your responsibility for safety. Your foreman, as required by OSHA, is obligated to hold you responsible for your safety by enforcing these rules and by providing you a safe place to work. Please read the following: A. I will immediately report to my foreman or superior all accidents or near misses, and injuries, no

matter how slight, that occur on the job.

B. I will cooperate with and assist in the investigation of accidents to identify the causes and to prevent recurrence.

C. I will promptly report to my foreman or superior all unsafe acts, practices, or conditions that I observe.

D. I will become familiar with and observe safe work procedures during the course of my work

activities. E. I will keep my work areas clean and orderly at all times. F. I will avoid engaging in any horseplay and avoid distracting others. G. I will obey all safety rules and follow published work instructions. H. I will wear personal protective equipment when working in hazardous areas, and/or as required

by the foreman.

I. I will inspect all equipment prior to use and report any unsafe conditions to my immediate superior.

J. I will submit any suggestions for accident prevention which may assist in improved working conditions or work practices to my immediate superior.

k. I will smoke in authorized locations only.

l. I will not bring onto the job site, have in my possession or in my car, any weapons or ammunition of any kind.

m. I will not have in my possession, use, or introduce any kind of intoxicating liquor or illegal drugs on any customer's property or company work area or facility, or I will accept possible discharge for these illegal actions.

n. I will not come to work under the influence of intoxicating liquor or illegal drugs, and realize that I will not be allowed to start work and may be immediately discharged for this action.

I HAVE READ AND UNDERSTAND THE ABOVE ITEMS AND REALIZE THAT FAILURE TO FOLLOW THESE RULES MAY BE GROUNDS FOR DISMISSAL.

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EMPLOYEE ACKNOWLEDGEMENT FORM CODE OF SAFE PRACTICES I , hereby acknowledge that I have received, read, and understand the "Code of Safe Practices" for COMMERCIAL SCAFFOLD, INC.. I agree to conform to all Company practices, rules, and regulations relating to safe work performance. I understand that my failure to follow these safety procedures will result in disciplinary action up to and including discharge. I further understand that: a. It is my responsibility to report all unsafe conditions or violations of the Code

of Safe Practices to my supervisor or other management personnel in order to minimize the potential of injury to my fellow workers.

b. I am encouraged to inform my immediate superior of any hazards at

the worksite without fear of reprisal, and that should my assistance create any such action or related intimidation, that I am encouraged to contact a member of executive management at the office by phone or mail.

_____ _____________ (Signature of Employee) Date _____ _____________ Signature of Foreman) Date COPIES TO: OFFICE (ORIGINAL) JOB SITE FILE SAFETY COORDINATOR EMPLOYEE

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EMPLOYEE ACCIDENT PREVENTION AND RECOGNITION ENCOURAGE POSITIVE PERFORMANCE Monitoring performance is a constant reminder that safety should be practiced at all times. Proper safety practices will result in an easier job, and better working conditions for everyone. Each foreman, as example setters, are held responsible for monitoring performance. Whenever an unsafe practice is observed, it must be immediately brought to the attention of the employee. On the other hand, when an effort to approach a problem in a safe manner is observed, a gesture of recognition and approval should be immediately made. Performance is monitored to encourage safety consciousness and to convince employees that unsafe working habits will not be tolerated. Where a continued failure to comply with safety procedures is observed, the employee will receive a written warning from their foreman according to company policy. See the disciplinary policy for establishing corrective action. ACCIDENT PREVENTION CAMPAIGN On the following pages is another one of the company's programs which has been developed to encourage and promote safety awareness among employees. The ACCIDENT PREVENTION CAMPAIGN is one method of providing direct safety communication with employees. In this case it would normally be utilized after an accident occurs, whether or not an injury may result.

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ACCIDENT PREVENTION CAMPAIGN Purpose The purpose of the "Accident Prevention Campaign" form is to promote job safety awareness or re-instruction, in a non-threatening manner, following any accident on the job. The process also invites top management involvement in the accident investigation process, an element that promotes the employees awareness to the company's commitment to safety. Each and every time an employee has an accident on the job, the employee is to have a "consultation" with the job superintendent or Safety Coordinator. Objectives: A. To help establish why the accident occurred. B. To involve the injured employee in the accident investigation process in a non-

threatening manner. C. To provide an educational tool for re-establishing the employee's proper safety

attitude and behavior. D. To establish if additional corrective measures are necessary on the part of the

company. E. To establish if additional disciplinary measures may be necessary following an

accident. F. To involve top management in the accident investigation process. Procedure: A. PHILOSOPHY - The "Accident Prevention Campaign" is designed to establish why

an accident happened; and what could have been done to prevent it from happening. It is intended to establish who was responsible for the accident, the employee or the company, in a non-threatening manner.

Since statistics show that between 90 and 98% of all employee job related accidents are caused by the "unsafe act" of the employee, not "unsafe conditions", the program is designed to help identify for the company the root causes and reasons for the unsafe acts. It is expected that the employee will be open and cooperative in telling his story about the accident to a member of top management, rather than his foreman.

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This personal interview with top management is intended to communicate to the

employee that management has a sincere interest in the safety program and cares about its employee's. It is also intended that employee's will form the opinion that they will not want to come under the personal review of top management. It is also thought that the employee will take his personal responsibility for safety more seriously with this program.

B. DEFINITIONS 1. Unsafe act - Failure of the employee to follow proper work procedure,

or violation of a safety rule. 2. Unsafe condition - A physical condition that is unguarded or

uncontrolled. The "unsafe act" of an employee can be a hazardous condition also.

3. Accident - For the purposes of this procedure, an accident is defined

as "any" accident which resulted in or may have resulted in: a. A recordable injury. b. Property damage. c. A potential for serious injury or property damage. C. ACCIDENT PREVENTION CAMPAIGN 1. Minimum Action Standard - The job superintendent or company

safety representative will hold an "Accident Prevention Campaign" conference with any employee who has an "accident" (see definition of accident) on the job. If the superintendent or safety representative are not available, a member of senior management will conduct the conference.

a. The conference should be private and held in comfortable

surroundings, with no time limit set.

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b. The employee should be told the reason for the conference as

being for the benefit of all to learn "what" and "why" the accident happened:

1. To find out what the company can do to prevent

recurrence; 2. What the employee can do to prevent recurrence of the

accident; 3. That the conference is not to fix blame on anyone; 4. To review events that led up to the accident; 5. That the company is concerned for the well being of it's

employee's; c. All documentation regarding the accident should be at hand

for easy review. 1. Prior to the conference all records should be reviewed,

any witnesses interviewed, and a review of the accident scene made in order to be as familiar as possible with the accident.

2. If employee discipline is necessary refer to the

Employee "Disciplinary Policy" for action. 3. The "ACCIDENT PREVENTION CAMPAIGN" form

should be completed at the bottom (manager section) with a summary of the meetings key points.

2. PREPARATION AND PLANNING Once it has been determined by management that an "accident"

(see definition of accident) was of a serious nature, an "Accident Prevention Campaign" form will be given to the foreman of the accident - injured employee.

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a. Foreman's Responsibility Upon receipt of the "ACCIDENT PREVENTION CAMPAIGN"

form, the foreman will: 1. Give the form to his employee and ask them to

complete the form. 2. Tell the employee that the purpose of the form is to

document his view of the accident and suggestions for preventing recurrence.

3. Upon the return of the completed "employee" portion of

the form, the foreman will complete the "supervisor" section of the form and provide details of the incident as they know them.

4. Upon completion of the "supervisor" section, the

foreman will return the form to management for their review.

3. CORRECTIVE ACTION The final disposition of a conference can be far reaching. But

normally most attention will be placed in the area of the employee to correct past behavior or attitudes. This will be done through a subsequent means of employee discipline or through retraining of the employee.

The other area of corrective action deals with items that the company

must accomplish in order to prevent recurrence of an accident. A plan should be developed for the implementation of any corrective measures identified as the result of these investigations and reviews.

4. COMPLETING THE FORM Prior to the consultation, a blank copy of the form should be given to

the employee for them to fill out the portion labeled as such. The foreman will then fill out the portion for the "supervisor". And then the job superintendent will fill out the "manager" portion during the consultation. The "consultation" should center around the following:

1. The problem which led to the accident/injury. 2. Corrective measures to be used to prevent the accident.

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3. Discuss with the employee and document events and/or

conditions that led to the accident/injury. 4. Discuss with the employee and document how the accident

/injury can be avoided in the future, including corrective measures, training, etc.

5. The employee should provide their comments regarding the

accident/injury, corrective measures, etc. and why it happened.

6. If corrective measures are necessary, how soon will they be

implemented. If employee corrective measures are necessary, complete the appropriate "employee" correctional procedure program.

7. The job superintendent should be aware of previous

"consultations." Contact the office if necessary for additional information. Please note that "consultations" can be both verbal or written. The form also provides documentation to show "misconduct" if and when you must terminate an employee.

8. All "Accident Prevention Campaign" forms must be signed by

the employee of concern. A copy should be forwarded to the office for the job file.

9. The foremen must also be informed of any unsafe work

practices or unsafe work conditions. If the conditions continue to exist, corrective action must be taken as necessary.

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ACCIDENT PREVENTION CAMPAIGN

TO BE FILLED OUT BY EMPLOYEE

Name How long employed by Company?

Occupation Is this your regular occupation? YES ¨ NO ¨

Accident occurred? (Date) (Day) (Hour)

Where did accident occur? (Give exact location)

How did accident happen?

Why did accident happen?

Describe work injury

What action do YOU suggest to prevent a similar accident?

Accident Type ¨ Struck By ¨ Fall - Same Level ¨ Inhalation ¨ Contact with Electrical Current (Check One) ¨ Struck Against ¨ Fall - Different Level ¨ Ingestion ¨ Exposure to Temp. Extremes ¨ Overexerted ¨ Caught In, On, or Between ¨ Absorption

Signed Date

TO BE FILLED OUT BY SUPERVISOR

Accident was first reported (Day) (Hour) To whom? Treated by Doctor? YES ¨ NO ¨

First Aid rendered? YES ¨ NO ¨

By whom? Did you investigate accident? YES ¨ NO ¨

Time lost? YES ¨ NO ¨

How many days?

Have you changed any conditions or issued any instructions which will help to prevent recurrence?

Have you any suggestions for changes to avoid a similar accident?

Signed Date

TO BE FILLED OUT BY MANAGER

The suggestions are: ¨ Practical ¨ Impractical

The suggestions should: ¨ Be Carried Out ¨ NOT Be Carried Out

Additional comments

Signed Date

This report reviewed by (Title) Date

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EMERGENCY PROCEDURES Provisions shall be made prior to the start of a project for prompt Medical attention in case of serious injury. The location and phone number of emergency service providers will be posted at each job site. PURPOSE To establish a system for the planning, and implementation of emergency procedures. OBJECTIVES A. To provide for the recognition, evaluation, and proper response in the event of an

emergency situation. B. To provide minimum guidelines for employee involvement in emergency

preparedness. PROCEDURE A. Planning for Emergencies: Each job site shall, under the direction of the safety coordinator and job

superintendent, establish an emergency plan. The job superintendent is to be in charge of:

1. Supervising the development of plans and coordinating the planning with

appropriate authorities at the job site. 2. Setting up cooperative emergency plans and arrangements with other

company's in the area. 3. Consulting with local police and fire department as applicable. 4. Putting the basic procedures in written form. 5. Keeping the plans simple and up-to-date. 6. Arranging for special training of employees as needed. 7. Instructing personnel at the site, in their responsibilities in case of fire or any

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B. General Emergency Procedure Guidelines: The job superintendent shall follow the Emergency Procedure guidelines listed

below, at minimum, when writing the procedures for their job site. The following procedures, when appropriate, can be established for any job site as may be applicable or amended as necessary to meet the needs of other job sites:

1. NOTIFICATION a. The person first encountering the emergency condition should notify

their supervisor and the facility/job site telephone operator and give the LOCATION and DESCRIPTION of the emergency. (See the "Site Emergency Phone List")

b. If at a site which has its own phone system, follow that company's

telephone reporting procedure, or if not, c. Notify the telephone operator or 911 operator, following verification

of the reported emergency by the supervisor, Safety Coordinator or Emergency Coordinator will contact the appropriate Agency for emergency services, i.e. fire department, police, etc. per the emergency phone list.

2. EVACUATION: If it has been determined there is a need to evacuate the building, the

telephone operator will sound the alarm within the facility to alert all affected employees to the actual emergency. Supervision and Emergency Coordinators will implement an evacuation or appropriate action according to the emergency as listed in the plan below.

EVACUATION (Building) The following guidelines should be followed should an evacuation be

necessary: a. Any evacuation should be conducted by the Safety Coordinator and

their designated and authorized personnel including Emergency Coordinators and supervision.

b. At least annually, a test evacuation will be performed in order to

demonstrate the effectiveness of the program. This will also allow for a test of the alarm systems and other important safety/fire prevention systems and devices.

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EVACUATION GENERAL I. TYPES OF EVACUATIONS There are three (3) types of evacuations: 1. Partial - The removal of persons in immediate danger. 2. Horizontal - The removal of persons to an area in the same

building, protected by fire doors, and safe from the area of the emergency.

3. Complete - The removal of ALL persons from the entire

facility. II. PREDESIGNATED SAFE AREA The predesignated safe area for a full and complete evacuation of the

building is to the predesignated "ASSEMBLY AREAS" as noted on the evacuation map._______________________________________________

The only exception to this is if the emergency is of such a magnitude that

one or both of these areas also becomes too hazardous to the safety of personnel. Under such circumstances, the Safety Coordinator and management will choose an alternate "safe area", such as the street (if no longer passable by vehicles) or another lot in the vicinity. In all cases, it will be imperative that any other location chosen must be done so only after evaluation of the threat of electrical hazards, fire or explosion, or chemical hazards.

III. EVACUATION PROCESS Emergency Coordinator's Responsibilities An Emergency Coordinator will be designated by the Safety Coordinator to

provide assistance and support in the event of an emergency. Whenever there is an imminent or actual emergency, the Emergency Coordinator or one of the alternates shall implement the following actions:

a. Ensure that Security and emergency personnel are notified to

evacuate all personnel from the building when required. b. Ensure that appropriate agencies are notified if their help might be

needed, i.e. the Fire Department, Paramedics, or Police.

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c. Assist and coordinate emergency personnel in order to make every

reasonable effort to contain the fire or chemical spill to as small an area as possible. Also, efforts should be made to keep incompatible chemicals separated without further endangerment to human health on the environment.

d. Identify what caused the emergency (chemical or fire), exact source,

and amount of material released. e. Assess all possible hazards to human health or the environment

considering direct and indirect effects of the release, fire or explosion, such as toxic or irritating gases, water runoff from chemical agents used to control the emergency, etc.

Supervisor's Responsibilities 1. Lead and maintain order. Try to keep employees calm. Tell them that

there will be less danger if they proceed to the designated safe area in a calm and orderly manner.

2. Conduct a thorough search of the area (floor, offices, restrooms, etc.)

or job as applicable, and report findings to the Emergency Coordinator and Safety Coordinator. Be sure to report anyone not accounted for to the Safety Coordinator.

Building Evacuations 3. Close all doors behind you. Many doors are "fire rated" and can

assist in reducing the potential spread of fire and smoke, but only if they are closed completely.

4. In a fire, if in smoke, instruct employees to breathe through the nose

in quick, short breaths, and crawl along the floor. 5. Instruct the employees to move in an orderly manner to the nearest

exit. Instruct the people not to panic, and remain calm. 6. Do not stand or remain in the exit doorway. The doors must closed

completely to effectively prevent air from rushing in to help the spread of fire and/or smoke.

7. Keep the exit doorway clear and keep your employees together.

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8. After exiting, go to the designated safe ASSEMBLY AREA. 9. RE-ENTRY. Wait for word from the Emergency Coordinator, or

Safety Coordinator before attempting re-entry of the building or returning to work.

C. EMERGENCY CONTINGENCY PLAN If the emergency situation could threaten human health or the environment, and an

assessment of the pending danger indicates that an evacuation of the local area (ie. other businesses, etc.) is advisable, immediately contact:

The FIRE DEPARTMENT @ 911 immediately and assist them however possible.

Also notify the STATE OFFICE OF EMERGENCY SERVICES, should a chemical spill occur, at (800) 852-7550 and report the following:

A. Name and telephone number; B. Company name and address; C. Time and type of incident; D. Name and quantity of materials released; E. Extent of injuries, if any; F. Possible hazards to others or the environment. G. When the emergency situation is under control, cleanup or neutralization

can begin using appropriate tools, safety equipment, and outside services as necessary. All hazardous materials must be cleaned up, stored properly or hauled to an appropriate dump sight for disposal by properly trained personnel only.

H. Before normal operations resume, all tools, emergency equipment and devices listed on the Emergency Equipment List must be operational and ready for use. The LOS ANGELES COUNTY FIRE DEPARTMENT, HAZARDOUS MATERIALS CONTROL SECTION must also be notified by telephone at (213) 744-5105.

I. Within 15 days after an emergency that requires implementing the contingency plan, a written report must be completed and sent to the State Office of Emergency Services (916) 427-4287 by writing to: CEPRC/LEPC

2800 MEADOWVIEW RD. SACRAMENTO, CA 95832 ATTN: Sec. 304 (REPORT) A copy of the report will be kept for our files. The report must contain the

following: A. Name of Owner, address, and telephone number; B. Company name, address, and telephone number; C. Date, time, and type of emergency; D. Name and quantity of materials involved;

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E. Extent of injuries, if any; F. Assessment of actual or potential hazards to human health or

the environment, if applicable; G. Estimated quantity and disposition of waste resulting from the

emergency situation. This report is to be completed by the Safety Coordinator. D. FIRE EMERGENCY, EXPLOSION, OR CHEMICAL SPILL If a fire is discovered or explosion occurs, the foreman shall: a. Remove their people from the immediate area of the fire and evacuate to the

predesignated "safe" area. b. Notify the telephone operator (at the job site) or call 911, stating the location

of the fire and what is burning. c. Make a head count of employees at the predesignated assembly area to

ensure that they are all accountable. d. Return to the site and attempt to extinguish any fire only if you have received

the proper training to do so. e. Assign an employee to meet and direct the fire department to the location of

the fire. f. Notify the job superintendent and Corporate Office immediately of any fire

that involved company personnel, equipment, or liability. E. CHEMICAL SPILL If a chemical spill occurs, in addition to the above steps make every effort to contain

the spill to as small an area as possible without further endangerment to human health or the environment.

E. EARTHQUAKE Employee's Responsibilities a. During the earthquake: 1. Get at least 15 feet away from windows. 2. Find shelter under a sturdy structure. 3. Stay away from free standing objects. 4. Do not panic or attempt to evacuate.

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b. After the earthquake: 1. Stay put until the foreman tells you to return to your work area or

evacuate to the predesignated assembly area until the "all clear" is given. An initial shock usually lasts less than a minute, but other jolts may come soon after.

2. Above all, do not panic. Depending on the severity of the

earthquake, the lights may fail or fire may break out. Expect the unexpected.

3. If the earthquake results in fire or injuries, follow the appropriate

procedure for the specific problem. Foreman's Responsibilities a. Inspect the site for any possible hazardous conditions, i.e., fires, electrical

shorts, plumbing leaks, structural damage, etc. b. Determine casualties, provide any assistance possible and make

notifications to the emergency services needed. c. Notify the Corporate Office, by telephone, walkie-talkie or by messenger, of

your situation and status. d. DO NOT ATTEMPT AN EVACUATION OF THE AREA UNLESS

ORDERED BY THE LOCAL FIRE OR POLICE DEPARTMENT. BOMB THREATS (Office Locations): When a bomb threat is received, the Safety Coordinator should be notified immediately. The police should then be notified. The person receiving the call should try to connect the caller with the Safety Coordinator, or gain as much information as possible such as: A. Location of bomb B. Time of detonation C. Reason why bomb was planted Additional information relating to the identity of the caller should be attempted to be gathered by the employee who receives the call in order to develop the proper profile of the caller. They should try to gather information such as the caller's: A. Sex B. Race (accent) C. Voice characteristics D. Knowledge of building and personnel E. Background noises

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Search Procedure Until police arrive, the Safety Coordinator may conduct a careful search of the

facility to look for anything that is unusual: a package, a box, a briefcase left unattended, etc.. If a suspicious object is discovered, under no circumstances should it be handled or disturbed. NOTIFY THE POLICE IMMEDIATELY. Every effort should be made to work with the police in the search, the identity of the caller, and any other information that must be exchanged.

CIVIL DISTURBANCE: Notify the Safety Coordinator and give them the location of the disturbance. They will direct further action, as may be necessary.

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FIRE PREVENTION AND EMERGENCY PREPAREDNESS FIRE AND EXPLOSION HAZARDS There are three (3) elements necessary for a fire: a. Fuel - Combustible material, i.e., wall coverings, paper products, furniture, etc. b. Heat - Sufficient to raise the material to its ignition temperature. Primary causes

can be cigarette smoking, electrical fires, grease fires and fires caused by explosions.

c. Oxygen - To sustain combustion. Oxygen is the one element that could be

controlled by closing doors and isolating the fire as much as possible. FIRE AND EXPLOSION PREVENTION Each foreman will be responsible for the following fire prevention activities: a. Make routine inspections of company fire prevention and protection systems

regularly and keep in good operating condition. b. Review evacuation routes with employees on a regular basis for each work area on

the job site. Follow the designated routes and know the predesignated safe areas established by the contractor. Obtain a copy of the contractor's plan and review it with the employees.

c. Train key employees, if necessary, in the use of fire protection equipment

(extinguisher's, hose, etc.) When at a job site which has their own fire department, rely upon these trained professionals except in minor emergencies.

d. Be familiar with known hazards inside and outside the facility which may affect your

work force. e. Coordination with the public fire department on pre-fire plans, training and

evacuation procedures, as they may apply. SPECIFIC HAZARDS a. Smoking Smoking is permitted in designated areas only. Don't use ashtrays as waste paper

receptacles, or don't use waste paper receptacles as ashtrays.

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Even if you don't smoke, have an ashtray available for those visitors who do. This will remove the temptation to use the waste paper receptacle as an ashtray. When at job site locations, follow that company's policy.

b. Electrical Make sure that all electrical cords are not frayed and that the connections with the

receptacles and the machinery are intact. Do not overload wiring. If cords become warm, this is the first sign of a possible overload.

c. Housekeeping 1. Don't allow excess paper or combustible products to pile up in the open,

near equipment, or buildings. 2. Don't allow materials or boxes to be placed in the way of exit travel. 3. Keep material away from access to electrical panels. FIRE PREVENTION RULES General Requirements 1. Portable fire extinguishers must be maintained in a fully charged and

operable condition and kept in their designated places at all times when they are not being used.

2. Extinguishers must be conspicuously located where they will be readily

accessible and immediately available for use. 3. The selection of fire extinguishers for a given situation will depend upon the

characteristics of a potential fire, the construction and occupancy of the individual property, the vehicle or hazard to be protected, ambient-temperature conditions, and other factors.

4. The number of extinguishers required must be determined by reference to

the layout criteria included in this manual. 5. Only UL or FM approved fire extinguishers are permitted. 6. Only employees who have been trained in their proper use are permitted to

use fire extinguishers. 7. All welding work must have a capable "fire watch" assigned to the area to

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Maintenance 1. At regular intervals, not less than annually, or when specifically indicated by

an inspection, extinguishers must be thoroughly examined and/or recharged or repaired to ensure operability and safety, or replaced as needed.

2. Extinguishers removed from their locations to be recharged must be

replaced by spare extinguishers during the period they are gone. 3. Each extinguisher must have a durable tag securely attached to show the

maintenance or recharge date and the initial or signature of the person who performs this service.

FLAMMABLE AND COMBUSTIBLE LIQUID AND MATERIALS 1. Flammable liquid containers must be clearly labeled and stored in a protected,

separate area. 2. Flammable liquids must be used only in small quantities and in approved (UL or

FM), self closing containers. 3. Do not refuel a hot or running engine. Clean up spills before restarting. 4. Never use gasoline as a cleaner or solvent. Anyone who may do so is subject to

immediate discharge. 5. Use only the proper transfer equipment when transferring a flammable liquid such

as gasoline for refueling. 6. Never use an air hose for pressure to empty drums. 7. Lines or other containers holding gasoline, oil, grease and other flammable material

must be thoroughly purged and tested for explosiveness by approved testing equipment before any burning or welding is done.

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SCRAP RECEPTACLE - TYPE, LOCATION AND USE Fire Prevention This procedure outlines types, location, and use of containers for trash, scrap metal, and similar materials. Type 1. All receptacles must be constructed of metal or other suitable type containers of

non-flammable materials. 2. Paper or pasteboard cartons, wooden boxes or crates, and similar type containers

must not be used for collection of combustible materials. 3. Receptacles, located outside of buildings, for combustible trash must be located at

least 15 feet from the building or combustible materials. Use 1. Employees must be instructed to use trash barrels for the disposal for paper, lunch,

remnants, and all small scraps of a combustible nature. 2. Cigarette and cigar butts, matches, etc., should never be thrown in trash

receptacles. 3. Glass (broken, empty jars, etc.), scrap metal, and similar material should be placed

in special trash containers.

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EARTHQUAKE PREPAREDNESS Nothing can be done to prevent an earthquake. However, there are precautions that can be taken to lessen the devastating effects of an earthquake. a. Housekeeping 1. Ensure that cabinets are stable and anchored. Spread the material

throughout the drawers evenly. 2. Ensure that paper, books, etc., are not stacked on top of cabinets. 3. Ensure that boxes, electrical cords, etc., will not become tripping hazards in

case the lights fail. b. Earthquakes Preparedness Each foreman will be responsible for the following activities: 1. Review emergency water supplies for fire protection system and drinking

water. 2. Provide a plan for shutdown of damaged power, gas, and flammable liquid

supply lines which may be your responsibility. 3. Make a list of equipment that may be needed for rescue and salvage

operations and its location in and outside the facility when applicable. 4. Plan for emergency communications 5. Make provisions for additional medical supplies, food water and shelter, if

needed. 6. Coordinate facility emergency plan with those of local agencies or job site as

they may apply.

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SITE EMERGENCY TELEPHONE LIST NAME TELEPHONE NUMBERS Office COMMERCIAL SCAFFOLD, INC. Fire Department 9-1-1 Local Law Enforcement Agencies 9-1-1 Nearby Hospitals Ambulance Services 9-1-1 American Red Cross Chemical Transportation Emergency Center (CHEMTREC 24 hour hotline) Electric Company (as applicable) Gas Company (as applicable) Water Company (as applicable) Telephone Company (as applicable) State or Local Building Inspection Departments State and Local Civil Defense Agencies (for emergency plan). OSHA office U.S. Weather Bureau Key Personnel:

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FIRE AND EMERGENCY PLAN CHECKLIST The following checklist should be completed by the Emergency Coordinator and any supervisor as applicable: STATUS ¨ 1. Site emergency telephone list completed. ¨ 2. Emergency plans established for company. ¨ 3. Evacuation areas designated and routes assigned. ¨ 4. Fire prevention equipment inspected regularly. ¨ 5. Key employees trained in the use of fire protection equipment. ¨ 6. Any "special hazards" identified and reviewed (toxic or explosive). ¨ 7. Smoking policy established and reviewed with employees. ¨ 8. Electrical equipment inspected regularly. ¨ 9. Housekeeping program put into operation. ¨ 10. Emergency drinking water provided. ¨ 11. Plans for emergency communication established. ¨ 12. Emergency equipment and supplies established. ¨ 13. Emergency communications coordinated with customers/vendors. ¨ 14. First aid and medical supplies provided as needed. ¨ 15. Provisions for Emergency food, water, and shelter established. ¨ 16. Emergency plans coordinated/communicated with "Local Agency" area

plans. ¨ 17. Key personnel trained in first aid procedures.

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LIST OF EMERGENCY EQUIPMENT AND SUPPLIES COORDINATOR DATE

ITEM QUANTITY LOCATION

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EMERGENCY COORDINATORS PHONE NUMBERS NAME PRIMARY COORDINATOR SAFETY COORDINATOR Tim Trask WORK# HOME# FIRST ALTERNATE WORK# HOME# SECOND ALTERNATE WORK# HOME# THIRD ALTERNATE WORK# HOME# One of the Emergency Coordinators will be available at all times. The Primary Coordinator is to notify one of the alternates if he will be out of town, on vacation, etc. OTHER IMPORTANT PHONE NUMBERS:

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ACCIDENT/LOSS REPORTING PROGRAM PURPOSE To establish a standard system for the notification and reporting of accidents involving occupational injury or illness, property damage, and public or private property. OBJECTIVES A. To obtain the information necessary for the local, state and federal agencies and

the company's insurance carriers. B. To inform management of accidents resulting in serious employee injury or illness

and property damage. PROCEDURE A. GENERAL REQUIREMENTS Timely reporting within 24 hours of any accident or loss is mandatory. The foreman

shall thoroughly investigate the cause of each accident/loss occurring within their area of operation and record their findings and recommendations on the appropriate reporting form. One copy shall be forwarded to the office. The job site copy should be critically reviewed and signed by the job superintendent, where applicable. A copy shall be retained in the foreman's file for their record.

B. REPORTING EMPLOYEE INJURIES 1. Regardless of the degree of injury, the employee must report to his

supervisor or in writing on the applicable "state form" that he was injured. THIS FORM MUST BE COMPLETED AND TURNED INTO THE OFFICE WITHIN 24 HOURS.

In California, the employee must be given the "Employee's Claim For

Worker's Compensation Benefits" (DWC - 1) within 24 hours of the reported injury AS REQUIRED BY THE STATE OF CALIF.

First aid/medical treatment will be provided by the foreman. If necessary the

injured employee will be taken to the designated company medical facility.

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2. The foreman shall complete the form, "ACCIDENT INVESTIGATION

REPORT", within 24 hours and send a copy to the office. Once the foreman is told by the employee or is aware of the work-related injury, IT MUST BE REPORTED TO THE OFFICE WITHIN 24 HOURS EVEN IF THE FOREMAN THINKS THE INJURY:

a. is minor, or b. might have been caused by unsafe actions such as inattention or

negligence, or c. aggravated an old injury, or d. is not work-related. If the foreman thinks any of the four above items are applicable, it should be

stated on the "report" forms. AT NO TIME SHOULD A FOREMAN WITHHOLD OR HINDER THE FILING OF AN EMPLOYEE INJURY REPORT TO THE OFFICE.

3. A FOREMAN SHALL NOT ALLOW AN EMPLOYEE TO RETURN TO

WORK AFTER AN OCCUPATIONAL INJURY OR OCCUPATIONAL ILLNESS UNLESS HE RECEIVES A SIGNED AUTHORIZATION TO RETURN TO WORK FROM THE TREATING PHYSICIAN. IF THE INJURED EMPLOYEE HAS BEEN OFF WORK MORE THAN 30 CALENDAR DAYS AND IS IN A NON-SEDENTARY POSITION, HE/SHE WILL BE REQUIRED TO TAKE A SPECIAL PHYSICAL EXAM AT THE COMPANY'S EXPENSE.

Upon their return to work, the company will make every attempt to put

employee's to work within the limitation(s) specified by the treating physician. 4. BECAUSE OF THE COMPLEXITY OF WORKER'S COMPENSATION

LAWS, RULES, AND PROCEDURES, THE FOREMAN SHOULD NOT ATTEMPT TO ANSWER ANY QUESTIONS ABOUT WORKERS' COMPENSATION INSURANCE. REFER THE INJURED EMPLOYEE TO THE OFFICE.

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SERIOUS EMERGENCY REPORTING SERIOUS EMERGENCIES are accidents that are life threatening or require more than routine first aid. Call for emergency medical service and transportation. In the Southern California area the number is 911. Tell them you have a SERIOUS ACCIDENT. Describe the nature of the accident, i.e. burn, fall, electrical shock, cut, etc. Tell them the ACCIDENT LOCATION. Give them directions to the accident site, especially if the location in a large plant or facility. If the accident location is difficult to find, send an employee to the plant main gate or out to the street to direct emergency vehicles. INSIST ON AN IMMEDIATE RESPONSE. Note the time you called and with whom you talked. Make sure transportation for the injured to a doctor or a hospital is immediately dispatched. Give the doctor and/or hospital notice that the injured is in transit to them. ATTEND TO THE INJURED. Make sure that there is no chance of further injury to the injured employee or anyone else. Provide immediate first aid as necessary until the emergency personnel arrives. CLEAR AND SECURE THE AREA so that emergency treatment can be administered to the employee and there is clear access to the accident site for emergency vehicles and personnel. After the injured has been removed from the area, rope off the area and do not allow access to anyone until completion of all investigations, and authorization to proceed by the COMMERCIAL SCAFFOLD, INC. Safety Coordinator. REPORT TO OFFICE. Sudden severe illness or injury occurring to employees during regular job hours requiring EMERGENCY MEDICAL TREATMENT (such as possible heart attacks, strokes, seizures, fainting, serious injuries, etc.), must be reported to the superintendent and Project Manager BY TELEPHONE as soon as possible. The superintendent should then contact the family of the injured employee. CAL OSHA NOTIFICATION. Serious job injuries must also be reported to CAL-OSHA within 24 hours.

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HANDLING NON-SERIOUS ACCIDENTS Provide first aid for the injured employee. First aid supplies are available in the kits provided in the job tool boxes. The customer's first aid facilities may also be available to you. Send the employee to a doctor if there is any question that the first aid treatment may not be adequate. If the employee receives medical treatment he may not return to work unless he has a release from the doctor or treatment center. All non-serious accidents and injuries are warning sign that a serious accident may occur. Report all non-serious accidents (see ACCIDENT REPORTING SECTION) as soon as possible to the Safety Manager, but don't delay in taking corrective action on the job site.

Tim Trask Safety Officer

COMMERCIAL SCAFFOLD, INC. FIRST AID TREATMENT The first priority in the treatment of an injured employee is to obtain proper medical attention. In an extreme emergency, immediate first aid may be necessary. In the event we are working in an area where a medical facility is not reasonably accessible to provide treatment to the injured, a person with a valid certificate in FIRST AID training shall be available at the job site. Each job site shall have at least one foreman, per shift, on the site at all times who is trained in First Aid. First Aid Training should be American Red Cross or American Heart Association, or their equivalent. Employees are encouraged to be CPR trained also.

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FIRST AID The first priority in the treatment of an injured employee is to obtain proper medical attention. In an extreme emergency immediate first aid may be necessary. The following are common first aid treatments for the various ailments listed. ------------------------------------------------------------------------------------------------------------------------- ASPHYXIATION Symptoms: Nausea, dizziness, unconscious, lips or earlobes blue, breathing

stopped, bizarre behavior. Treatment: Remove to fresh air, give rescue breathing. ------------------------------------------------------------------------------------------------------------------------- BLEEDING ARTERIES Symptoms: Bright red blood spurting from wound. Treatment: Direct pressure over wound to control bleeding. ------------------------------------------------------------------------------------------------------------------------- BLEEDING VEINS Symptoms: Dark red blood flowing steadily. Treatment: Apply sterile bandage firmly over wound. Do not break blood clot. ------------------------------------------------------------------------------------------------------------------------- BLEEDING (INTERNAL) Symptoms: Faintness, pale face, thirst, sighing, weak rapid pulse. Treatment: Lie victim down, keep warm and quiet. Call an ambulance. ------------------------------------------------------------------------------------------------------------------------- BURNS Symptoms: Caused by exposure to heat, or dry caustic chemicals, or acids or alkalis. Treatment: Cold applications for minor burns. For liquid chemical burns, wash

affected area with large amounts of water, usually for 15 minutes. For dry chemicals, carefully brush or blow away chemicals, then wash area with large amounts of water.

-------------------------------------------------------------------------------------------------------------------------

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FIRST AID (CONTINUED) ------------------------------------------------------------------------------------------------------------------------- DISLOCATIONS Symptoms: Compare injured to uninjured limb; longer or shorter? Look for

deformity at the joint. Treatment: Support along lines of deformity. Do not attempt to reposition. ------------------------------------------------------------------------------------------------------------------------- DROWNING Symptoms: Unconscious, not breathing. Treatment: Give rescue breathing. Press on stomach to remove water if bloated

and breathing is impaired. Clean mouth, loosen clothing. ------------------------------------------------------------------------------------------------------------------------- ELECTRIC SHOCK Symptoms: Unconscious, breathing stopped. Burn at point of contact. Treatment: Shut off electricity or insulate yourself from electrical source, then

rescue the victim. Give rescue breathing and/or CPR as necessary. ------------------------------------------------------------------------------------------------------------------------- FAINTING Symptoms: Face pale. Eyelids droop. Cold sweat. Weak, rapid pulse. Treatment: Lie victim down, loosen clothing. Keep warm and quiet. Check for

other injuries if person falls. ------------------------------------------------------------------------------------------------------------------------- FRACTURES (CLOSED) Symptoms: Pain, swelling, tenderness, bruising. Treatment: Support limb above and below fracture. Apply well padded splints if

injured must be moved. ------------------------------------------------------------------------------------------------------------------------- FRACTURES (OPEN) Symptoms: Open wound, bleeding, bone protruding. Treatment: Bandage wound. Apply splints in line of deformity if injured must be

moved. Do not straighten fracture. -------------------------------------------------------------------------------------------------------------------------

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FIRST AID (CONTINUED) ------------------------------------------------------------------------------------------------------------------------- FRACTURED SKULL Symptoms: Bleeding may be noticed from eyes, nose, or mouth. Blood or serum

from ears. Swelling of head wound. Treatment: Elevate head. Lay bandage on injury, avoiding pressure on the

wound. Never give a stimulant. Check victim periodically for a state of consciousness.

------------------------------------------------------------------------------------------------------------------------- POISONING - GAS/CHEMICALS Symptoms: Yawning, giddiness, fluttering heart, breathing stopped. Treatment: Remove to fresh air. Give rescue breathing. ------------------------------------------------------------------------------------------------------------------------- HEAT EXHAUSTION Symptoms: Cold wet skin, dizziness, headache, nausea, weakness. Treatment: Lie victim down, loosen clothing. Keep cool. Carefully give fluids. ------------------------------------------------------------------------------------------------------------------------- RUPTURE/HERNIA Symptoms: Sharp stinging pain. Faint feeling. Sick to stomach. Lump in groin. Treatment: Place injured on his back, elevate knees. Apply cold pack to lump. ------------------------------------------------------------------------------------------------------------------------- SHOCK Symptoms: Face pale, eyelids droopy, skin cold and clammy. Unconscious. Treatment: Lie victim down, elevate feet. Loosen clothing. Keep warm and quiet. ------------------------------------------------------------------------------------------------------------------------- SNAKE BITE Symptoms: Pain, swelling, pin point wound. Treatment: Apply restricting band 3 inches above wound and not too tight. If

alone, walk slowly for help. Be calm. Don't squeeze or cut the wound.

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COMPANY PROPERTY/EQUIPMENT DAMAGE When company property or equipment, other than vehicles, is damaged or stolen, it must be reported on the proper report form. A formal investigation should follow within 24 hours. The "ACCIDENT INVESTIGATION REPORT" should be used and filled out. VEHICLE ACCIDENT REPORTING: 1. When an employee is involved in a collision while operating a company or

personal vehicle on company business, he/she shall call the police to the scene for investigation. Supervision shall not interfere with police investigation.

2. The foreman of the employee shall also investigate the collision and

complete the appropriate "ACCIDENT INVESTIGATION REPORT" within 24 hours.

3. Employees, foremen and superintendents shall follow the company Vehicle

Policy. CITIZEN/PUBLIC ACCIDENTS (NON-AUTO): Public accidents shall be reported on blue "General Liability Accident Report" and

forwarded to the Corporate Office within 24 hours of the time the incident occurred. The "ACCIDENT INVESTIGATION REPORT" form should also be completed

within 24 hours. However, when there is a serious injury, it shall be reported by telephone immediately to the Safety Coordinator and followed by the reports listed above.

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REPORTING FORMS/FORMAT 1. COMMERCIAL SCAFFOLD, INC. "ACCIDENT INVESTIGATION REPORT"; This report is to be used for the reporting or investigation of "serious" employee

accidents/injuries, accidents involving property damage, or vehicle accidents, and any others.

2. STATE "EMPLOYER'S REPORT OF OCCUPATIONAL INJURY OR ILLNESS"; a. This form will be used by the Corporate Office when filing an employee injury

report under Worker's Compensation. b. The information supplied by the "foreman" on the "ACCIDENT

INVESTIGATION REPORT" form will be placed on the "State" form. Also information available on the medical reports and personnel records will be included.

3. "EMPLOYEE'S CLAIM FOR WORKERS' COMPENSATION BENEFITS" (Form

DWC-1). CALIFORNIA ONLY!!! It is imperative that any employee who has an injury, no matter how slight, be given

this form by the Foreman to fill out and return. Should the company fail to provide the form, Worker's Compensation benefits will be increased and the company will be subject to reprimand.

This form and its use became effective January 1, 1990. Under the Margolin - Bill

Greene Act of 1989, one of the requirements is that every employer provide an injured employee the claim form within 24 hours, whether requested by the employee or not, the employer is required to furnish the employee the form..

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RECORDKEEPING All accidents or injuries of any type shall be recorded, logged, and filed in their respective office, job site and personnel folders as may be applicable. 1. EMPLOYEE INJURIES: a. "LOG OF FIRST AID INJURIES" All employee occupational injury/illnesses will be logged on the job site first

aid log and copy sent to the office for recordkeeping purposes. b. "OSHA LOG OF RECORDABLE INJURIES" When an injury occurs which is more than a first aid injury (See definition

below), this would be classified as a "recordable injury" by OSHA definition. This log of injuries will be maintained by the office on the OSHA log (see OSHA Recordkeeping Guidelines).

(NOTE: A "FIRST AID" injury is one which only minor injuries occur and

which can normally be handled by a trained first aid person. This also includes initial treatment and a one time follow-up visit even if treated by a physician. However, once prescription medication is provided the injury is then required to be classified as a "recordable injury" per OSHA.)

c. "FIRST REPORT OF INJURY" A copy of the State "First Report of Injury" form must be attached to the

Foreman's "Accident Investigation Report" for all accidents entered on the OSHA log by the office and must be retained for at least 5 years.

2. VEHICLE, PROPERTY DAMAGE, AND PUBLIC LIABILITY ACCIDENT

REPORT LOGS: All other accidents and injuries reported to the Corporate Office will be

logged on separate accident logs to maintain and monitor the accident history for each type category, I.E. vehicle accidents, customer property damage, and public liability. The logs will identify the persons involved, i.e., driver, etc., job site/location, foreman, a short description of the accident, injury, time, date, and estimated cost.

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OSHA RECORDABLE INJURIES Deciding if work-related injuries are recordable Although the OSHA Act requires that all work-related deaths and illnesses be recorded, it limits the recording of injuries to certain specific types of cases. Sections 8(c)(2) and 23(a) of the OSHA Act refer to maintaining records for work injuries "...other than minor injuries requiring only first aid treatment, and which do not involve medical treatment, loss of consciousness, restriction of work or motion, or transfer to another job." Consequently, a work-related injury must involve at least 1 of these 4 conditions before it is deemed recordable. Minor injuries requiring only first aid treatment are not recordable. 1. Medical treatment: It is important to understand the distinction between medical

treatment and first aid treatment since many work-related injuries are recordable only because medical treatment was given.

Part 1904.12(d) of the regulations and the instructions on the back of the log and

summary, OSHA No. 200, define medical treatment as any treatment, other than first aid treatment, administered to injured employees. Essentially, medical treatment involves the provision of medical or surgical care for injuries that are not minor through the application of procedures or systematic therapeutic measures.

The OSHA Act also specifically states that work-related injuries which involve only

first aid treatment must not be recorded. Therefore, the definition of first aid treatment has important implications for evaluating potential medical treatment cases. First aid is commonly thought to mean emergency treatment of injuries before regular medical care is available. However, first aid treatment has a different meaning for OSHA record-keeping purposes.

2. First Aid Treatment: Part 1904.12(e) of the regulations defines first aid treatment as: Any one-time treatment, and any follow-up visit for the purpose of observation, of

minor scratches, cuts, burns, splinters, and so forth, which do not ordinarily require medical care. Such one-time treatment, and follow-up visit for the purpose of observation is considered first aid even though provided by a physician or registered professional personnel.

The distinction between medical treatment and first aid depends not only on the treatment provided, but also on the severity of the injury being treated.

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First aid is: (1) Limited to one-time treatment and subsequent observation; and (2) involves treatment of only minor injuries, not emergency treatment of serious

injuries. Injuries are not minor if: (a) They must be treated only by a physician or licensed medical personnel; (b) They impair bodily function (i.e., normal use of senses, limbs, etc.); (c) They result in damage to the physical structure of a non-superficial nature

(e.g., fractures); or (d) They involve complications requiring follow-up medical treatment. Physicians or registered medical professionals, working under the standing orders of a physician, routinely treat minor injuries. Such treatment constitutes first aid. Also, some visits to a doctor do not involve treatment at all. For example, a visit to a doctor for an examination or other diagnostic procedure to determine whether the employee has an injury does not constitute medical treatment. Conversely, medical treatment can be provided to employees by lay persons; i.e., someone other than a physician or registered medical personnel. The following classifications list certain procedures as either medical treatment or first aid treatment. MEDICAL TREATMENT: The following are generally considered medical treatment. Work-related injuries for

which this type of treatment was provided or should have been provided are almost always recordable:

· Treatment of INFECTION · Application of ANTISEPTICS during second or subsequent visit to medical

personnel · Treatment of SECOND OR THIRD DEGREE BURN(S) · Application of SUTURES (stitches) · Application of BUTTERFLY ADHESIVE DRESSING(S) or STERILE

STRIP(S) in lieu of sutures · Removal of FOREIGN BODIES EMBEDDED IN EYE

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MEDICAL TREATMENT (continued): · Removal of FOREIGN BODIES FROM WOUND; if procedure is

COMPLICATED because of the depth of wound, size, or location · Use of PRESCRIPTION MEDICATIONS (except a single dose administered

on first visit for minor injury or discomfort) · Use of hot or cold COMPRESSES during second or subsequent visit to

medical personnel · CUTTING AWAY DEAD SKIN (surgical debridement) · Application of HEAT THERAPY during second or subsequent visit to

medical personnel · Use of WHIRLPOOL BATH THERAPY during second or subsequent visit to

medical personnel · POSITIVE X-RAY DIAGNOSIS (fractures, broken bones, etc.) · ADMISSION TO A HOSPITAL or equivalent medical facility FOR

TREATMENT. FIRST AID TREATMENT: The following are generally considered first aid treatment (e.g., one-time treatment

and subsequent observation of minor injuries) and should not be recorded on the OSHA Log 200 if the work-related injury does not involve loss of consciousness, restriction of work or motion, or transfer to another job:

· Application of ANTISEPTICS during first visit to medical personnel · Treatment of FIRST DEGREE BURN(S) · Application of BANDAGE(S) during any visit to medical personnel · Use of ELASTIC BANDAGE(S) during first visit to medical personnel · Removal of FOREIGN BODIES NOT EMBEDDED IN EYE if only irrigation

is required · Removal of FOREIGN BODIES FROM WOUND; if procedure is

UNCOMPLICATED, and is for example, by tweezers or other simple technique.

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· Use of NONPRESCRIPTION MEDICATIONS AND administration of single

dose of PRESCRIPTION MEDICATION on first visit for minor injury of discomfort.

· SOAKING THERAPY on initial visit to medical personnel or removal of

bandages by SOAKING · Application of hot or cold COMPRESSES during first visit to medical

personnel · Application of OINTMENTS to abrasions to prevent drying or cracking · Application of HEAT THERAPY during first visit to medical personnel · Use of WHIRLPOOL BATH THERAPY during first visit to medical personnel · NEGATIVE X-RAY DIAGNOSIS · OBSERVATION of injury during visit to medical personnel The following procedure, by itself, is not considered medical treatment: 1. Administration of TETANUS SHOT(S) or BOOSTER(S): However, these shots

are often given in conjunction with more serious injuries; consequently, injuries requiring these shots may be recordable for other reasons.

2. Loss of consciousness: If an employee loses consciousness as the result of a

work-related injury, the case must be recorded no matter what type of treatment was provided. The rationale behind this recording requirement is that loss of consciousness is generally associated with the more serious injuries.

3. Restriction of work or motion: Restriction of work or motion is the third criterion

specified by the Act for determining whether an injury is serious enough to be recorded. The decision that a case involves restricted work activity should be made solely on the rules set forth in Part 1904.12(f) of the Code of Federal Regulations and in the instructions to the Log and Summary of Occupational Injuries and Illnesses, OSHA No. 200. The central concept established in these sections is that restricted work activity occurs when the employee, as a result of a job-related injury or illness, is physically or mentally unable to perform all or any part of his or her normal assignment during all or any part of the workday of shift. The emphasis is on the employee's ability to perform normal job duties. Restriction of work or motion may result in either a lost work-day injury or a non-lost work-day injury, depending upon whether the restriction, extended beyond the date of injury. This distinction is discussed at length in Chapter VI.

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Restriction of work or motion sometimes is the sole reason for recording a case.

For example, if an employee suffers a cut on a joint of the first finger and the sound requires only a small bandage, the bandage may prevent bending the finger. This case involves a work-related injury, but is it recordable? The employer can reasonable conclude that no medical treatment was involved nor was there any loss of consciousness or transfer to another job. The case would be recordable only if it involves restriction of work motion; that is, if the motion that was limited affected the employee's limitation of motion in the abstract. In this situation, the case would be recordable if it involved a typist who was unable to type, but probably not if it involved an executive.

4. Transfer to another job: Injuries requiring transfer of the employee to another job

are also considered serious enough to be recordable regardless of the type of treatment provided. Transfers are seldom the sole criterion for it being recordable because injury cases are almost always recordable on other grounds, primarily medical treatment or restriction of work or motion.

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ACCIDENT INVESTIGATION ALL ACCIDENTS MUST BE INVESTIGATED All accidents must be investigated by the foreman, superintendent, or Safety Coordinator. A Supervisors Accident Report form must be filled out, signed by the foreman and sent to the Safety Coordinator for each and every accident. Most of our customers will also require that we investigate each accident, and they may have their own investigation form that we will be required to complete. The main purpose of the investigation is not to determine who was at fault, but to understand what occurred and how to prevent it from happening again. A sample copy of the Supervisors Accident Investigation Report has been included in this manual. Additional copies are available from the Safety Coordinator or the Corporate Office. "NEAR MISS" ACCIDENTS (Near Accident Reporting): COMMERCIAL SCAFFOLD, INC. employees will regard all "near accidents" as if they actually caused bodily injury or damage to equipment and will be reported on a accident report form. An accident investigation review will be held as soon as possible to determine the

cause and methods to prevent future occurrences. Accident investigation and reporting will be conducted in accordance with procedures found in the COMMERCIAL SCAFFOLD, INC. Safety Manual.

The following COMMERCIAL SCAFFOLD, INC. employees will attend this

meeting:

• Project Coordinator

• Project Safety Representative

• Superintendent

• Foreman

• Employees involved

• Witnesses

• Client Representative

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ACCIDENT INVESTIGATION PROCEDURE PURPOSE: The purpose of accident investigation is to identify those unsafe conditions and acts which contribute to injuries in order that solutions for accident prevention may be proposed. Accident investigation is an invaluable tool in controlling losses. Each accident must be considered a total loss unless it's true cause is objectively determined and all contributing deficiencies are corrected. Thorough investigation, reporting, recording and corrective follow-up of each incident/accident can be time consuming. However, putting forth the necessary time and effort to prevent the reoccurrence of each accident is an invaluable investment that will pay compounded benefits to employees and management as the number of accidents decrease. EMPLOYEE ACCIDENTS: All accidents regardless of whether or not they result in injury should be thoroughly investigated by the employee's immediate Foreman and reported to the Superintendent or Corporate Office within 24 hours. This should include "near miss" accidents. The investigation should be extensive enough to allow the Foreman to suggest practical corrective action. A written report should be made which includes: 1. Injured employee's statement concerning the accident. 2. Statements from other witnesses. 3. Complete description of the accident including the type of work in which the

employee was involved. 4. Evaluation of unsafe conditions and acts. 5. Recommendations for action to prevent similar accidents. DEFINITIONS: Industrial Injury: An injury arising out of and in the course of employment with the company. Occupational Illness: A disease caused by specific hazardous conditions or materials when there is a direct relationship between the conditions under which the work is performed and the occupational disease.

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PROCEDURES FOR INVESTIGATING AN ACCIDENT/LOSS 1. Check the Scene a. Begin where the accident occurred. The first step is to carefully examine

where the injury occurred. b. Reconstruct as much as possible the chain of events leading up to the

injury, and attempt to determine the single event that caused the injury. Have the employee tell you what happened. If necessary, have him/her show you up to the point where the injury occurred. DO NOT let them do the part of the incident that resulted in the injury.

c. Draw a diagram of the location if it will be helpful in arriving at a conclusion. d. Sketch in machinery, equipment and any other nearly physical objects,

together with the places where witnesses were standing. 2. Write it Down a. Make notes on all facts that may relate to the cause of the injury. As an

example: employee had complained of dizziness or employee had not used proper equipment, etc.

b. Write down any procedure used; that is, unsafe act, etc. c. Write down any unsafe conditions in work area, i.e. defective tools or faulty

equipment noted. d. Write down such other items as: the time of your investigation, the lighting

conditions, the weather conditions, if pertinent, a description of supplementary evidence, and conversations having a bearing on the case.

3. Collect the Evidence If an injury or near miss occurs when machine parts or structures fail, it is essential

to determine what failed and why. This can frequently be done without laboratory analysis and corrective action can be initiated without great expense. If, however, a detailed study is determined to be essential, then all components shall be collected and submitted for study immediately if cost of analysis is economically feasible.

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4. Interview Witness It is important to interview witnesses at the scene or as soon thereafter as possible.

Make brief notes and identify who gave the information. 5. Interview the Victim a. Timing is important. If the injury is minor, the interview should be made as

soon as the investigation of the scene and a review of the medical report is complete.

b. If the injury is serious, selecting the right time is a judgment factor. Too soon

afterward and the victim may be confused and inaccurate; waiting too long may cause them to be cautious and evasive. Let the employee tell the story as they wish without actual interrogation, but a complete picture should be encouraged. The interview must be complete, and it may be necessary to question the employee or witnesses several times in order to verify information and stories.

6. Weigh the Evidence a. It is essential to eliminate any inconsistencies in the testimony of the injured

or witnesses even if further questioning is required. b. When assembled, all facts should be reviewed for completeness before

submission on the "Accident Investigation Report" Form to the Superintendent or Corporate Office.

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ACCIDENT INVESTIGATION REPORT

EMPLOYEE INJURY OR ILLNESS DATE FLEET OR PROPERTY DAMAGE

NAME PROPERTY DAMAGED

OCCUPATION

PART OF BODY ESTIMATED COST ACTUAL COST

NATURE OF INJURY OR ILLNESS

NATURE OF DAMAGE VEHICLE SPEED

OBJECT/EQUIPMENT/ELEMENT INFLICTING INJURY OR ILLNESS

OBJECT/EQUIPMENT INFLICTING DAMAGE REGISTRATION NO.

PERSON WITH MOST CONTROL OF OBJECT/EQUIPMENT/ETC.

PERSON WITH MOST CONTROL - INFLICTING DAMAGE

JOB OR ACTIVITY AT TIME OF ACCIDENT

DEPARTMENT

EXACT LOCATION

DATE OF OCCUR. TIME AM/PM DATE REPORTED

DESCRIBE CLEARLY HOW THE ACCIDENT OCCURRED (WHAT HAPPENED?) FOR ALL MOTOR VEHICLE ACCIDENTS, DRAW A DIAGRAM ON THE OTHER SIDE

THE CAUSE OF THE ACCIDENT: WHAT ACTS, FAILURE TO ACT, AND/OR CONDITIONS CONTRIBUTED MOST DIRECTLY TO THIS ACCIDENT?

DESCRIBE ANY UNSAFE ACTS AND/OR UNSAFE CONDITIONS

EXPLAIN SPECIFICALLY WHY THESE ACTS AND/OR CONDITIONS EXISTED?

LOSS SEVERITY POTENTIAL ¨ MAJOR ¨ SERIOUS ¨ MINOR

PROBABLE RECURRENCE RATE ¨ FREQUENT ¨ OCCASIONAL ¨ RARE

WHAT ACTION HAS OR WILL BE TAKEN TO PREVENT RECURRENCE? (LIST ITEMS, THEN PLACE AN "X" BY ITEMS COMPLETED AND DATE)

SUPERVISOR OF INJURED PERSON

DATE REVIEWED BY MANAGER DATE

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FOREMAN'S (SUPERVISOR'S) SAFETY MEETING INTRODUCTION: Safety communication is important for all levels of the company. But there is no place more important than within the management organization. In order to keep supervision and management (Foremen, and Superintendents) informed on safety issues that pertain to the company, a Foremen's (Supervisors) safety meeting will be held periodically, but at least quarterly. The company relies upon supervision to communicate the safety policies and set the example for safety on the job for employees to follow. The Foremen's safety meeting will provide the necessary forum for the above objectives to be implemented and maintained. PURPOSE: To establish a program of safety communication, education and training for all supervisory personnel, foremen, and superintendents, on a regular basis. OBJECTIVES: 1. To communicate job safety and health procedures and requirements established

either by the company or others. 2. To communicate accident statistics respective of their jobs and the company as a

whole. 3. To provide an educational forum on applicable safety subjects and issues. 4. To provide information and training on legal issues of job safety and health that

affect the job. 5. To review job safety survey's and issues affecting the job site to which they are

assigned.

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PROCEDURES: I. Minimum Action Standard - At least quarterly, a safety meeting will be held where

all foremen and job superintendents are required to attend. These meetings will be held under the direction of senior management. The meetings will be chaired by a senior member of management or the Safety Coordinator. The following standards should be met for all meetings:

a. The meetings (at least quarterly) will be held at the end of the work day. The

meetings should be held on the same day of the month such as the second Wednesday of each month scheduled.

b. The meetings should last from 30 minutes to 1 hour in length in order to

adequately cover the material to be presented. c. An agenda and notification should be prepared in advance in order to inform

the job foremen of the material to be discussed. It will serve as a reminder for the meeting. (See attached).

d. Minutes of the meeting should be recorded on "Foremen's Safety Meeting"

report form. e. The completed minutes will be posted in the Corporate Office and each job

site within 7 days of the meeting. f. The topics and material to be discussed will be prepared in advance in order

to maintain time and attention of those attending. On any job site where the General Contractor holds a safety meeting of "his"

subcontractors such as COMMERCIAL SCAFFOLD, INC. and others, the Superintendent or other designated individual will attend those meetings. (In some cases the job foreman will represent the company).

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II. Preparation and Planning - Prior to each meeting the Safety Coordinator will

prepare the information necessary for review. This will include: a. A review of the minutes from the previous safety meeting. b. A review of past accidents and claims since the last meeting. This would

include all areas of loss exposure. c. A progress report on what has been accomplished on any previous

recommendations. d. A review of job site safety surveys and foremen's safety inspection

completed since the last meeting. e. An outline of subject material to be presented; such as, company policy or

procedures, safety rules and regulations of the company or State, educational programs or information.

f. A review of any alleged hazardous conditions brought to the attention of any

committee member since the last meeting. g. A review of any employee safety suggestions submitted since the last

meeting.

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MINUTES FOREMEN'S SAFETY MEETING Minutes of the meeting of ,199 at The meeting was called to order at by Those Foremen attending were: Minutes of the previous meeting were reviewed. Review of past accidents and claims. Progress reports were given on what has been done about previous recommendations. (Describe) The Foremen's Safety Inspection reports were reviewed and their recommendations were discussed. Any recommendations are listed: Other business discussed. The meeting adjourned at Signature of Superintendent COPIES TO: OFFICE (ORIGINAL) JOB SITE FILE SAFETY COORDINATOR

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AGENDA FOREMEN'S SAFETY MEETING Date of Meeting: Time of Meeting: a.m./p.m. Location of Meeting: Those invited to attend: I. Call to order by Chairman. II. Review of minutes of prior meeting. III. Review of all past accidents and claims with identification of trends and

accident-prone areas or types of accidents since last meeting. IV. Progress reports on what has been done or accomplished on previous

recommendations. V. Review of findings of the most recent hazard surveys and new

recommendations. VI. Review of hazards brought to the attention of the safety committee

members. VII. Review of employee suggestions or recommendations. VIII. Other business: A. B. C. IX. Adjournment COPIES TO: OFFICE (ORIGINAL) JOB SITE FILE SAFETY COORDINATOR

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TAILGATE SAFETY MEETINGS Each foreman is the official management representative for his group of employees. It is the foreman who the company as well as employee looks to who sets the example of company policy, philosophy, and communication. Safety communication is a key to employee safe work behavior. The tailgate safety meeting is one method of providing this line of communication with employees which in time will assist in enhancing job safety performance. OBJECTIVES: A. To encourage safety awareness. B. To get employees actively involved. C. To motivate employees to follow proper safety practices. D. To encourage employees to report or discuss job hazards. E. To introduce workers to new safety rules. F. To provide vital information on accident causes and types. PROCEDURES Minimum Action Standard - Each job foreman will meet at least once every other week (bi-monthly) with his employees in a group meeting to communicate on safety issues. a. The meetings should be held at the beginning of the shift, preferably on the first

work day of each week. b. The meeting should last from 5 to 10 minutes. c. The topic of the meeting should be prepared in advance in order to maintain

employees attention. d. Minutes of the meeting should be recorded on the "Safety Meeting Report Form".

(See attached) f. The completed reports, with the signatures of all employees who attended would be

turned into the job Corporate Office within 24 hours of being completed. Preparation and Planning Prior to each meeting, the foreman may receive a written and prepared safety talk from the Corporate Office. This tool can be effectively used and presented directly to the employees by reading it. However, in some instances the written topic may not be available. Under these circumstances, the foreman will be required to formulate a meeting "script" on his own. The following outline will assist the foreman to develop his own meeting topic: 1. Choose your topic carefully: Such things as a recent accident, new

equipment or dangerous new work will be impressive. 2. Gather your facts and figures: Be sure they are complete and accurate; use

visual aids if possible. 3. Map out your presentation: Outline your topic; what you hope to

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4. Keep within a time limit: The meeting should last from 5 to 10 minutes, or

longer; set a time table and stick to it; employees will pay more attention when the time does not drag on unreasonably.

5. Devise strategies to get employees involved: Discuss safety; ask questions

that require more than a yes or no reply of the employee. How to Conduct a Meeting If you have done your preparation and planning, the meeting will practically run itself. While some foremen are not in the habit of conducting weekly safety sessions and may not be comfortable doing so, experience usually will stop these feelings. Whether presenting a safety topic in written form from the office, or preparing one yourself, the basic steps listed below should be followed in order to maintain employee attention and interest: A. Introduce the Topic: Begin with the meat of the subject matter or the reason for the

meeting. Use some humor if appropriate. B. Present the Facts: Be concise as possible when providing any information to the

employees. Use only credible facts and figures. Present them in as interesting a manner as possible.

C. Demonstrate: Use visual aids to demonstrate your point. Use employees to "act

out" or role play a new safety procedure or policy to give the meeting added impact. D. Open the meeting up for discussion: Use this time for questions and answers,

clarify any misunderstandings, and obtain feedback from the employees. E. Summarize the major points: Recap the key points you have discussed. End the

meeting on a note of things that the employee should remember. F. When you have selected a topic or been provided one for your weekly meeting,

review the material in advance to familiarize yourself with the information. Use any supplemental material you can think of to reinforce or illustrate the meetings' subject matter. Make a note on the outline material where you may want to emphasize important information or add any appropriate facts, or accident statistics.

G. When presenting the meeting from a prepared topic, try not to read the information

word for word, but if it is necessary to do so, this method is better than no meeting. It is better to be prepared and know what you are to say, visual aids readily accessible, support equipment available, and demonstration rehearsed. This will allow the meeting to run more smoothly and keep employees attention. Employees will otherwise be distracted by disorganization, rambling discussion, or ill planned demonstration.

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TAILGATE SAFETY MEETING I. Employees Present: 1. 7. 2. 8. 3. 9. 4. 10. 5. 11. 6. 12. II. Items Discussed: 1. Prepared safety topic. 2. Review unsafe situations mentioned at previous meeting. 3. Review any safety suggestions from the crew. 4. Review of hazards expected in today's work. 5. 6. 7. 8. 9. III. Comments: This safety meeting conducted by: Date: Site: COPIES TO: OFFICE (ORIGINAL) SAFETY COORDINATOR

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JOB SITE INSPECTIONS & HAZARD CORRECTION Employee injuries and liability claims resulting from the unsafe actions by an employee or because of an unsafe condition on a company job site or facility constitutes a significant financial drain upon company capital. While some conditions are beyond our control, we must use our best efforts toward eliminating the causes. It is the responsibility of every employee to assist in the identification of hazardous conditions or unsafe actions of employees in order to prevent losses and injury. These are also key responsibilities on the part of every foreman in conducting their every day duties. The following procedure outlines the role of all company employees for hazard recognition: PURPOSE To establish a plan for the systematic recognition and control of work place hazards (unsafe acts and conditions) through periodic safety surveys. OBJECTIVE a. Eliminate or control unsafe acts and conditions before they result in accidents or

exposures that may produce injury and/or damage. b. Stimulate regular employee hazard detection and control activity. c. Provide a mechanism for employees to formally report hazards and to make safety

recommendations. PROCEDURE A. DEFINITIONS 1. Hazard - An unsafe act or unsafe condition that may cause an exposure,

accident or injury. 2. Unsafe act - Means not following proper work procedures or the violation of

the safety rules. It is what the employee did or failed to do that has or could have resulted in an exposure or accident (There are various factors which influence the employee to act in an unsafe way including mental, emotional, physical, and attitudinal problems).

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3. Unsafe condition - Any hazardous physical condition that is unguarded or

uncontrolled is an unsafe condition. It is any part of employee's physical surroundings that has or could have resulted in an accident or exposure (factors such as the deterioration of equipment, poor design of equipment, inadequate maintenance; even the unsafe actions of employees are the source of unsafe conditions).

B. PROGRAM PHILOSOPHY It is the responsibility of "all" employees to identify any hazardous condition on the

job site. However, it is each foreman's responsibility to make a planned systematic daily survey of his job site for hazard detection and control.

Thoughtful preparation for hazard detection produces a greater likelihood of

identifying critical (high risk) hazards. It is generally the more obscure high risk hazard that produces the severe injuries and illnesses. The supervisor of the employee performing the work is in the best position to detect and control high risk, unsafe acts.

C. HAZARD RECOGNITION AND CONTROL 1. Minimum Action Standard - At least bi-weekly (every other week), the

actions listed below should be incorporated into each foreman's work activities. It is the foreman's responsibility to monitor the worksite for unsafe acts or unsafe conditions by implementing the following actions:

a. Conduct observations of employees performing job/task, record any

unsafe acts and take required hazard control action. b. Make a survey of tools, machines, equipment or work areas to identify any

unsafe condition and take any required hazard control action. c. Record and act on any unsafe acts or unsafe conditions brought to

the foreman's attention by others. 2. Corrective Action - When any unsafe act or unsafe condition is observed, it

requires that the foreman take one or more of the following actions within 24 hours after identifying and recording a hazard:

a. Eliminate or control the detected hazard. Always take immediate

temporary control (ITC) action.

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For those hazards which cannot be immediately controlled or

eliminated, the action necessary for correction should be documented with a date established for completion. Complete the form "REQUEST FOR CORRECTIVE ACTION" for follow-up, of those hazards that cannot be controlled within 24 hours.

A copy of this report is to be sent to the Corporate Office. Each job

site will maintain a log of incomplete items which will be reviewed at the monthly Foreman's Safety Meeting. Any item that has not been corrected will be identified in the review of all inspection items at that time.

Imminent Danger: Should an imminent danger be associated with

any job site, the hazard must be immediately corrected before work continues or the job site shut down and all personnel removed from the area until corrected. If it is necessary for company personnel to enter the area of "imminent danger" to correct the hazard, then only the minimum number of personnel necessary are permitted to re-enter the area using extreme caution and with the necessary safeguards, equipment, and provisions that will minimize their exposure to the hazard.

b. Schedule for correction those hazards which may require more than

24 hours for control and provide protection against the hazards until they are corrected.

c. Pass to higher supervision all hazards which may require

assistance due to limitations of responsibility or authority. The foreman will retain the responsibility for follow-up and corrective action until the hazard is corrected. The form, "REQUEST FOR CORRECTIVE ACTION", should be used for this purpose.

3. JOB SITE INSPECTION FORM a. The "JOB SITE SAFETY INSPECTION FORM" is to be used on a

bi-weekly basis to record all job/task observations, and hazard detection and control activity.

The form will be sent to the Company Office with the Tailgate Safety

Meeting form. The Safety Coordinator will maintain the Inspection Forms and monitor completion of the items.

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b. The reports will remain on file for five (5) years for audit and reference

purposes. c. Job/task observation and unsafe act recording: The name of

employee(s) should be recorded for necessary follow-up. D. EMPLOYEE PARTICIPATION 1. The foreman should encourage employees to bring hazards to his/her

attention without fear of reprisals. When an employee advises the foreman of a hazard, the foreman should immediately record the hazard and note the employee's name on the JOB SITE SAFETY INSPECTION FORM. The foreman should discuss the employee's views on the significance or urgency of the hazard in question to avoid any possible misconceptions concerning control timing. After the foreman has evaluated and/or controlled the hazard, he should personally advise the employee of what action was taken.

2. In the event the foreman and the employee differ regarding the existence of

a hazard and, in the foreman's best judgment, no action is necessary, the following steps should be taken:

a. Avoid any rejecting comments during the initial contact. b. Provide impersonal, objective reasons for the rejection after review. c. If the employee persists, review the question with the Superintendent,

Project Manager, or Safety Coordinator for final disposition.

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SUPPLEMENTAL SHEET #1 JOB/TASK OBSERVATION Job/task observation simply involves determining whether employees are performing their work (duties) safely. The intent is to conduct a planned observation, i.e. to observe the employee(s) at work; what job/task, when, etc. for unsafe practices rather than mere casual looking. Among other benefits, the technique is excellent for identifying whether employees are following the general safety rules or the job safety procedures. Targets for Observation * Inexperienced employee * Poor performer * Accident repeater * Troubled employee * Chronic unsafe behavior * Unusual/infrequent jobs What to Observe For * Positions of employees * Protective equipment * Actions of employees * Work methods/procedures * Tools/Equipment * Orderliness Observation Process 1. Prepare 4. Contact employee 2. Conduct observation 5. Record results 3. Mental notes 6. Follow-up Modifying Unsafe Behavior 1. Re-instruction 4. Counseling 2. Education/training 5. Warning/reprimand 3. Reasoning/persuasion 6. Discipline

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SAFETY INSPECTION CHECKLIST LOCATION SUPERVISOR INSPECTOR DATE All items that need correction are marked with "C". Note the corrections needed and suggestions for corrective action below. Unless noted, all other items are acceptable. (Unsafe Actions of Employees) ¨ 1. Personal protective equipment being worn as required? ¨ 2. Employees safety trained for the job being performed? ¨ 3. Employees following proper work procedures? (Unsafe Conditions) ¨ 4. Walkways, floors, and work areas properly maintained? ¨ 5. Housekeeping and cleanup adequate? ¨ 6. Office equipment properly maintained? ¨ 7. Power tools or equipment maintained and guarded? ¨ 8. Flammable liquids properly used, identified, and stored? ¨ 9. Chemicals properly labeled, used, and stored? ¨ 10. Adequate illumination provided? ¨ 11. Adequate ventilation provided? ¨ 12. Environmental hazards reviewed and maintained? ¨ 13. Fire protection equipment provided and maintained? ¨ 14. First Aid and emergency medical supplies available? ¨ 15. Sanitation and drinking facilities properly maintained? ¨ 16. Safety communication and publicity provided? ¨ 17. Emergency procedures and phone numbers posted? CORRECTIONS MADE: SUGGESTIONS: COMPLETED BY: DATE: COPIES TO: OFFICE (ORIGINAL) SAFETY COORDINATOR

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REQUEST FOR CORRECTIVE ACTION OPTIONAL: INDIVIDUALS MAY SUBMIT THIS FORM ANONYMOUSLY. NAME: JOB TITLE: LOCATION OF CONDITION BELIEVED TO BE UNSAFE OR HAZARDOUS: DATE AND TIME CONDITION OR HAZARD OBSERVED: DATE TIME DESCRIPTION OF UNSAFE CONDITION OR HAZARD: WHAT CHANGES WOULD YOU RECOMMEND TO CORRECT THE CONDITION OR HAZARD? OPTIONAL: SIGNATURE DATE COMPANY RESPONSE: NAME OF PERSON INVESTIGATING REPORT: RESULTS OF INVESTIGATION: WHAT WAS FOUND? WAS CONDITION UNSAFE OR A HAZARD? (ATTACH ADDITIONAL SHEETS IF NECESSARY): ACTION TAKEN TO CORRECT HAZARD OR UNSAFE CONDITION, IF APPROPRIATE; (OR ALTERNATIVELY, INFORMATION PROVIDED TO INDIVIDUALS AS TO WHY CONDITION WAS NOT UNSAFE OR HAZARDOUS) (ATTACH ADDITIONAL SHEETS IF NECESSARY): SIGNATURE OF INVESTIGATOR: DATE:

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EMPLOYEE SAFETY & HEALTH SUGGESTIONS INTRODUCTION On occasion, employees do not notify the company of impending danger or hazards on the job. This may be due to a fear of reprisal, fear of rejection, lack of encouragement by their supervisor, or many other reasons. An informal, and if desired, anonymous method will provide another means for a bashful employee to inform the company of important safety information. PURPOSE 1. The "EMPLOYEE SAFETY & HEALTH SUGGESTION FORM" is to be used by

employees to formally report hazards not handled directly by their superior or for the presentation of suggestions to improve the safety & health of their job and the company.

2. The form is designed to be used to ensure that: a. The employee is provided with a means of reporting a safety or health

problem without fear of reprisal. b. Feedback is provided to the employee on their suggestions, whether positive

or negative. PROCEDURE Management and supervision should encourage employees to utilize the Safety & Health Suggestion Form at any time they would like to make a safety or health suggestion or observation. The forms should be made available at various locations within the site or facility where employees may easily find them. Each location should be readily identifiable and a means for depositing the completed forms provided. The deposit "boxes" must be made secure so that the completed forms can be collected by persons designated by the Safety Coordinator only. The forms should be collected daily. For if a hazard of imminent danger were to go unnoticed, the potential for a serious accident increases. Any suggestion found to identify a condition of imminent danger will require that immediate corrective action be taken. Otherwise all other items will follow the same procedures for corrective action as those noted during regular inspections. A review of the suggestions will be made by the Superintendents, and Safety Coordinator. If the employee has given their identity, it is important for the Safety Coordinator to provide a response on the action to be taken. The employee should be thanked for their participation.

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EMPLOYEE SAFETY & HEALTH SUGGESTION FORM I WOULD LIKE TO REPORT, WITHOUT FEAR OF REPRISAL, WHAT I BELIEVE TO BE IS A SAFETY/HEALTH HAZARD THAT MAY CAUSE INJURY, ILLNESS, DEATH, OR DAMAGE TO AN EMPLOYEE, OR THE PUBLIC. DESCRIBE SAFETY/HEALTH PROBLEM: LOCATION: SUGGESTION (TO CORRECT PROBLEM): EMPLOYEE'S NAME (OPTIONAL) RECEIVED BY: DATE: REVIEW AND COMMENTS COMMENTS: REVIEWED BY: DATE: COMMENTS: REVIEWED BY: DATE: COMMENTS: REVIEWED BY: DATE: ACTION TO BE TAKEN APPROVED BY: EFFECTIVE DATE: COPIES TO: OFFICE (ORIGINAL) - SAFETY COORDINATOR -SUPERVISOR

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SAFETY TRAINING AND COMMUNICATION The effectiveness of any safety program is directly related to the quality of employee safety training by supervision, a thorough understanding of the hazardous related to any job, and the ability to consistently follow safe practices specified in published work rules. A. SAFETY TRAINING OF SUPERVISION Each supervisor (Foreman, General Foreman, Job Superintendent, or General

Superintendent) is responsible to be familiar with the policies and procedures in this manual as they apply to their operations and employees. Ability to do so will enable them to provide employees with an under-standing of the company safety standards and their jobs.

It is mandatory that each foreman provide the necessary training for their workers in

order to help eliminate accidents. Supervision will periodically be provided with safety training in order to upgrade

their skills with both job requirements and employee participation in safety. B. SAFETY TRAINING OF EMPLOYEES It is most important that each worker be familiar with the hazards that may exist for

the job that they are assigned. The foreman must insure that his workers understand the methods of doing each

job safely. The company has established many employee job training programs that

emphasize the safest way in which to perform a job task. It will be important that supervision work with employees to maintain the highest level of quality in their work: the quality of the job and the quality of safety.

Employees should be encouraged to assist in identifying hazardous conditions to

which they may be exposed. When certain hazards cannot be totally eliminated, the supervisor must ensure that special methods or procedures be adopted to control the hazards or exposures. It is therefore essential that the foreman utilize the published work rules as a tool to train employees as well as hold employees accountable for safe work performance by:

1. Prior to beginning work, and particularly at the beginning of the shift, each

foreman should identify or define each hazardous task that their workers may encounter.

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2. The foreman should take time to review the work rules for which their people

are responsible and define the correct work procedures for the safe method to accomplish the task. This will enable the foreman to attain a consistent quality of instruction that instills employee confidence in their own capabilities and those of the foreman.

3. By reviewing with the employee a copy of the work rules after instruction,

they will have a ready reference for their review at any time. 4. Upon completion of any training that the foreman may provide, whether

upon initial indoctrination of the employee or during any other time, the training given should be documented on the EMPLOYEE SAFETY TRAINING RECORD. The foreman should also have the employees sign the TRAINING CLASS RECORD sheet.

5. All training should be documented on the EMPLOYEE SAFETY TRAINING

RECORD with the name of the employee, type of training received, date, and name of the provider.

COMMUNICATION OF SAFETY AND HEALTH MATTERS Employee involvement is key to the success of COMMERCIAL SCAFFOLD, INC.'s effort to prevent injuries and illnesses in the workplace. Communication is the primary means by which employees become involved in safety. Communication must be a dialogue. Safety information has to be in the hands of the front line employee. Conversely, the safety concerns and suggestions of workers must be heard by management. The following describes some of the mechanisms by which safety and health issues are communicated. SAFETY SUGGESTION PROGRAM This program is managed by the Safety Department, which evaluates employee input and takes appropriate action. These suggestions and comments are also routed through the line management chain. The Safety Department, in concert with Site Supervisors, will coordinate with customer representatives where appropriate. This information can also be disseminated laterally through the Safety Coordinator and toolbox meetings. JOB SITE BULLETIN BOARDS Each major job site will have a safety bulletin board in a conspicuous location. This board can be inside the office trailer, provided it is readily accessible to all employees and that employees are aware of its location. Outside boards should be protected from the elements as much as possible. Safety information posted should be separate from other postings (wage orders, training info, schedules, etc.). Employee input and suggestions are encouraged.

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TOOLBOX (TAILGATE) MEETINGS Toolbox meetings are small, informal meetings held by a foreman with his crew. The meetings are to be held at least bi-weekly. Each meeting should cover some specific safety topic or have a focus. They are not designed to be one way training sessions. Employees should actively participate in the meetings, voicing their concerns, sharing experiences, and asking questions. One very worthwhile approach is to designate an employee to conduct a toolbox meeting, rotating this responsibility through the crew. The Safety Department can assist in the development of subjects, formats, and training aids for these meetings. Attendance rosters and lists of topics covered are required. C. SAFETY TRAINING OUTLINE/GUIDE No foreman/supervisor should assume that a newly hired, newly-assigned, or

reassigned employee thoroughly knows all the safe job procedures or the way in which COMMERCIAL SCAFFOLD, INC. knows of the best way in which a job should be done. Each employee must be trained.

The four-point method of job instruction has been found best for all hazardous operations: Preparation, Presentation, Performance, and Follow-up.

1. Preparation a. Put the employee at ease. b. Define the job and find out what the employee already knows about it. c. Get the worker interested in learning the job. d. Place the employee in the correct position to do the work. 2. Presentation a. Tell, show, and illustrate one important step at a time. b. Stress each key point. c. Instruct clearly, completely, and patiently, but cover no more than the

employee can master each time. 3. Performance a. Have the worker do the job; coach the employee while working. b. Have the employee explain each key point to you as the worker does

the job again. c. Make sure the employee understands. d. Continue until YOU know the employee knows.

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4. Follow Up a. Put the employee on his/her own. b. Designate to whom the employee goes for help. c. Check frequently; encourage questions. d. Taper off extra coaching and close follow up.

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SAFETY TRAINING LOG I CERTIFY THAT THE EMPLOYEES LISTED BELOW RECEIVED SAFETY TRAINING IN THE SUBJECT(S) AS INDICATED. LOCATION DATE SUBJECT(S) TITLE(S) OF FILM(S), VIDEO(S) OR SLIDE PRESENTATION(S) SHOWN TO EMPLOYEES: ATTACHED IS AN OUTLINE OF THE SPECIFIC ITEMS DISCUSSED IN THIS TRAINING

PROGRAM, ALONG WITH HANDOUTS, IF ANY. INSTRUCTOR'S SIGNATURE DATE INSTRUCTOR'S NAME (PLEASE PRINT) INSTRUCTOR'S INITIAL EMPLOYEE NAME (PLEASE PRINT) EMPLOYEE SIGNATURE

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INITIAL TRAINING RECORD (INDIVIDUAL EMPLOYEE TRAINING DOCUMENTATION) NAME OF TRAINER TRAINING SUBJECT TRAINING MATERIAL USED NAME OF EMPLOYEE DATE OF HIRE/ASSIGNMENT I, HEREBY CERTIFY THAT I HAVE RECEIVED TRAINING AS DESCRIBED ABOVE IN THE FOLLOWING AREAS: THE POTENTIAL OCCUPATIONAL HAZARDS IN GENERAL IN THE WORK

AREA AND ASSOCIATED WITH MY JOB ASSIGNMENT. THE "CODES OF SAFE PRACTICES" WHICH INDICATE THE SAFE WORK

CONDITIONS, SAFE WORK PRACTICES, AND PERSONAL PROTECTIVE EQUIPMENT REQUIRED FOR MY JOB.

THE HAZARDS OF ANY CHEMICALS TO WHICH I MAY BE EXPOSED AND MY

RIGHT TO INFORMATION CONTAINED ON MATERIAL SAFETY DATA SHEETS FOR THOSE CHEMICALS, AND HOW TO UNDERSTAND THIS INFORMATION.

MY RIGHT TO ASK QUESTIONS, OR PROVIDE ANY INFORMATION TO THE

EMPLOYER ON SAFETY EITHER DIRECTLY OF ANONYMOUSLY WITHOUT ANY FEAR OF REPRISAL.

DISCIPLINARY PROCEDURES THE EMPLOYER WILL USE TO ENFORCE

COMPLIANCE WITH "CODES OF SAFE PRACTICES". I UNDERSTAND THIS TRAINING AND AGREE TO COMPLY WITH THE "CODE OF SAFE PRACTICES" FOR MY WORK AREA. EMPLOYEE SIGNATURE DATE COPIES TO: ORIGINAL (OFFICE), SAFETY COORDINATOR, EMPLOYEE

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EMPLOYEE SAFETY TRAINING RECORD EMPLOYEE NAME HOME PHONE DATE OF EMPLOYMENT EMERGENCY PHONE DRIVER LICENSE NO. CLASS EXPIRATION DATE ************** TRAINING RECEIVED INSTRUCTOR DATE NEW EMPLOYEE ORIENTATION HEARING CONSERVATION HAZARD COMMUNICATION FORKLIFT CERTIFICATION TOOLS SAFETY LIFTING SAFETY FIRE EXTINGUISHER USE FIRST AID - CPR LOCKOUT SAFETY RESPIRATOR (QUALITATIVE FIT) (POSITIVE FIT TEST) (NEGATIVE FIT TEST) OTHER SAFETY TRAINING: 1. 2. 3. 4. COPIES TO: OFFICE (ORIGINAL) SAFETY COORDINATOR SUPERVISOR

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D. JOB SAFETY ANALYSIS Job Safety Analysis is a simple review of major job tasks that are put through a step

by step analysis to identify the hazards that may be encountered, and then determining the best method to safely accomplish each step by either: implementing the proper procedures (steps) to either eliminate or control the hazard to workers; or by instituting the necessary safeguards to eliminate or control the hazards.

Below is a brief guideline for the foreman to follow as an outline when making any

safety analysis of a job or procedure. These procedures should be carefully followed:

1. The job is broken down into basic steps. These steps describe what is to be

done in sequence. You should omit details which have no bearing on the objective.

2. After the steps are listed, each step is analyzed for hazards that could cause

an accident. The purpose is to identify as many hazards as possible, whether produced by the environment or connected with the mechanics of the job procedure, so that each step of the entire job can be done safely and efficiently.

3. When the hazards and potential accidents associated with each step are

identified and their causes understood, ways of eliminating them shall be developed. There are four ways in which this can be handled:

a. Eliminate the process or operation or provide a substitute action

which can be done without the hazard, or; b. Isolate the process or operation so as to eliminate or minimize the

hazard, or; c. Provide guards or automatic devices to eliminate or minimize the

hazard, or; d. Provide personal protective equipment and enforce its use to

eliminate the possibility of injury. 4. Using the information gathered from the first three steps, work rules shall be

written and disseminated among all employees, and maintained on file for periodic review.

The written and complete Job Safety Analysis then becomes a document to

assist the foreman in the instruction of his employees in the safe method of performing their jobs. The process should also define what protective equipment will be required to do the job safely. It also provides each employee with a source of information he can use for occasional review.

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JOB SAFETY ANALYSIS Job Name Date Supervisor Location Job Steps Hazards Controls 1. 1. 1. 2. 2. 2. 3. 3. 3. 4. 4. 4. 5. 5. 5. 6. 6. 6. 7. 7. 7. COPIES TO: OFFICE (ORIGINAL) SAFETY COORDINATOR

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OSHA REPORTS Every employer must keep occupational injury and illness records for their employees. The recordkeeping forms are contained in a booklet entitled, "Record Keeping Requirements Under the Occupational Safety and Health Act", published by the State, Occupational & Health Administration. Superintendents should familiarize themselves with the record keeping requirement of OSHA in order to: ascertain that the records are properly kept and maintained; and, post the records as required. The State Occupational Safety and Health Act prescribes the following mandatory requirements: 1. Posting Requirement: The law requires that employees be informed of the job

safety and health protection provided under the Act. All employers must post and maintain in a conspicuous place of major travel (time clock, employee bulletin boards) copies at each establishment of the OSHA Notice, "Safety and Health Protection on the Job". This poster notice may be obtained from the State Occupational Safety and Health Administration Office.

The poster briefly states the intent and coverage of the Act and the responsibilities

of employers and employees to maintain safe and healthful working conditions. 2. Recording Requirement: Occupational injuries and illnesses must be recorded on

OSHA Form #200, Log of Occupational Injuries and Illnesses. A new Log must be kept for each calendar year for the period of January 1 to December 31. Each reportable injury and illness must be entered on the Log within six working days.

3. At the end of each calendar year, prepare a summary on OSHA Form #200,

Summary-Occupational Injuries and Illnesses, of those entries on the Log (OSHA Form #200) to cover the calendar year. The law requires that the Summary be posted in a conspicuous place accessible to the employees for thirty (30) consecutive days beginning February 1, annually, and a copy kept on file at the location.

4. Supplementary Records Of Each Occupational Injury or Illness (Form #101):

Retention of the Workers' Compensation First Report of Injury submitted to the insurance carrier is acceptable in lieu of OSHA Form #101, providing that the Form contains all items that are found on the OSHA No. 101 Form.

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5. Employers must report orally or in writing to the nearest Cal/OSHA office within 24

hours, any case involving serious injury or death from an accident or health hazard that results in one or more fatalities or hospitalization.

Serious injury is defined as "any injury or illness which requires inpatient

hospitalization for a period in excess of 24 hours for other than medical observation or in which an employee suffers loss of any member of the body or any serious degree of permanent disfigurement.

6. The records must be retained for a period of at least five (5) years (7 years-

Federal) following the end of the calendar year to which they relate, and be made available to OSHA Compliance Officers upon request.

Note: 1. For detailed instructions in preparing these forms, refer to

Record-Keeping Requirements pamphlet available from CAL/OSHA. Note: 2. Records maintained by an employer and reports submitted pursuant

to and in accordance with the requirements of an approved State Plan under Section 18 of the Act shall be regarded as compliance with this part of the Act.

Note: 3. There has been discussion by OSHA to change the current

recordkeeping requirements. The new procedure will be simplified, with the elimination of Form #102, "Summary of Accident/Illness." New instructions and forms will be available or provided by the U.S. Department of Occupational Safety and Health Administration, when the new procedure is implemented.

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POSTING REQUIREMENTS ¨ CAL/OSHA Poster "Safety and Health Protection on the Job" ¨ EMERGENCY PHONE NUMBERS (Ref. CAL/OSHA Sec. 1512 f.) ¨ NOTICE OF WORKER'S COMPENSATION COMPANY ¨ PAYDAY NOTICE (DLSE 8 - or equivalent) ¨ FEDERAL/STATE MINIMUM WAGE NOTICE "INDUSTRIAL WELFARE COMMISSION ORDERS (ORDER NO. MW-88)" ¨ UNEMPLOYMENT AND DISABILITY INSURANCE (EDD - #DE 1857A) ¨ DISCRIMINATION IN EMPLOYMENT (DFEH 162) ¨ NOTICE REGARDING EMPLOYEE RIGHTS (EEOC) ¨ NOTICE REGARDING EMPLOYEE POLYGRAPHS (WH Publication 1462) ¨ EQUAL EMPLOYMENT OPPORTUNITY NOTICE ¨ OSHA CITATIONS (Individual site location) ¨ CONFIDENTIALITY OF MEDICAL RECORDS (REF.SEC. 3204) ¨ TIME OFF FOR VOTING (ELECTION DAY NOTICE - Ref. CA Election Code) **************** OTHER SUGGESTED POSTINGS ¨ EXIT SIGNS ¨ ROOM CAPACITIES ¨ FLOOR LOADING ¨ MATERIAL SAFETY DATA SHEETS LOCATION ¨ EXPOSURE TO RADIATION OR SUBSTANCES ¨ SUGGESTION BOX LOCATION ¨ WARNING NOTICE AGAINST WORKER'S COMPENSATION FRAUD ¨ USE OF SAFETY EQUIPMENT ¨ SAFETY MEETING NOTICE ¨ LOCATION OF FIRST AID KIT/SUPPLIES

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SAFETY INFORMATION AND RESOURCES NATIONAL RESOURCE SAFETY CENTER The National Safety Resource Safety Center is a non-profit safety center which provides free safety videos, films, slides, and posters for the price of membership. Cost of membership was last quoted at less than $25.00 per month, and tax deductible. For further information and a free copy of their catalogue contact: NATIONAL RESOURCE SAFETY CENTER WESTMINSTER, CA (800) 468-4296 NATIONAL SAFETY COUNCIL The National Safety Council and its local chapters are excellent sources of safety information. The National Safety Council is a non-governmental, not-for-profit public service organization. The annual, tax-deductible membership fee is reasonable for the resources that are available. The following is list of locations covers all of California: WESTERN REGION, NATIONAL SAFETY COUNCIL (BAY AREA) 1111 TRITON DRIVE, SUITE 201 FOSTER CITY, CA 94404 (415) 341-5649 GREATER LOS ANGELES CHAPTER, NATIONAL SAFETY COUNCIL 3450 WILSHIRE BOULEVARD, SUITE 700 LOS ANGELES, CA 90010 (213) 385-6461 SACRAMENTO SAFETY COUNCIL, INC. 3909 BRADSHAW ROAD SACRAMENTO, CA 95827 (916) 366-7233 (800) 825-7262 FAX (916) 366-1762 SAN DIEGO COUNTY SAFETY COUNCIL 3320 KEMPER STREET SAN DIEGO, CA 92110 (619) 223-2657

SAN JOAQUIN SAFETY COUNCIL 1221 NORTH EL DORADO STREET STOCKTON, CA 95202-1332 (209) 464-4674

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HAZARD COMMUNICATION AND CONTROL PROGRAM TITLE AND PURPOSE This document is the COMMERCIAL SCAFFOLD, INC.'s program for HAZARD COMMUNICATION AND CONTROL. Its purpose is to set forth guidelines and procedures for the proper handling, storage, and disposal of hazardous substances in order to ensure a healthful and safe environment for all persons engaged in activities at any of the company's locations. Upon request, this document shall be made available to employees, their designated representative, and authorized , State, or Federal safety officials. LEGAL REFERENCES It is the intent of this document to reflect and incorporate the legal requirements of: CAL OSHA Section 5194, AB 2185, 2187, and 3377; Federal Hazard Communication Standard CFR1910.1200; and SARA title III, Emergency Planning and Community Right to Know Act of 1986, as they apply to Hazard Communication Standards. SITES AND SITE COORDINATORS Each company site, such as a customer facility, or other special facilities, and the company Offices, shall be considered a separate site. (See Appendix "A" for list of sites) Each site shall designate a site coordinator who will be responsible to coordinate and manage the company Hazard Communication Program for that site. In most cases this will be the function of the Project Manager. As appropriate, the Safety Coordinator may designate key personnel to assist the site coordinator with the Hazard Communication Program. The name of each site coordinator shall be posted and made known to employees at each site where hazardous substances are utilized or stored. The Site Coordinator's name is to be sent to the Safety Coordinator who will maintain a list of designated representatives.


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HAZARD COMMUNICATION AND CONTROL (Continued) It is the responsibility of each Site Coordinator to ensure that storage, handling, and disposal of hazardous substances takes place in accordance with the guidelines and procedures set forth in this document. The Safety Coordinator is designated as the company's coordinator to implement and coordinate the program. HAZARD DETERMINATION AND DISCLOSURE Hazardous substances are those chemicals that are designated as hazardous by one of the following: the manufacturer; by the Material Safety Data Sheet; or if they are listed on the "Directors List" of hazardous chemicals, or similar Government List. Manufacturers and suppliers are required to provide health and safety information to their customers on hazardous substances purchased. This is done through the use of Material Safety Data Sheets (MSDS), which must be provided to the purchaser prior to, or at the time of shipment. The company is mandated by law to maintain copies of the required MSDS for each hazardous substance in the work place and to ensure that these are readily accessible to employees when they are in their work area(s). At each site, an ongoing inventory shall be taken and a complete and current list, including quantity, of all hazardous substances shall be compiled for each site or area where such substances are stored, handled, or utilized. The inventory shall be reported to the Safety Coordinator's office monthly. (See Appendix "B" for Inventory Sheet) Material Safety Data Sheets (MSDS) shall be requested from manufacturers and suppliers, and all purchases of any item containing a "Hazardous Substance" must include the MSDS with the delivery. Any hazardous substance received without the Material Safety Data Sheet (MSDS) should not be utilized until a follow-up request has been sent and an MSDS received. If the vendor has not provided the MSDS within 25 working days of the request, the local office of CAL/OSHA shall be notified for assistance as specified in the Law. Only "designated" employees shall have the authority to make purchases which involve "hazardous materials". All "designated" company employees who purchase materials shall ensure that vendors and suppliers are notified of the MSDS requirement. Open purchase orders shall not include hazardous substances which by law must be accompanied by a MSDS.

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HAZARD COMMUNICATION AND CONTROL (continued) All purchases shall be made from the list of "Approved" vendors only (See Appendix "C"). Any exception from this practice must first be approved by the Safety Coordinator. It shall be the responsibility of each site coordinator where hazardous materials are stored or utilized to ensure that Material Safety Data Sheets and hazardous substance lists are developed, maintained in a current status, and posted or filed in the work place for employee use. The Safety Coordinator and site coordinators will rely on the manufacturer's determination of hazardous material as stated in the information provided on their published Material Safety Data Sheet (MSDS) and the designated government lists of hazardous substances. LABELS AND OTHER FORMS OF WARNING Each product which contains hazardous substances must be properly labeled, tagged, or clearly marked with: (1) the identity of hazardous substance(s) within; (2) appropriate hazard warnings; and (3) manufacturer's name. Existing labels on incoming containers shall not be removed or defaced unless the container is immediately marked with the information required above. If existing labels on containers received from suppliers already convey the required information, new labels do not need to be affixed. Hazardous chemicals that are transferred to containers which are intended only for "immediate use" need not be labeled providing that such containers, upon completion of the transfer and use, shall be emptied and devoid of any hazardous residue. Large containers or other stationary process containers may be labeled with signs, or other appropriate written information as long as the container to which the information applies is identified. Substances which do not have the proper label and/or cannot be identified shall not be used, handled, or stored. In such instances the site coordinator must be notified immediately. The substance must then be identified and properly labeled or removed from the site under the direction of the Safety Coordinator's office.

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HAZARD COMMUNICATION AND CONTROL (Continued) EMPLOYEE INFORMATION AND TRAINING At each site, department, or area where hazardous substances are utilized or stored, employees shall be provided with information and training on: a. How to handle hazardous materials safely and use personal protective equipment. b. Where to find and how to use Material Safety Data Sheets (MSDS) and the

hazardous substances labeling system. c. Potential physical and health hazards associated with the use of hazardous

substances or mixtures. d. Methods and observations used to detect the presence or release of hazardous

substances in the work place. e. First aid and emergency procedures to be utilized in the case of spills or accidental

overexposure. f. General safety precautions necessary to prevent or minimize exposure to

hazardous substances. g. Throughout each site, employees shall be informed whenever any temporary

activity involving the use of hazardous materials is to take place. In such cases, employees shall be informed of the nature of the activity and advised of any necessary precautions or potential hazards to be avoided.

h. Employees shall be advised of the location and availability of the company's written

Hazard Communication and Control program. i. Employees shall be advised: 1. Of the right of the employee and/or the employee's physician or bargaining

agent to receive information regarding hazardous substances to which the employee may be exposed.

2. That the employee is protected against any form of discrimination due to the

employee's exercise of the rights afforded to the provisions of the Hazardous Substances Information and Training Act.

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HAZARD COMMUNICATION AND CONTROL (Continued) OUTSIDE CONTRACTORS Whenever outside contractors, vendors, suppliers, or emergency responders enter or work at a site or department where hazardous substances are stored or utilized, the site coordinator, or supervisor shall inform them that their employees may encounter hazardous substances while performing their work, and provide the visitors with access to Material Safety Data Sheets (MSDS) and suggested appropriate protective measures. Further, a site map shall be prepared to identify the location of areas where hazardous materials are stored or in use. The site map shall be made available to emergency responders and shall be provided upon request, or at the site coordinator's discretion, to employees of outside contractors, vendors, or suppliers. Whenever it becomes necessary for an employee to perform an unfamiliar, non-routine task, which involves exposure to or utilization of a hazardous substance, the job supervisor shall ensure that the employee receives appropriate safety and hazard awareness training prior to the work. STORAGE OF HAZARDOUS SUBSTANCES To the maximum extent possible, all poisons, acids, and flammable chemicals shall be stored separately from all other substances, preferably in designated storage areas or cabinets that are approved for the type of exposure anticipated. The site coordinator shall schedule periodic inspections to ensure that all hazardous substances on the site are appropriately labeled and stored. Chemicals and substances utilized in maintenance, and which are particularly vulnerable to incompatibility and possible adverse reaction or accident due to improper storage, should be minimized. To the maximum extent possible, for storage purposes, chemicals and substances should be separated into organic and inorganic groupings and further sorted into compatible families within the two major groupings.

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HAZARD COMMUNICATION AND CONTROL (Continued) HAZARDOUS WASTES DISPOSAL PROCEDURES AND REGULATIONS Federal, state, and local environmental regulations require strict control of the handling, storage, and disposal of all materials identified as being hazardous or toxic to human health or the environment. Once such materials have been used within the operations, specific restrictions and procedures apply as to their disposal. The Safety Coordinator's office will maintain a monthly inventory based on information supplied by the site coordinator accordingly, the following procedures shall be carried out at all sites which generate hazardous waste: 1. No hazardous waste may be dumped in drains, sewers, dumpsters, or onto the

ground. The only exception is small quantities of some chemicals may be disposed of by drain or dumpster, in accordance with local Sanitation District rules or OSHA guidelines or the Material Safety Data Sheet (MSDS).

2. The Safety Coordinator's office shall be the contact point for all information

regarding storage and disposal of hazardous materials. It will arrange for periodic removal (a minimum of quarterly, or as required by law) of hazardous waste by a licensed hazardous waste hauler as needed.

3. Department of Transportation (DOT) storage drums are required for storage of

waste oils, sludges, and solvents. Prior to removal, waste oils, sludges, and solvents shall be stored in Department of Transportation (DOT) approved and labeled storage drums with lids. Labels shall clearly identify the material being stored for removal and the date it was placed in the drum. The average monthly quantity of each category and waste name shall be maintained and reported to the Safety Coordinator.

4. Hazardous wastes designated for disposal or treatment must be removed from the

site by a licensed hazardous waste hauler. Arrangements for any hazardous materials disposal MUST be made through the Safety Coordinator's office. For removal, send an inventory sheet to the Safety Coordinator's office with name, quantity, and location of hazardous materials. Before choosing the hauler, his identification and record will be checked.

5. When hazardous waste is disposed of from a given site, a manifest list must be

prepared by the hauler. Each list must identify the name and amount of each material for disposal.

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HAZARD COMMUNICATION AND CONTROL (Continued) A copy of the Environmental Protection Agency (EPA) manifest list and any related

documents MUST be forwarded to the Safety Coordinator's office as soon as they are completed. The ORIGINAL shall be kept on file at the site.

After the waste has been deposited at an approved dump site, another copy of the

manifest will be returned to the Safety Coordinator's office to document proper disposal and site location.

6. Each site coordinator shall be responsible for keeping an on-going Hazardous

Waste Disposal Manifest File, with copies of all information sent to the Safety Coordinator's office for the master file. As provided by law, the site Disposal Manifest File is subject to regular inspection by the local HEALTH DEPARTMENT. Appropriate fines may be levied for noncompliance.

DISCLOSURE PROCEDURE FOR EMERGENCY RESPONDERS AND EMERGENCY RESPONSE PLAN FOR HAZARDOUS SPILLS 1. Compulsory Federal Law (SARA Title III) provides that counties adopt ordinances

mandating that businesses or persons using, handling, or storing hazardous materials provide information regarding the location, type and health risks of such materials to emergency responders such as fire department and paramedics.

2. To comply with SARA Title III, the company will provide the designated area

agencies the Hazardous Chemical Inventories and Emergency Response Plans. Currently the law applies only to businesses or persons using, storing or handling hazardous materials where:

THERE IS AN ESTIMATED TOTAL YEARLY USE IN EXCESS OF 55 GALLONS

OF LIQUIDS, 500 POUNDS OF SOLIDS, OR 200 CUBIC FEET OF GASEOUS SUBSTANCES.

ONCE THE COMPANY HANDLES THIS AMOUNT OF PRODUCT, IT IS

NECESSARY TO DETERMINE HOW MUCH WASTE IS THEN BEING GENER-ATED. IF IT IS NECESSARY TO RECYCLE OR DISPOSE OF WASTE THROUGH A LICENSED WASTE HAULER, RECYCLER, ETC., THEN THE COMPANY MUST BECOME LICENSED AS A GENERATOR OF HAZARDOUS WASTES.

Each site coordinator shall maintain an inventory of all hazardous chemicals, the

quantities, and the Material Safety Data Sheets. The updated inventories shall be sent to the Safety Coordinator's office on a monthly basis. The Safety Coordinator's office shall assist in coordinating the program.

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APPENDIX "A" COMPANY SITES & DESIGNATED SITE COORDINATORS ----------------------------------------------------------------------------------------------------------------------- LOCATION SITE COORDINATOR -----------------------------------------------------------------------------------------------------------------------

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APPENDIX "B" HAZARDOUS CHEMICAL (PRODUCT) INVENTORY ----------------------------------------------------------------------------------------------------------------------- SITE LOCATION________________ SITE COORDINATOR_______________ INVENTORY DATE ----------------------------------------------------------------------------------------------------------------------- PRODUCT NAME QUANTITY ON SITE PROPANE ACETYLENE

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APPENDIX "C" LIST OF APPROVED VENDORS ----------------------------------------------------------------------------------------------------------------------- VENDOR

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MSDS SAMPLE LETTERS (Instructions for obtaining Material Safety Data Sheets) MATERIAL SAFETY DATA SHEET (MSDS) Copies of Material Safety Data Sheets (MSDS) for all hazardous substances to which employees may be exposed are kept in the Office. As outlined in the company's Hazard Communication Program, the Safety Coordinator will be responsible for obtaining and maintaining the data sheet (MSDS) system for the company. The Safety Coordinator will review incoming data sheets for new and significant health and safety information. The Safety Coordinator will see that any new information is provided to employees as necessary. The new MSDS's will be reviewed for completeness by the Safety Coordinator. If a MSDS is missing or incomplete, a new MSDS will be requested from the manufacturer or distributor, as applicable. If the Company does not receive the required MSDS within the 25 day period mandated under law, the Safety Coordinator will write to CAL/OSHA as stipulated in the regulations to notify them that the company has met the legal requirements outlined. MSDS's are available to all employees upon request for review during each work shift. If an MSDS is not available, or new hazardous substance(s) in use do not have an MSDS, please contact the Safety Coordinator immediately. OBTAINING MSDS FORMS REQUIRES THE FOLLOWING STEPS: 1. MSDS Request Letter 2. Follow-up Letter if MSDS is not received 3. Follow-up Letter if MSDS is incomplete 4. Letter to CAL/OSHA Reporting Non-Compliance

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SAMPLE LETTER #1 MSDS REQUEST LETTER Date: (Chemical Company or Distributor name and address) RE: MSDS for (products) Dear Sirs: Please send a copy of your Material Safety Data Sheet (MSDS) for the product listed above. The MSDS is needed for compliance with the State of California "Hazard Communication" regulation under Section 5194 of Title 8, California Code of Regulations (T8CCR). Please send the MSDS to our Safety Coordinator at the following address: If this product does not require an MSDS, please notify us in writing that it meets the exemption, or that it contains no hazardous material as defined in the CAL/OSHA regulations. If this/these product(s) have any special container labels, we would appreciate receiving a sample label(s), If you have any questions regarding our request, please contact our Safety Coordinator immediately. Sincerely, Purchasing Department

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SAMPLE LETTER #2 (MSDS NOT COMPLETE) FOLLOW-UP LETTER Date: (Chemical Company or Distributor name and address) RE: MSDS for (products) Dear Sirs: Thank you for responding to our request of (date) . We have received the MSDS requested. However, it did not contain the information required by GISO Title 8, Section 5194. We are returning the MSDS sent to us by your firm. We have highlighted those areas in question for your review. Should you have any questions, please contact us immediately. Sincerely, Purchasing Department

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SAMPLE LETTER #3 REPORTING NON-COMPLIANCE SAMPLE LETTER TO CAL/OSHA Date: Dr. John Howard, Chief CAL/OSHA 455 Golden Gate Ave., Room 5246 San Francisco, CA 94102 Re: MSDS Request Dear Sir: In order to comply with the requirement to have Material Safety Data Sheets (MSDS) in our company, we requested the MSDS for the following product(s) as stipulated in GISO Title 8, Section 5194: As indicated in the enclosed correspondence, non-compliance still exists for the following reason: (circle the one applicable) A. Did not furnish the MSDS B. MSDS sent without the required information. C. Other Sincerely, Safety Coordinator Enclosures:

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IMPORTANT REFERENCE INFORMATION MATERIAL SAFETY DATA SHEETS Valuable information for the safe use, handling and disposal of chemical materials on the job site may be obtained from the manufacturer or supplier in the form of a Material Safety Data Sheet (MSDS). Each MSDS describes the physical and chemical properties of one chemical material or substance. It also provides information for first aid treatment and special personal protection, procedures for cleanups, and precautions for storing and handling that are appropriate to the material. The Material Safety Data Sheet is designed to inform the user of the properties of the material and to suggest proper controls for protecting employees, property and the environment against injury or damage. The data sheet also helps the user set up and maintain appropriate controls so that he can avoid preventable accidents. Below is an outline of the contents of a Material Safety Data Sheet. SECTION I - MANUFACTURING IDENTIFICATION Name, address and phone number of the manufacturer. Material and trade names, chemical family and other designations. Pay particular attention to the EMERGENCY TELEPHONE NUMBER. Should an emergency occur, this information should be readily available. The date the MSDS was prepared is important because you should always refer to the most recent MSDS for accurate information. Not only does new information on chemicals become available with time, but product formulas change. SECTION II - HAZARDOUS INGREDIENTS Hazardous ingredients and their percent (%) concentrations in the material, as well as their toxicity; also hazardous mixtures of other substances. SECTION III - PHYSICAL DATA Properties such as boiling point, vapor pressure and density, solubility in water, evaporation rate, percent volatiles, and characteristic appearance and odor. SECTION IV - FIRE AND EXPLOSION HAZARD INFORMATION Properties such as flash point (method of ignition), autoignition temperature, and lower and upper limits in the air. This information is very important for materials used near sources of ignition or within poorly ventilated spaces. Also, means of extinguishment and special procedures for fire fighting. SECTION V - HEALTH HAZARD DATA Threshold limit value (TLV), effects of overexposure, and first aid treatment for eye or skin contact and inhalation. This information offers a guideline for monitoring exposure during use or handling.

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SECTION VI - REACTIVITY DATA Stability of the material and related conditions to avoid. Other materials that are incompatible. Hazardous decomposition products and hazardous polymerization with related conditions to avoid. This information outlines conditions of use and storage under which the material will remain stable, as well as likely conditions that could cause a dangerous chemical reaction. SECTION VII - SPILL OR LEAK PROCEDURES Recommended action for safe clean-ups and for final disposition without posing a hazard to people, property, or the environment. SECTION VIII - SPECIAL PROTECTION INFORMATION Suggestions covering the need for ventilation, respiratory protection, eye protection, gloves, and other protective equipment during exposure to the material. SECTION IX - SPECIAL PRECAUTIONS Information on safe storage and handling to avoid hazardous reactions, and Department of Transportation classification.

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GLOSSARY OF MATERIAL SAFETY DATA SHEET TERMS Information sheets, such as Material Safety Data Sheets for hazardous or toxic substances contain words that may be unfamiliar. The following explanation of terms will help you to understand the MSDS. ACGIH: Abbreviation for the American Conference of Governmental Industrial Hygienists, a private organization of occupational safety and health professionals. ACGIH recommends occupational exposure limits for numerous toxic substances and it updates and revises its recommendation as more information becomes available. CARCINOGENIC: Capable of causing cancer. CEILING LIMIT: The maximum amount of toxic substance allowed to be in workroom air at any time during the day. COMBUSTIBLE: Able to catch fire and burn. CONCENTRATION: The amount of one substance in another substance. DECOMPOSITION: Breakdown of a chemical. DENSITY: How much space a given weight of substance takes up. Gold is a very dense substance because a small piece of it weighs a lot. Styrofoam is not very dense because it weighs very little but takes up a lot of space. The density of a substance is usually compared to water, which has been given a density value of 1. Substances more dense than water (which sink in water) have a density greater than 1; substances that float on water have a density of less than 1. DERMAL: By or through the skin.

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EXPLOSIVE LIMITS: The amounts of vapor in air sufficient to form explosive mixtures. Explosive limits are expressed as LOWER EXPLOSIVE LIMITS and UPPER EXPLOSIVE LIMITS; these give the range of vapor concentrations in air that will explode if heated. Explosive limits are expressed as a percentage of vapor in the air. FLAMMABLE: Catches on fire easily and burns rapidly. FLAMMABLE LIMITS: See EXPLOSIVE LIMITS FLASH POINT: The lowest temperature at which the vapor of a substance will catch on fire, and then go out, if heat is applied. Provides an indication of how flammable a substance is. Not to be confused with IGNITION TEMPERATURE. HEALTH HAZARD: Anything that can have a harmful effect on health under the conditions in which it is used or produced. There can be both ACUTE and CHRONIC health hazards. IGNITION TEMPERATURE: The lowest temperature at which a substance will catch on fire and continue to burn. The lower the ignition temperature, the more likely the substance is going to be a fire hazard. INFLAMMABLE: Same as FLAMMABLE. INGESTION: Swallowing. LC50: The concentration of a substance in air that causes death in 50% of the animals exposed by inhalation. A measure of acute toxicity.

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LD50. The dose that causes death in 50% of the animals exposed by swallowing a substance. A measure of acute toxicity. mg/kg A way of expressing dose: milligrams (mg) of a substance per kilogram (kg) of body weight. Example: a 100 kg (220 pound) person given 10,000 mg (about 0.02 pounds) of a substance would be getting a dose of 100 mg/kg (10,000 mg/100 kg). mg/m A way of expressing the concentration of a substance in air: milligrams (mg) of substance per cubic meter (m ) of air. MILLIGRAM: One-thousandth of a gram. MUTAGENIC: Capable of changing cells in such a way that future cell generations are effected. Mutagenic substances are usually considered suspect carcinogens. NIOSH: Abbreviation for the National Institute for Occupational Safety and Health, U.S. Department of Health and Human Services. NIOSH does research on occupational safety and health questions and makes recommendations to OSHA. ODOR THRESHOLD: The lowest concentration of a substance's vapor, in the air, that can be smelled. Odor thresholds are highly variable depending on the individual who breathes the substance and the nature of the substance. OXIDIZER: Any substance that reacts violently with oxygen or that gives off large amounts of energy in a chemical reaction.

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PEL: Permissible Exposure Limit: means the same as TLV. PEL is often used in OSHA Standards instead of TLV. PH: A measure of how acidic or caustic (basic) a substance is on a scale of 1-14. Ph 1 indicated that a substance is very acidic; Ph 7 indicates that a substance is neutral; and Ph 14 indicates that a substance is very caustic (basic). PPM: Parts per million: Generally used to express small concentrations of one substance in a mixture. REACTIVITY: The ability of a substance to undergo change, usually be combining with another substance or by breaking down. Certain conditions, such as heat and light, may cause a substance to become more reactive. Highly reactive substances may explode. SOLUBILITY: The amount of a substance that can be dissolved in solution, usually water. SUSPECT CARCINOGEN: A substance that might cause cancer in humans or animals, but has not been proven to do so. TERATOGENIC: Capable of causing birth defects. TLV: Abbreviation for Threshold Limit Value (TLV). The average 8-hour occupational exposure limit. This means that the actual exposure level may sometimes be higher, sometimes lower, but the average must not exceed the TLV. TLV's are calculated to protect most workers for a working lifetime.

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TOXIC SUBSTANCE: Any substance that can cause acute or chronic injury to the human body, or that is suspected of being able to cause disease or injury under some conditions. Many toxic substances are chemicals or chemical mixtures, but there are other kinds of toxic substances as well (bacteria and viruses, for example). VAPOR: The gas given off by a solid or liquid substance at ordinary temperatures. VAPOR DENSITY: The density of the gas given off by a substance. It is usually compared with air, which has a vapor density set at 1. If the vapor is more dense than air (greater than 1) it will sink to the ground; if it is less dense than air (less than 1), it will rise. VOLATILITY: A measure of how quickly a substance forms vapors at ordinary temperatures. Vapor pressure is a measure of volatility. The lower the vapor pressure the lower the volatility.

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PROPOSITION 65 NOTIFICATION SCOPE AND HISTORY Originally, California's Proposition 65 was enacted by the voters in 1986. The same emphasis has been placed on its provisions within the CAL/OSHA as before. However, it is now more directly applied to the work environment, whereas previously there had been some question to its application therein. In California Labor Federation v. California Occupational Safety and Health Standards Board, 221 Cal. App. 3d 1547 (1990) the court of appeal determined that the State Plan did not provide clear and reasonable warning protection as required by the Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65). Accordingly, regulatory amendments have been adopted to incorporate the clear and reasonable Warning protection of Proposition 65 into the Industrial Safety Order Regulations, and thereby into the State Plan. Employers who come within the scope of Proposition 65 are now prohibited from knowingly and intentionally exposing their employees to a chemical known to the state to cause cancer or reproductive toxicity unless they provide a clear and reasonable warning through specified methods, before the exposure. The enforcement provisions of Propo-sition 65 have also been incorporated into the Industrial Safety Orders regulations. This is a very simple law with two primary requirements: 1. The Company must notify anyone that it exposes to a carcinogen or reproductive

toxicant. 2. The Company cannot cause a significant amount of a carcinogen or reproductive

toxicant to enter a source of drinking water or the workplace, whether it may be in the form of water, in the air, or absorbed through the skin, without proper control or elimination of employee work exposure.

EXEMPTIONS Any business with less than ten employees is exempt from Proposition 65. ENFORCEMENT Effective May 31, 1991, CAL/OSHA became the STATE'S enforcement agency for Proposition 65. This change affects Section 5194 of the GENERAL INDUSTRY SAFETY ORDERS of Title 8, California Code of Regulations. In part these regulations require all employers to provide information to their employees about hazardous substances to which the employees may be exposed by means of a hazard communication program, labels and other forms of warning, material safety data sheets, and information and training.

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WHAT IS A CARCINOGEN OR A REPRODUCTIVE TOXICANT? Proposition 65 requires the Governor to develop a list of chemicals known to the state that cause cancer or reproductive harm. This list is produced by the Scientific Advisory Board and distributed by the Health and Welfare Agency. There are around 480 chemicals on the Proposition 65 list. EXPOSURE WARNINGS The manufacturers of products that present the risk of exposure to Proposition 65 listed chemicals are required to provide the Company with an EXPOSURE WARNING either on the package, in the form of a letter or on the "material safety data sheet" (MSDS). This exposure warning is to be passed on to our employees and customers, if they are exposed to the product. DISCHARGE PROHIBITIONS Proposition 65 broadly defines "drinking water" to include effluent from waste water treatment systems. Because of this, the Company must take care in what chemicals are allowed to go down the drain and into the sewer system. When there may be any doubt, the Safety Coordinator is to consult with the product supplier on the best way to handle the chemical... and get their answer in writing! EMPLOYEE NOTIFICATION Using our Hazardous Chemical Inventory Sheet, the Safety Coordinator will identify those chemicals which are affected by Proposition 65. The supervisor is to inform their employees of any of the Proposition 65 listed chemicals they come into contact with on the job. For commonly used products, the Safety Coordinator is to discuss ways that the employees can minimize exposure to listed chemicals. Employees training should include a reminder that additional information on Proposition 65 listed substances is available in the MSDS. All employee training is to be documented on Proposition 65 in the Employee Training Record. A copy of the Proposition 65 Exposure Warning Statement on the following page is to be attached to the Material Safety Data Sheet (MSDS) for those products that contain Proposition 65 listed chemicals. The Proposition 65 Notification Policy is to be posted where it can be seen by all employees.

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CONTRACTORS AND VISITORS Employees are to be informed that they are responsible to provide prior notification to contractors and visitors that may be exposed to a Proposition 65 listed chemical that they are handling or applying. The best way to provide that notification is to give the individual a copy of the MSDS.

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PROPOSITION 65 EXPOSURE WARNING CHEMICALS FOUND IN THIS PRODUCT ARE KNOWN TO THE STATE OF CALIFORNIA TO CAUSE CANCER OR BIRTH DEFECTS. FOR INFORMATION ON THE SAFE USE OF THIS PRODUCT, PLEASE CONTACT: NAME DATE

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PROPOSITION 65 NOTIFICATION POLICY THIS ORGANIZATION HAS A POLICY TO PROVIDE CLEAR AND ADEQUATE WARNING TO ANY EMPLOYEE, CUSTOMER, OR OTHER INDIVIDUAL WHO IS EXPOSED TO A PROPOSITION 65 LISTED CHEMICAL AS A RESULT OF OUR WORK. THE FOLLOWING STEPS ARE TO BE TAKEN BY ALL EMPLOYEES TO "ENSURE THAT PEOPLE ARE WARNED PRIOR TO POSSIBLE EXPOSURE: 1. A Material Safety Data Sheet (MSDS) with an attached warning statement will be

kept on all products that contain Proposition 65 listed chemicals. These Material Safety Data Sheets (MSDS) are available to all employees.

2. Employees will be informed during regularly scheduled training programs of

products containing Proposition 65 listed chemicals used by this company. Specific information about the hazards and precautions for these products is available in the MSDS binder.

3. When using products that contain Proposition 65 chemicals, a copy of the MSDS

with the attached Proposition 65 warning will be provided to any person who may come in contact with the product.

4. When appropriate, Proposition 65 warning signs will be posted in the work area. Signed: Date: SAFETY COORDINATOR

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PHYSICAL EXAMS - EMPLOYEE HEALTH Physical fitness of employees is a prime requisite in preventing a significantly large number of personal injuries. An employee's health will be evaluated to insure that their true physical capability and job assignment is compatible. A. SPECIAL PHYSICAL EVALUATIONS 1. Any employee whose physical condition or capabilities, as outlined in the job

requirements, constitutes a safety hazard to himself or other employees will be required at the company's expense to undergo a physical evaluation at a company approved facility for the following:

a. An inability to do a satisfactory job because of a physical or mental

problem. b. *Return from an extended absence because of a serious illness or an

off-the-job injury when time lost has exceed 30 calendar days, and the individual is not in a sedentary type position.

c. *Return from an extended recovery after a serious industrial injury

when absence has exceeded 30 calendar days and the individual is not in a sedentary position.

*In these two cases, the employee is required to furnish the

company's approved medical facility with a copy of his/her personal physician's RELEASE TO WORK plus a brief report of DIAGNOSIS, TREATMENT and PROGNOSIS. These must be provided at the time of the evaluation.

d. Return from resignation or leave-without-pay status of more than six months

duration for those job classifications which require pre-placement physicals. e. Return from resignation or leave-without-pay status for any duration

when the health status of the employee is questionable. f. Employees transferring to a job that requires greater physical

capability and a pre-placement physical exam is required. g. An employee who appears to be working while groggy or incoherent.

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B. ALL OFFICE EMPLOYEES INCLUDING TEMPORARY, PART-TIME, INTERMIT-

TENT, SUMMER YOUTH EMPLOYEES All office employees shall be required to complete a Medical Questionnaire in which

they certify what their physical condition is to the best of their knowledge. C. ALCOHOLISM Confirmed alcoholism is acknowledged as a disease and therefore may be treated

as any other illness. An alcoholic employee is potentially hazardous to himself and to others, and ignoring his/her problem at the work site is a mistake management and employees must avoid. When the need for diagnosis of alcoholism or drug abuse is indicated, the case should be reviewed with the Safety Coordinator. SUPERVISORS SHOULD NOT ATTEMPT TO DIAGNOSE ALCOHOL OR DRUG ABUSE -- CONTACT PERSONNEL.

D. CONFIDENTIALITY OF PHYSICAL EXAMINATION REPORTS The results and findings of a physical examination performed at a company

approved medical facility, either for pre-placement, annual or an evaluation, shall be treated as CONFIDENTIAL. Information must not be provided anyone outside the normal processing agencies involved in hiring, evaluating or extending leaves on an individual without the individual's expressed consent in writing.

E. EMPLOYMENT DURING ABSENCE FROM COMPANY DUTIES An employee who is absent from his/her company duties because of illness or

injury must not work outside his/her company employment. Normally, if an employee is cleared to work off duty by his/her physician, it is

possible that he/she could be placed in some company job within the limitations set by the physician. Supervision should make every effort to do this when possible.

F. DRUG ABUSE POLICY

CSI has a zero tolerance policy for drugs and alcohol (or beer) use during hours of work. It is never allowed to drink or take drugs at work. It is never allowed to have drugs or alcohol (or beer) at work, or in the CSI yard, or at the job site, or in any CSI vehicle. Anyone in possession of drugs or alcohol (or beer) at work, or in the CSI yard, or at the job site, or in any CSI vehicle may be terminated immediately. Drugs include but not limited to Marijuana, PCP, Cocaine, Heroin, LSD, methamphetamines, opiates, and/ or abuse of prescription medications.

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AUTHORIZATION FOR MEDICAL TREATMENT DATE: EMPLOYEE'S NAME: PLACE OF EMPLOYMENT: ADDRESS: CITY, STATE: This form authorizes the above employee to receive medical attention as provided under the Workers' Compensation Benefits Coverage by our insurance carrier. AUTHORIZED BY:

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PERSONAL PROTECTIVE EQUIPMENT The use of personal protective equipment for any job which has an inherent injury potential is the responsibility of the job foreman. The foreman should plan ahead prior to beginning the job by analyzing what special personal protective equipment would be necessary to complete the work prior to getting started, then ordering it out at the last minute. Since some jobs require the use of respiratory protection, it is important to see prior to starting the actual phases of the job requiring the respirators that they are: 1. On the job and ready for use, in a clean and sanitary condition. 2. That personnel who are assigned to the job have had a physical examination and

cleared by the doctor to wear the respirators. 3. That the personnel have been trained in the proper use of the equipment. All of these factors are best accomplished at least a day ahead of the planned workday. Thus the equipment is on the job, and those personnel assigned to do it, and ready to begin work. Detailed specifications for the design, purchase, and use of all personal protective equipment shall be coordinated among the Purchasing Department, the Safety Coordinator, and the foreman of the workers. Any specialized safety equipment specified as mandatory on hazardous jobs will be provided by the company. Employees will be fully accountable for its use and condition. Ordinary safety hard hats and safety glasses will be provided by the company when required. MANDATORY PROTECTIVE EQUIPMENT When the use of personal protective equipment has been specified for hazardous work, its use will be mandatory as a condition of employment. Supervision, foreman and superintendents, will be held accountable for employees allowed to work without compliance. Enforcement can be made easier by educating employees on the reasons for using or wearing the articles and the possible injuries that can result when the need is ignored. The monthly review of injuries by the Safety Coordinator shall place emphasis on those that resulted from failure to use protective equipment.

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BASIC PERSONAL PROTECTIVE EQUIPMENT 1. We must ensure that the following personal protective equipment is available prior

to the start of construction activities. a. Supply of hard hats (meeting ANSI Z.89.1 standards). b. Supply of safety glasses (meeting ANSI Z.87.1 standards). c. Safety belts when elevated work is part of the contract. d. Lanyards and rope grabs. e. Respiratory protective equipment as dictated by hazard; to include, but not

limited to, respirators, hoods, masks, etc. f. Goggles. g. Hearing protectors. h. Foot guards when contract calls for compacting, jack-hammering, etc. i. Cutting goggles if welding and burning operations are anticipated. j. Welding hoods and lens. k. Welding gloves. l. Welding jackets and sleeves. m. Full face shields (for operations producing flying chips, particles or sparks). n. Rubber boots, gloves, etc. (for concrete placing operations). 2. The project superintendent will ensure that an adequate stock of this equipment is

maintained. SELECTING PERSONAL PROTECTIVE EQUIPMENT 1. Personal Protective Equipment must meet the following requirements: a. Provide desired protection against the hazard to which the worker will be

exposed.

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b. Maximum comfort coupled with minimum weight. c. Minimum restrictions of essential body movement, vision, etc. d. Durability and, when possible, ability to be maintained on the project. e. Manufactured in accordance with accepted standards for performance and

materials, i.e., American National Standards Institute (ANSI), and National Institute for Occupational Safety and Health (NIOSH).

f. When the use of personal protective equipment is necessary, the use of

such protection will be mandatory. Failure to use protective equipment when necessary will result in disciplinary action.

The equipment listed below shall be worn when hazards as described exist: 1. Hard hats to protect the head against falling objects, head bumping situations or

electrical conductors. 2. Goggles, face shield, or safety glasses to guard against airborne debris, dust, flying

particles, chips, chemicals, heat, or injurious rays. 3. Ear plugs or ear muffs to guard against prolonged exposure to noise exceeding

sound tolerance levels defined by law. 4. Respirators, gas masks, airline respirators, and self-contained breathing apparatus

to protect employees against toxic or abnormal atmospheric conditions. 5. Safety footwear on some jobs to protect feet against possible mashing such as

when using a jackhammer. Steel toed shoes are not required to be worn as a condition of employment, but all employees are encouraged to wear them as an extra measure of protection.

6. Reflective vests to increase employee's visibility while working in or around traffic

lanes on jobs in the public streets is mandatory. 7. Protective clothing such as gloves, sleeves, aprons, leggings, and full suits to

protect against things such as contaminated soils will be required. 8. Seat belts to prevent injury when in a company vehicle. 9. SAFETY BELTS/HARNESS: Safety belts must be used when erecting

scaffolds or any time working above 6' when not on an approved scaffold, platform, or runway that meets the OSHA requirements for a standard railing.

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PROPER DRESS FOR WORK 1. GENERAL Each employee must wear clothing suitable to the job they are performing at all

times. Suitable clothing means clothing that will minimize danger from moving machinery, hot or injurious substances such as when welding, and even sunburn during jobs on hot summer days, etc. Individuals with long hair shall wear a cap or net while working around machines.

2. FACIAL HAIR POLICY Individuals required to wear breathing devices (respirators) in toxic atmospheres

shall be clean-shaven where the mask contacts the face. FOOT PROTECTION 1. Employees are required to wear sturdy work boots which will provide adequate

protection against injury to the feet. 2. When work boots will not provide sufficient protection, the employee will be

required to wear approved foot guards. 3. Employees are be encouraged to purchase and wear boots with steel toes, sole

penetrating protection, and ankle protection. 4. When construction projects require the wearing of steel toe safety boots, this is to

be enforced. 5. Tennis shoes, running shoes, light canvas shoes, sandals, etc., are not authorized

for wear on construction areas of Projects. SAFETY BELTS/HARNESSES, LANYARDS AND LIFE LINES 1. Fall protection, as required by OSHA/MSHA and/or the Safety Manual, will be

provided for employees. 2. Any employee whose work places them outside any secured area otherwise

protected by guardrails or where their work is to be performed on suspended scaffolds or any other working surface where they may be subject to a fall greater than 6' will wear and use safety harnesses (belts only where permitted), lanyards and lifelines if needed.

HEARING PROTECTION 1. Employees exposed to noise in excess of the Occupational Exposure Limits will

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2. There are two types of recognized hearing protectors available for use in reducing noise exposure:

a. Ear Plugs. b. Ear Muffs. 3. In most instances ear plugs are acceptable hearing protectors. 4. When using ear muffs for hearing protection, they must be disinfected before being

issued to another employee. 5. Employees are to be informed of the hazards associated with the exposure to noise

and the purpose and limitations of protective hearing devices. The wearing of this equipment will be mandatory in high noise areas.

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RESPIRATORY PROTECTION 1. GENERAL a. Employees who are or may be exposed to hazardous concentration of

gases, vapors, smoke, fumes, mists or dusts will be provided, and required to wear, respiratory protective equipment designed to protect the worker from such concentrations.

b. Employees will use the provided respiratory protection in accordance with

the instructions and training received. On projects where the use of such protection is required, initial training in this equipment will be incorporated in the "new hire" safety orientation.

c. When respiratory protective equipment is required to be worn in areas which

are contaminated with hazardous substances, excess head or facial hair which prevents effective sealing of the skin will be removed.

d. The wearing of contact lenses during the use of respiratory protection in

contaminated atmospheres will be prohibited. e. Where practicable, the respirators will be assigned to individual workers for

their exclusive use. f. Respirators used routinely will be inspected during cleaning. Worn or

deteriorated parts will be replaced. Respirators for emergency use such as self-contained devices will be inspected once a week and after each use.

g. Surveillance of work area conditions and degree of employee exposure or

stress will be maintained by the supervisor. There will be regular inspection and evaluation to determine the continued effectiveness of the program.

h. Employees will not be assigned to tasks requiring use of respirators unless it

has been determined that they are physically able to perform the work and use the equipment.

CLEANING OF RESPIRATORS Respirators will be regularly collected, cleaned and disinfected. Those that are issued for the exclusive use of one worker will be cleaned after each day's use if necessary. Those respirators used by more than one individual will be cleaned and disinfected after each use. INSPECTION OF RESPIRATORS All respirators will be inspected before and after each use. A respirator that is not routinely used but is kept ready for emergency use will be inspected after each use and weekly to assure that it is in satisfactory working condition.

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EYE WARE PROTECTION POLICY The company recognizes the need to provide eye protection for employees whose job exposes their eyes to possible injury. The company will designate areas where industrial grade safety glasses will be worn. In those locations specified as eye hazard areas, all individuals who work there or enter the site must wear appropriate eye protection. There will be no exceptions. Since everyone does not wear prescription glasses, plano glasses or goggles are available for issue at the job site. Those who wear standard street sunglasses, must wear industrial grade glasses or goggles when entering predesignated areas. The company may have available dark glasses which meet this standard. Individual supervisors are responsible to insure their employees are adequately protected. The American National Safety Institute (ANSI) (Z87.1-1979) Standard is what has been adopted by the company. In brief, all industrial grade glasses (prescription or non prescription) must meet or surpass the following specifications: FRAMES Frames must be capable of disinfection. Frames must support the lens around the entire periphery of the lens. Frames must be constructed so that the lens can be inserted from the front only to

minimize the possibility of backward lens projection upon impact. Frames must withstand the weight of a 16 oz. weight with no permanent deformity. Frames (metal only) when bent in half must not break nor must the solder break. Frames must be marked with Z87 logo on the front and temple. Frames must have manufacturer's name or trademark. Size must be stamped on the frame. LENS Lenses must be impact and penetration resistant. Lenses must be 3.0 mm thick. Lenses must be marked with fabricators logo. Lenses must have "V" on photo-chromatic glasses.

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STEREOPHONIC HEADPHONES Listening to music through music headphones adjusted to the correct volume can be a very relaxing and entertaining pastime in the proper environment. Their use while on the job, however, can create a health hazard and creates an unsafe condition for employees as well as others with whom they come in daily contact. Rather than jeopardize employees and public safety and health, it is the company's policy that music headphones are prohibited and must not be worn by employees while on the job. According to medical professionals and hearing conservationists, music headphones are rapidly becoming a leading cause of noise induced hearing loss. Most attribute the hearing losses to improper volumes used by the wearer for extended amounts of time. Improper volume is most often necessary due to the poorly designed headphones which do not keep out competing sounds from outside the set. This forces the wearer to turn up volume in order to hear the program which is being broadcast on the set. Sound levels in excess of 110 decibels are not uncommon in these circumstances. OSHA's noise standards prohibit this level of noise. There are other factors to be considered. Communication under normal situations is not easy, especially in the field where machinery is being used to excavate or to accomplish other similar tasks. It becomes significantly more difficult to communicate with an employee when he is wearing headphones. The chance of hearing a warning shout, an unusual machinery noise, the sound of a horn or back up alarm or the screeching of tires is greatly decreased by the interference caused by the headphone. This also causes a problem for the public's safety. The company cannot afford to become involved in litigation which could result from an employee's failure to prevent an accident due to the use of a music headphone while on the job. It should be noted that this policy is specific to "music" headphones. Such are not to be confused with approved communication headphones, ear protector muffs, or secretarial dictaphones. These units must meet stringent specifications before they are marketed and are well regulated to insure that the wearer is not subjected to harmful after effects.

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FALL PROTECTION PROGRAM

I. PURPOSE To provide guidelines for maximum protection for all employees against falls from

elevations above six feet (6') when working or moving on a project that requires elevated work.

II. GOAL To achieve 100% fall protection when working six feet or more above ground level

or adjacent surface. III. PLANNING Achievement of 100% fall protection starts with proper planning. Each project and

each job being different, planning for each is necessary. Planning should include at a minimum the following:

• Schedules of project materials • Equipment, material and supplies needed for fall prevention • Work sequence • Employee orientation • Training • Inspection and Maintenance • Rescue training and equipment IV. RESPONSIBILITY Project management and front line supervision are responsible for implementation,

enforcement and supporting this policy to assure compliance by all employees. 1. Project Management are responsible to: a. Plan in advance the methods, material and equipment needed for

compliance. b. Authorize the necessary action to correct unsafe acts and/or

substandard safety conditions reported or observed. c. Establish training programs to acquaint the worker with fall preventa-

tive measures and fall protection procedures.

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2. Superintendents are responsible to: a. Determine the fall prevention/protection equipment and/or materials

needed by employees working in locations above six feet (6') and assure that the equipment and/or material is available prior to work.

b. Ensure that the COMMERCIAL SCAFFOLD, INC. Fall Protection

Program is explained to each employee and subcontractor before they start work and a means is provided for their active participation.

c. Make daily safety inspections of equipment and job activities. 3. Project Foremen/Supervisor a. Instruct employees in safe work practices and methods at the time

the employee is given a work assignment. b. See that employees have and use the proper fall protection

equipment and tools for the job. c. Continuously check to see that no unsafe practices or conditions are

allowed to exist on the job. 4. Subcontractors Each contractor is responsible to provide and execute all work in compliance

with this program for their employees. V. FALL PREVENTION 1. General All jobsites must make maximum use of fall prevention systems such as

scaffolds, aerial lifts, personnel hoists, ladders and stairways. 2. Fall Prevention Systems Fall Prevention Systems including the following shall be instituted on each

and every jobsite as applicable. Some jobs will require the implementation of one or more of the following:

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a. These systems provide walking and working surfaces in elevated

areas which are free from floor openings and are equipped with standard guard rail systems on all open sides and with closure apparatus for ladder openings or other points of access when required. These systems include but are not limited to: scaffolds, aerial lifts (scissor lifts, etc.) and other approved personnel hoisting devices.

b. "Standard Railing" systems: This requirement consists of a top rail approximately forty tow inches

(42" - 45") above the walking/working surface, a mid-rail at approxi-mately twenty one inches (21") above the surface and a four inch (4") high toe board, and the entire system must be capable of supporting a 200 pound live load in any direction.

c. Floor openings and hole covers: Floor opening/hole covers are to be used to close openings and

holes in floors, platforms and walkways. These covers must be capable of supporting the maximum potential load they may be subjected to and be secured against displacement. Each must be made of at least 3/4" construction grade plywood. The words "hole cover - do not remove" of the equivalent must be marked on the cover.

3. Temporary Work Platforms and Walkways a. Employees working from temporary work platforms or traveling on

temporary catwalks must have their safety lanyard secured at all times to a structure or lifeline capable of supporting 5400 pounds impact loading.

b. Every temporary work platform or walkway must be provided with a

safe means of access/egress which allows employees to be hooked up at all times. Rope grabs or retractable lifelines must be used to achieve fall protection while ascending or descending to temporary work platforms or walkways.

4. Personnel Lifts/Hoisting/Devices a. Employees riding in or working from lifts must secure their safety

lanyard to the lift basket at all times. b. Lifting devices must be placed on solid level surfaces so as to reduce

the possibility of overturning.

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5. Sky-Climbers and Spiders a. Employees riding in or working from these devices must be provided

an independent lifeline and rope grab to which their safety lanyard must be secured.

b. Each lifeline must be secured to an individual anchor point. 6. Crane Hoisted Personnel Baskets/Platforms a. Use of these devices must comply with the safety procedures set

forth in the COMMERCIAL SCAFFOLD, INC. Safety Manual and applicable OSHA regulations.

VI. FALL PROTECTION 1. General a. Employees traveling or working in elevated areas six feet (6') or more

above ground level or adjacent surface where a fall exposure exists must make use of personal fall protection in securing their safety lanyard at all times to a structure, lifeline or approved fall arresting device capable of supporting 5400 pounds.

b. Fall protection equipment such as safety belts, lanyards, rope grabs,

lifelines, etc. must be inspected on a regular basis for damage and/or deterioration. Defective equipment must be removed from service and destroyed or repaired.

c. Fall protection equipment that has been subjected to a shock load

must be removed from service. d. Fall protection equipment and systems must not be used for any

other purpose other than employee safe guarding. 2. Safety Harnesses and Lanyards a. Lanyards must be the double locking type and must not exceed six

feet (6') in length. A two lanyard system must be used when necessary.

b. Safety harnesses and lanyards not furnished by COMMERCIAL

SCAFFOLD, INC. must be inspected and approved by project management prior to use.

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c. Safety harnesses must be of the approved type with a double "D"

ring. 3. Lifelines a. Lifelines must be capable of supporting 5400 pounds. b. Lifelines must not be used for any purpose other than fall protection. c. Anchor points for lifeline must be capable of supporting 5400 pounds. d. Horizontal lifelines must be of three-eighths inch (3/8") wire rope

cable as a minimum and must be secured on each end by at least two (2) cable clamps.

e. Horizontal lifelines should be placed to provide hook up points at

least waist high for employees. f. Vertical lifelines must be of five-eighths inch (5/8") synthetic rope. g. Vertical lifelines must be used with approved rope grabs designed for

use with five-eighths inch (5/8") rope. h. Retractable lifelines must be approved for use in fall protection. i. Retractable lifelines must be secured by means of shackles and/or

wire rope slings or synthetic slings. j. Retractable lifelines must have a rope tag line attached for extending

the line to lower elevations whenever necessary. 4. Safety Nets Safety nets may be used in some situations as fall protection. The

installation and use of safety nets must be under the direction of the Safety Department.

VII. PLANNING 1. General Planning for 100% Fall Protection must be done on an individual project

basis. However, the sequence of planning should remain the same for all projects.

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2. Fall Hazard Analysis An analysis of elevated work begins by individually identifying the fall

hazards that can occur during the work tasks. A look at the required work task mobility is important. A job that lacks a set pattern or sequence of movement may necessitate a change to meet the capabilities and limitations of available equipment.

Scaffold erection, for example, varies considerably depending on the facilities or structure around which the scaffold is built. An appraisal of each exposure may serve to provide a rationale for reducing the level of risk. Overall, the primary objective would be to minimize the probability of a loss by controlling the most frequent elevated work task with the highest potential severity.

3. Hazard Control Measures Once an elevated fall hazard has been recognized and analyzed, an

approved control measure must be selected. Exposure to a fall hazard can either be prevented or fall protection equipment can be used to prevent and/or control the fall.

4. Prevention Preventative measures involve the installation of floors, walls, nets,

handrails, ladders and fixed platforms. These measures consist of permanent, passive systems and all require substantial planning effort. The availability of bucket trucks, scissor lifts, and other personnel lifts is increasing. These devices offer a means of access to a work station or can be used for the installation of a preventative or personal fall protection system. When aerial lifts are used, personal fall protection (safety harness and lanyard) is still required.

5. Protection When fall prevention is not feasible due to location, or not practical for the

work to be done, personal fall protection must be put into place. The overall objective is to minimize the potential for the employee to sustain injury due to a fall. It is important to determine how rescue will be accomplished in the event of a fall. Personal fall protection should serve to arrest a fee fall. Items required for personal fall protection include but are not limited to: safety harnesses, lanyards, rope grabs, harnesses, vertical and horizontal lifelines and retractable lifelines.

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6. Orientation and Training A personal fall protection system must include not only the device and all the

accessories, but also proper orientation and training. Training is the first step to increase awareness and to develop an understanding of the capabilities and limitations of available equipment. Training is the key to making employees aware of how to hook up the proper equipment, once anchor points have been established. Training will determine what additional skills, knowledge or understanding an individual needs to perform with efficiency -- without incident. An understanding of the equipment and its limitations enables employees to work out simple sequences of moving with protection.

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ELECTRICAL SAFETY GUIDELINES BASIC REQUIREMENT Employees must follow and management must ensure that applicable electrical safety guidelines be implemented, and maintained to prevent electrical shock or other injuries resulting from either direct or indirect electrical contacts, when work is performed near or on equipment or circuits which are or may be energized. Program requirements are listed below: STANDARD PRECAUTION Prior to working on or near potentially energized/live parts all efforts must be made to de-energize and lock out/tag out the equipment and electrical circuit(s). The only reasons for allowing parts to remain energized are: l Additional/greater hazards would be created. l Testing or trouble shooting that can be performed only with the circuit energized.

Electrical conductors and parts that have not been locked out/tagged and verified, shall be treated as energized parts. In addition to lock out/tag out, verification of the de-energized condition shall be required, before any circuits or electrical equipment can be worked on. As a result a Qualified Employee shall use test equipment to test the circuit elements and equipment parts to verify zero energy. This test shall include a determination of induced voltage, or unrelated voltage backfeed, or voltage presence due to improper wiring.

(Note: Test equipment used on circuits over 600 volts shall be checked for proper

operation before and after the test). The use of a Qualified Employee shall also be required prior to re-energizing a

system to ensure that all tools, electrical jumpers, shorts, and grounds have been removed.

GENERAL ELECTRICAL PROCEDURES REQUIREMENTS All repair, adjustment, diagnostic or load measurement work which must be performed on or near potentially energized circuits or equipment shall follow established procedures and requirements which include the following: l Only Qualified Employees shall work on or near electrical circuits or live parts (see

definition of Qualified Employee).

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l Specific requirements for personal protective equipment, insulating or shielding

materials, insulated tools/equipment and non-conductive ladders, etc. shall be maintained.

l Requirements for identifying and guarding hazardous conditions and protecting

employees from electrical shock, burns or failure of electrical equipment shall be met by the use of signs, tags, barricades or attendants.

l Tests and inspection criteria to: Verify de-energized status Ensure integrity of protective equipment and test instruments. l Requirements that protective equipment and test instruments and accessories shall

be rated and/or certified for the circuits and equipment which they will contact and for the environment in which they will be used.

l Adequate lighting. Additional electrical procedures shall be maintained, if applicable, for the following tasks: l Working near overhead lines by Qualified Employees (precautions to include

ground personnel). l Work in confined spaces or areas having limited work space. l Handling conduit or other conductive material in and around energized

conductors or circuit parts. l Cleaning and housekeeping performed on or in proximity to energized parts. l By-passing electrical safety interlocks. (Note: Procedures shall be developed which address working on or near 48 volt

DC circuits which involve high amperage. Burns and other injuries can occur from the unanticipated arcing of these systems).

TRAINING Employees whose work requires them to work on or near exposed parts of electrical circuits operating at 50 volts or more to ground shall be trained in and familiar with safety-related work practices/procedures that pertain to their respective job assignments.

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Training shall include but not be limited to: l Electrical Safety Related Work Practices/Procedures: l Procedures which apply to specific tasks identified as applicable. l Safe use of equipment such as: Portable electric power equipment. Grounding-type equipment, precautions regarding plug-in equipment. Electric power and lighting circuits. Operation of circuit protection devices, and test and inspection procedures

for instruments and equipment. l Safeguards for personal protection: Use, inspection and maintenance of personal protection and protective tools

and equipment. Use of signs, tags, barricades and attendants. l Each Qualified Employee must also be trained and familiar with: Skills and techniques necessary to distinguish exposed live parts from other

electrical parts. Skills and techniques to determine the nominal voltage of exposed live parts. Clearance distances required for specified voltage ranges and work

practices for overhead powerlines, if applicable. OTHER REQUIREMENTS A ground fault assurance program shall be established to ensure the grounding integrity of: l Single insulated power tools l Extension cords. l Equipment used in wet or otherwise conductive environments.

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Procedures and schedules shall be established for inspection, testing/certification and maintenance on the following equipment/systems: l All insulating and grounding systems l Portable power equipment l Personal protective equipment, (per American National Standards Institute and

American Society of Testing Materials). l Protective devices on generating and distribution systems. Persons other than Qualified Employees shall not position themselves or the longest conductive object he or she may possess closer to any unguarded, energized overhead line than the following distances. l Ten feet: Voltages to ground 50kv or below l Ten feet plus four inches for every 10kv over 50kv Qualified Employees who have to work in the vicinity of overhead power lines must follow minimum specified approach distances and shall receive additional training. The COMMERCIAL SCAFFOLD, INC. Health, Safety and Environmental Department shall be contacted if additional assistance is required. l Live parts under 50 volts do not need to be de-energized if there is no

increased potential exposure to electric burns or to explosion from electric areas.

(Note: Procedures shall be followed which address working on or near 48 volt DC

circuits which involve high amperage. Burns and other injuries can be incurred from the unanticipated arcing of these systems).

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ELECTRICAL EQUIPMENT This procedure outlines the policy on all electrically powered tools and equipment to protect employees from electrical shock. Temporary Lighting 1. Temporary lights shall be equipped with guards to prevent accidental contact with

the bulb. 2. Working spaces, walkways, and similar locations shall be kept clear of cords. 3. Portable electric lighting in moist or other hazardous locations (drum, tanks,

vessels, pipes, etc.) shall be operated at a maximum of 12 volts. Cords and Portable Tools 1. All extension cords, portable electric tools, and equipment shall be of three wire

type. 2. Portable tools will have trigger-lock devices removed. 3. Flexible cords shall be used only in continuous lengths without splice unless the

insulation is equal to the cable being spliced and wire connections soldered. 4. Cable passing through work areas shall be covered or elevated. 5. Worn or frayed electrical cables shall not be used. 6. Extension cords shall not be fastened with staples, hung from nails, or suspended

by wire. Disconnecting Means Disconnecting means shall be located or shielded so that employees will not be injured. 1. Boxes for disconnecting means shall be securely fastened to the surface upon

which they are mounted and fitted with covers. 2. Boxes and disconnecting means installed in damp or wet locations shall be

waterproof.

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GFCI Ground fault circuit interrupters are to be used on 120 volt, single phase 15 and 20 ampere outlets in line with cord on all temporary wiring receptacles. ELECTRICAL EQUIPMENT INSPECTION AND REPAIRS Each job site will maintain a record of all electrical equipment in use. The record will include all extension cords and drop lights which have been made for the field. All of this equipment must undergo an inspection prior to being made available to the field and is to be reinspected when returned. A monthly inspection program is optional when a site is using total GFCI protection. Extension Cords, Drop Lights, Portable Hand Tools (Drills, Saws, Grinders, etc.) 1. If any electrical equipment is in need of repair, it is the foreman's responsibility to

turn it in to the shop for the needed repairs. The shop will make the necessary repairs or replace the equipment if warranted.

2. The shop will make all necessary repairs to cords and equipment. No repairs

should be made on electrical equipment other than by a competent electrical repairman. The shop inspector will, after a thorough inspection, place an inspection tape on each item indicating the month of expiration (See monthly color code chart).

3. It is the responsibility of each foreman who has the equipment under his control to

establish adequate measures to ensure that the equipment is returned to the shop when the color code indicates that it is time for the equipment to be reinspected. No equipment should be used with an expired inspection code on it unless prior permission has been obtained.

4. Prior to issuing any portable electrical tools or equipment, the shop attendant will

check the tool or equipment to ensure that it is safe to use at that time. Electrically Powered Shop Equipment 1. All electrical powered shop equipment rigidly wired from main switches to

equipment will be inspected by the shop on a regular basis. Any equipment found to be in an unsafe condition will be removed from service until repairs are made.

2. Grounding rods and attachments are required and must be used. Office Electrical Equipment (Water Coolers, Electrical Heaters, Air Conditioners, etc.) 1. The shop will inspect all electrically operated office equipment periodically. This

includes fans, typewriters, calculators, water coolers, electrical heaters, air conditioners, etc.

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2. Any equipment found to be defective will be taken out of service and tagged "do not

use". Grounding of all Equipment Upon installation of any electrical power service to any apparatus or device, grounding circuits will be run, attached, and inspected by a qualified electrician. ASSURED EQUIPMENT GROUNDING PROGRAM 1. The following chart gives the recommended methods of coding to record the testing

and date of test. 2. Even though the color coding provides for monthly identification, the testing is

required only on a three- month basis. In order to be in compliance, the color(s) for the current or one of the two preceding months must be attached. Included is a quarterly (three-month) color code which correlates with the monthly colors and its use would comply with the requirements; however, for most users, it may be as convenient. Its use would necessitate testing and marking all equipment on the first day of each quarter rather than spreading the testing over a three-month period.

3. Self-adhesive color tape is recommended for use in the marking scheme. 4. Monthly Color Code Chart Month Color January WHITE February " March " April GREEN May " June " July RED August " September " October ORANGE November " December " 5. OSHA requires that the continuity and connections are to be tested after any

repairs or incidents reasonably suspected to have caused damage. It is recommended that this test record be verified by the use of the color "Brown" along with the current month's coding.

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SAFETY LOCK AND TAG OUT PROCEDURE The purpose of this lock and tag out procedure is to prevent injury and/or death to personnel by requiring that certain precautions be taken before servicing or repairing equipment. This includes shutting "off" and "locking out" the electrical power source of the equipment. On pneumatic and hydraulic systems, the pressure must be released and lines either disconnected or double blocked (with bleed) or blinded, and locked out, if possible. In addition, a DANGER, "Do Not Use", "Do Not Open" or "Do Not Operate" tag is to be placed at the power sources and valves of all equipment being serviced. GENERAL SAFETY LOCK AND TAG OUT PROCEDURE DANGER TAGS: Danger tags are not to be considered as a positive means of securing equipment, but are to be used in conjunction with locks. Tags will be used only to identify that work is being done on a valve, switch, or piece of equipment when injury or property damage could result from the operation. No work is to be done on any operable equipment until the operation of it is prevented by the use of this procedure. Danger tags should be used as outlined below: 1. Only the standard construction DANGER tags will be used. These may also

include either the words "DO NOT USE" or "DO NOT OPEN" depending on the operations at hand.

2. All tags are to be securely attached, dated, and signed by the person performing

the work. 3. Tags should be destroyed immediately on removal except those that are designed

to be re-used. However, no alterations are permitted. 4. No piece of equipment or device should be operated when there is a tag or lock

attached, regardless of circumstances. 5. No person should ever remove worker's tag or lock. Only the worker who placed

the lock and tag on the equipment should remove it. 6. It is the responsibility of the job superintendent or foreman to see that no work is

performed beyond the protection of locks and tags which have been installed. 7. Workers may place "multi-lock" devices on the equipment if other employees or

trades are involved. All persons working on the equipment must have their own lock and tag in place.

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CONSTRUCTION EQUIPMENT OR FACILITIES LOCK OUT/TAG OUT SEQUENCE A. The worker places the tag on all controls to warn others that the equipment

is not to be operated. The worker writes the reason on the tag(s), identifies the equipment and dates and signs each tag.

B. The worker will pull power switches and/or circuit breakers and place a

lockout clip(s) and a lock(s) on the controls to make them inoperative. Other power sources such as air, steam, or hydraulic may require blinding, disconnection, or valve locking.

C. After the worker has tagged and locked the equipment, the equipment

should then be tried to assure that it will not operate. D. All COMMERCIAL SCAFFOLD, INC. locks and tags should be installed first

and removed last, if possible. E. When other crafts are required to work on the same equipment, they must

place their personal locks and tags on each piece of equipment. F. All crafts must "try" equipment after installing their personal locks to assure,

once again that it will not start. G. Locks and tags must remain on controls until work has been completed and

it is safe to start the equipment. If maintenance or electrical work is to continue into the next shift, persons going off shift shall remove their "personal" lock and leave their tag on the equipment. Persons coming on shift must install their own personal lock(s) and tag(s) if they will be working on the equipment.

H. Upon completion of work, all other crafts will remove their locks and tags

first. COMMERCIAL SCAFFOLD, INC. locks and tags are to be removed last after it is determined that the equipment is safe to operate.

I. No equipment should be started by anyone (including bumping to check

rotation) without permission from the COMMERCIAL SCAFFOLD, INC. job superintendent or foreman responsible for the equipment.

OTHER SYSTEMS A. Appropriate person de-energizes, tags, locks, and "tries" the system. B. Workers performing the work are to place their locks and tags. C. Workers are to remove their locks and tags when their work is completed

and then the appropriate person removes his lock and tags and then re-energizes the equipment.

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SHOP EQUIPMENT 1. The qualified operator of shop equipment may lock out his equipment to change

tools, chucks, blades, and perform similar tasks. 2. A power disconnect switch must be provided for this purpose at or near the

equipment unless the equipment can be unplugged. 3. Push-button or butterfly controls may not be used for purposes of lockout. 4. A lock with a tag may be used for this purpose. 5. The above does not apply to any maintenance or repair work that is done by other

than the authorized operator. LOCKS 1. Only individual keyed locks will be used. The key will remain in the possession of

the person placing the locks. 2. A master series of locks to be used specifically for lockout may be provided to each

department that requires them. Master keys for the department will remain in the possession of the Safety Coordinator.

WARNING Any person who operates a switch or device to which "DANGER" tags are attached or removes a tag without authorization will be subject to dismissal. EMPLOYEE TRAINING: All employees who are responsible for following this procedure must receive training in the procedure. This includes all employees who perform the following duties: maintenance, repair, or construction personnel, janitorial or clean-up personnel. Following initial training in lock-out tag-out principals, each employee will receive an annual follow-up training session. Each training session shall include at minimum the following: - Lecture regarding this procedure including its purpose, scope, and

application; - Visual support materials including but not limited to video or film presentation

of "Lockout Safety Procedures"; and - Written quiz to establish the proficiency of the student.

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ENFORCEMENT/INSPECTION: Due to the severity of injury that could occur while not following these procedures, the company will strictly enforce this policy. The primary responsibility lies with each supervisor for monitoring performance of their workers. Those employees found to be in violation of this procedure will be subject to the "Disciplinary Policy". All surveys of worker performance shall be documented on the District's "Safety Inspection Report" form. The "inspection" must include the following information: 1. Identity of the machine or equipment on which the "Lock Out" procedure was

being utilized; 2. Date of inspection; 3. Employees included in the inspection; and 4. The person performing the inspection. SUPERVISORY RESPONSIBILITIES 1. It must be the responsibility of all supervisors of employees performing such

operations to: A. Instruct their employees as to the content of this procedure. B. Periodically follow-up to assure compliance with this procedure.

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RESPIRATORY PROTECTION PROGRAM POLICY Many substances exist in the industrial environment which can prove to be harmful to a person's respiratory system and overall health. We at COMMERCIAL SCAFFOLD, INC. are committed to meeting our moral and legal obligation to protect our employees from these substances and the serious effects they can have. Some substances can be controlled through engineering techniques, such as ventilation systems. There are, however, situations which known engineering techniques cannot be applied. It is in these situations where respiratory protective equipment becomes necessary. COMMERCIAL SCAFFOLD, INC. has established minimum standards for the use of respiratory protection equipment for certain conditions. These minimum standards are detailed below and equipment meeting or exceeding these standards shall be used, unless authorized by the Safety Coordinator. MINIMUM RESPIRATORY EQUIPMENT STANDARDS The following is a list of respirators which are designated as the minimum protection for the specified exposure: A. Welding - not in a confined space Dual Cartridge where positive ventilation cannot with Dust/Fume be achieved. Filter B. Welding - in a confined space Air Supplied where positive ventilation cannot Respirator be achieved. C. Demolition, earthwork, etc - 3M 8710 or Dual Cartridge with Dust Filter D. Cleaning with acids or caustics Dual Cartridge w/ Acid Filter E. Use of solvents or spray painting Dual Cartridge w/Organic Vapor Filter All others must be evaluated per the guidelines below.

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RESPIRATORY EQUIPMENT STOCKED BY COMMUNICATIONS INTERNATIONAL The above guidelines have been established to assist field management in the proper selection and use of respiratory equipment on the job site. This information is intended to insure that respiratory protection meets or exceeds the requirement of OSHA for any given exposure. However, there may be instances where there are special requirements; either the client may mandate that a different type of respirator be used, or after careful re-evaluation by COMMERCIAL SCAFFOLD, INC. management (Foreman, Superintendent, Safety Coordinator, or Project Manager) a change in the quality of protection may be necessary. It is also necessary to be familiar with the various MSDS (Material Safety Data Sheet) for any chemicals, or construction products that require the use of respiratory protection. Generally speaking, the equipment and exposures listed above will cover over 90% of the job sites that are a part of COMMERCIAL SCAFFOLD, INC. operations. RESPIRATORY HAZARDS You must first identify and evaluate the hazards present before you can select the right respirator. Respiratory hazards come in the form of dusts, fumes, mists, vapors, and gases. The hazard comes from the presence, or in cases of oxygen, the lack of a material. A respiratory hazard is a hazard when a material can enter the body by being inhaled and cause illness or bodily damage. The types of respiratory hazards to which workers may be exposed to workers can be classified as either acute or chronic: Acute hazards are those hazards which are immediately dangerous to life or health, and can cause immediate death (i.e. oxygen deficiency, H2S, Chlorine). Chronic hazards are those hazards which can cause permanent damage to a healthy worker following exposure over a substantial period of time (i.e. asbestos, benzene). In order to determine the proper respiratory protective equipment to be used, the material(s) to which a worker may be exposed must be classified into one of the categories listed below: DUST Solid particles generated by handling, crushing, or grinding of organic or

inorganic materials (Hazardous types include: asbestos, coke fines, catalyst dust).

FUMES Solid particles formed when a molten solid, such as metal cools and

condenses (Hazards: welding fumes).

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MISTS Suspended liquid droplets generated from condensing gas to liquid or from

breaking up a liquid by splashing or spraying (Hazardous types: spraying of paint or acid).

VAPORS The gaseous form of substances normally in the solid or liquid state

(Hazardous types: benzene, solvents). GASES Normally formless fluid which can only be changed to a liquid by combining

pressure and temperature (Hazardous types: H2S, Chlorine, Ammonia, S02, Methane, Butane).

OXYGEN DEFICIENCY The single respiratory hazard that poses the greatest problem and threat to life is oxygen deficiency. Normal air contains 21 % (percent) oxygen by volume. Oxygen levels of 16 % or less cannot safely support the respiratory needs of a person. This is why oxygen levels must always be taken into account when evaluating a worker's respiratory protection equipment. Oxygen levels must be at least 19 1/2 % by volume if respiratory protective equipment is to be used. An oxygen deficient atmosphere is a condition often found in poorly ventilated confined spaces. This atmosphere is classified as immediately dangerous to life or health. This atmosphere can occur in two ways: oxygen may be used up by a chemical reaction or oxygen can be displaced by another gas. EVALUATION OF THE HAZARD The hazard evaluation must be performed by a qualified individual who is trained in the operation of the proper detection equipment. If you are not qualified, contact the owner's personnel or the COMMERCIAL SCAFFOLD, INC. Safety Coordinator to properly evaluate the hazard. If the hazard identification and evaluation was performed by others, they should advise you in writing of their findings (i.e. stated on the Entry Permit).

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RESPIRATORS AND THEIR LIMITATIONS There are two categories of respirators which we use in our work; air purifying respirators and air supplying respirators. AIR PURIFYING RESPIRATORS Air purifying respirators do just what the words imply: they purify the air, but they do not supply oxygen if there is a deficiency. Air purifying respirators with filters are designed to remove particulates (dusts, mists, and/or fumes) from the air: there are disposable respirators (Examples: the 3M 8710 Dust Respirator and the 3M 9920 Welding Fume Respirator); and those with dual cartridges (the North 7700 series has cartridges for contaminants such as highly toxic particulates, organic vapors, acid gases, or asbestos). Each is designed to protect the wearer from gases, dust and/or vapors. LIMITATIONS OF AIR PURIFYING RESPIRATORS - "DO NOT USE" DO NOT USE AIR PURIFYING RESPIRATORS under the following conditions: 1. When the contaminant has poor warning properties; that is, when it cannot be

recognized by taste, smell, or irritation at or below the permissible exposure limit; 2. In oxygen deficient atmospheres; 3. In atmospheres immediately dangerous to life or health (atmospheres in which

a short exposure would cause death, injury, or delayed physical reaction). Air purifying respirators are small and allow freedom of movement. However, every time the wearer inhales, a negative pressure is created in the mask relative to the outside atmosphere. If the wearer does not have the proper fit or seal of the respirator on his face, then the contaminants will be drawn into the facepiece through the leaks in the seal. BREAKTHROUGH If a wearer of an air purifying respirator begins to taste, smell, or be irritated by the contaminant, it is an indication that a "breakthrough" has occurred. This means that it is time to replace the cartridge, provided that the wearer had a good seal or fit at that time. When using a cartridge for particulates, the contaminant will restrict or clog the air flow as the contaminant is trapped by the filtering action of the cartridge.

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AIR SUPPLYING RESPIRATORS We also have available airline respirators which use a stationary source of compressed air delivered through a high pressure hose. The breathing air is monitored for oxygen content and carbon monoxide contamination by special monitoring equipment connected to the source of the air. (Instructions on the use of this equipment are provided with it.) This equipment is designed for protection against most gases, vapors, and particulates for extended periods of time. Air continuously flows into the facepiece preventing inward leakage of contaminated atmospheres. LIMITATIONS OF AIR SUPPLIED RESPIRATORS This system is not designed to protect workers from air contamination that is immediately dangerous to life or health (IDLH) without the addition of an Emergency Escape Air Cylinder. Since the wearer is dependent upon a remote source of air, it would be extremely dangerous without emergency backup to work in an environment which is immediately dangerous. For example, if the hose is accidentally cut or blocked, or if the air source fails, the wearer would be unable to escape safely. Therefore, should a worker be required to work in any environment that is Immediately hazardous to Life or Health (IDLH), they should be provided with, at minimum, a air supplied respirator with an emergency escape air pack, where the escape route will take no more than 5 minutes. These are minimum OSHA requirements. RESPIRATOR EQUIPMENT PURCHASE All respirator equipment must be "approved" equipment for the protection against the particular contaminant found. All respirator equipment shall have either a NIOSH or MSHA approval certification. EMPLOYEE SCREENING OSHA guidelines require that any employee required to wear respiratory protection first be able to pass a medical/physical examination that will demonstrate his ability to wear the equipment without being a threat to his health. All employees will be required to pass a pre-placement physical examination prior to being issued any respiratory equipment. Some of the factors which will be considered include: 1. Lungs Does the individual have a history of asthma or emphysema, difficulty

with normal breathing, or previously documented lung problems? These conditions coupled with the wearing of a respirator will further restrict already difficult breathing.

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2. Heart Does the individual have high blood pressure, artery diseases or

documented heart problems? The use of a respirator will add stress on the heart which will aggravate these conditions.

3. Other Facial hair such as a beard or sideburns that Factors project under

the facepiece will cause a poor seal. Missing or arthritic fingers which would make it difficult for the individual to properly adjust and operate the respirator.

Facial scars that would prohibit a proper fit. Claustrophobia and poor

eyesight is considered. ISSUANCE OF RESPIRATORY EQUIPMENT Where practical, respiratory protective equipment will be issued for an employee's exclusive use. This will be especially true for cartridge type respirators. Cartridge type respirators come in various sizes, small, medium, and large, for the different shapes and sizes of faces. For single use, "disposable", equipment such as the 3M 8710, the equipment shall not be transferred from one individual to another. Disposable respirators shall not be re-used or shared and should be disposed of after each use. RESPIRATORY FIT TEST Fit tests are essential to ensuring that a respirator mask forms a good seal against the wearer's face to prevent contaminants from leaking into the mask. When a respirator is first issued to the wearer, they should try a variety of sizes to get a comfortable fit. Then a qualitative fit test, which includes a positive and negative fit, should be done. This can be self-administered and should be done with all air-purifying respirators before entering a hazardous atmosphere. The manufacturer's instructions, which accompany the respirators, should be consulted and followed. Negative pressure fit test: the wearer closes off the respirator inlet and inhales. A vacuum and partial inward collapse of the mask should result. If a vacuum cannot be maintained for at least ten (10) seconds, readjust the facepiece and try again. Positive pressure fit test: the wearer closes off the exhalation valve and breathes out gently. Air will escape through any gaps in the seal between the face piece and the wearers face.

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EQUIPMENT MAINTENANCE For all reusable respiratory equipment the following maintenance steps will be performed by shop personnel as the respiratory equipment is received from a job site. This includes all cartridge respirators, airline respirators, and self-contained breathing apparatus. 1. All equipment when received shall be cleaned and thoroughly disinfected.

Each respirator shall be thoroughly dry and placed in a clean plastic storage bag. All equipment shall be properly stored to protect it from dust, sunlight, heat, extreme cold, excessive moisture, and damaging chemicals.

2. All respirators shall be inspected for defects and missing parts before and

after each use and during cleaning. All straps, valves, regulators, etc. shall be in good working order or the respirator shall be removed from service immediately and tagged "do not use".

3. Any defects found shall be noted and repaired by qualified personnel. The above maintenance also applies to job site locations. Suitable storage and cleaning facilities shall be established as conditions allow. The job foreman shall be responsible for making the necessary arrangements to ensure that all applicable items in this section have been followed. EMPLOYEE TRAINING It will be the responsibility of the foreman to ensure that all individuals are properly trained in using the assigned respiratory equipment. The following items shall be reviewed with each employee: ALL RESPIRATORS 1. Name and location of the work area requiring respiratory protection

equipment. Describe the toxic substances present which make it necessary to wear a respirator. Give specific information regarding the contaminants, i.e. gases, vapors, toxic dust, etc.

2. Describe the type of respirator being assigned. Discuss the limitations of the

assigned respirator, i.e. good for dust only, do not use where toxic gases are present, etc.

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3. Review the respirator operating procedures: refer to the manufacturer's

instructions. Insure each worker has a proper fit of the assigned respirator. Have each demonstrate a positive and negative fit test.

RESPIRATORS - NOT INCLUDING DISPOSABLE 4. Instruct and show the employee how to inspect the respirator before each

use. 5. Review the company and job site policy for respirator cleaning with the

employees. If the respirators are to be cleaned on the site, identify the designated person assigned to the task. If the employees are assigned to clean and maintain the respirators, show the designated washing area and the proper procedure for cleaning. Insist that the respirator be cleaned after each use.

6. Review with the employee the designated storage area for his equipment.

Insist that the respirator be placed here after each use of the equipment. 7. Explain to the employees the need to report any defects that may be found

when using their equipment. NOTE: Items 4 through 7 above generally do not apply to disposable

respirators or those designed for single use. PROGRAM AND SITE EVALUATION Periodic inspections and safety surveys will be performed by the Safety Coordinator to insure that the necessary respiratory program is effective. If surveys indicate that changes are required, they will be made. Each foreman should make a routine review of his equipment during their job site inspections. Since each job site is different, hazard identification must be coordinated with the customer. Proper respirator selection must be based on hazard surveys and the customer's requirements.

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OXYGEN ACETYLENE WELDING AND CUTTING OXYGEN - FUEL GAS APPARATUS Oxygen-fuel gas welding depends on the heat produced by the combustion of a fuel gas in the presence of oxygen. The equipment is relatively portable and does not require an electric power source. Basic equipment consists of a cylinder of oxygen, a cylinder of fuel gas, two regulators, two hoses and a welding torch. The regulators are used to reduce the pressure of the gas in the cylinder to the required work pressure. Other protective equipment (safety check valve) in the piping system prevents the backflow of oxygen into the fuel gas system, stops a flash from entering the fuel gas system, and prevents an excess of pressure from oxygen in the fuel gas system. These devices help to prevent fires and explosions and are basic and permanent parts of the apparatus. SAFE HANDLING OF CYLINDERS Explosions of fuel gas or oxygen cylinders are not common occurrences due in part to the healthy regard that workers have developed for the disastrous consequences of unsafe handling procedures. Cylinders must be stored in dry well ventilated areas where they are not likely to be struck or knocked over. They should be secured "upright" by some substantial (chain, heavy wire, etc.) means so they will not fall. They should never be stored near stairways, gangways, or elevators. Keep sources of ignition at least 20 feet away from the storage area. Store oxygen and fuel gas cylinders separately (at least 20 feet apart or by a non-combustible barrier 5 feet high) and do not store oxygen with reserve stocks of carbides or other combustible materials. It is particularly important not to store oxygen cylinders in the same area as oil, grease or other petroleum products. CONTACT BETWEEN OXYGEN AND ANY PETROLEUM BASED PRODUCTS CAN RESULT IN FIRE AND EXPLOSION. Always attach the valve protection cap (hand tight) when the cylinder is not being used. The cap is designed to protect the valve from damage which could cause the sudden release of the contents of the cylinder. Make sure the cylinders clearly marked with their contents, i.e. oxygen, acetylene, etc. When a cylinder is emptied, mark it EMPTY or M T.

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VALVE EXAMINATION AND REGULATORS Use the proper wrench when attaching the regulator to the cylinder. Do not use a pipe wrench or a pair of pliers. If the valve is equipped with a hand wheel do not attempt to open or close it with a hammer. Watch the needle of the regulator after the torch valves have been closed. If it begins to creep upward replace the regulator immediately. Do not try to repair regulators or torches. Repair work should be done by a qualified person. CONNECTIONS AND HOSES Replace hoses which have leaks, burns, or worn places. Cut out the damaged section and splice the two cuts together. Do not attempt to repair hoses with tape. You can test for leaks by submerging the hose in water and looking for bubbles. Leaks in connections and hoses can also be detected by painting on a leak test solution of soapy water and checking for bubbles. Never test for leaks by using a flame. Use only approved bronze or brass fittings. When making up connections do not use white lead, grease, pipefitting compounds or other petroleum products. Make sure that the hoses are not placed where they can be walked on, driven over, cut or otherwise damaged. Do not expose them to heat, sparks, oil or grease. COLOR CODE THE HOSES All welding gas hoses used in the operation should conform to the following color code schedule: GREEN..........OXYGEN RED............ACETYLENE BLACK..........AIR/INERT GAS

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ELECTRIC ARC WELDING Electric arc welding is a fusion process in which adjoining pieces of metal are melted together forming a joint which is as strong as the original metal. Heat is supplied by an electric arc drawn between the work and an electrode. There are two types of electrodes, Carbon and Tungsten. The only function of a carbon or tungsten electrode is to carry current. As current is applied to the electrode the electrode melts supplying filler metal to the joint. In addition to carrying current and supplying filler metal, these electrodes are coated with a substance which vaporizes as the electrode melts. The vapor which is formed provides a gaseous shield around the arc and the work which prevents the formation of oxides and nitrides in the weld metal. While vapor from the coating on the electrodes has not been identified as an occupational hazard, filler metals which are introduced to the joint as the electrode melts may contain cadmium, nickel, or fluorine compounds. In all instances precautions must be taken to avoid contact with the metal fumes or the flux itself. OSHA regulations require that when the filler metal contains cadmium the containers must be labeled: WARNING CONTAINS CADMIUM POISONOUS FUMES MAY BE FORMED ON HEATING When fluxes contain fluorine compounds the containers must be labeled: CAUTION CONTAINS FLUORINE Adequate ventilation and/or respirators must be used to avoid breathing the fumes.

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WELDING EQUIPMENT Check both the weld lead cable and the work lead cable for damaged insulation and for exposed wires. Check electrode holders for loose or exposed connections. Do not splice weld lead within 10 feet of the holder. Replace it. Do not coil the electrode cable around your body. Check the composition of fluxes, rods, and coatings. If there is a potential hazard find out how to protect yourself. Ground both the frame of the welding equipment and the metal being welded. Do not attach the ground wires to pipes carrying gas or flammable liquids or to metal conduits carrying electrical wires. Ground as close to the machine as possible. When floors are wet take precautions against shock. Do not allow metal parts in contact with the electrode to touch your skin or wet clothing. Wear dry work gloves. Do not cool electrode holders by putting them in water. Electrically disconnect the welding equipment when changing electrodes in gas tungsten arc electrode holders. PERSONAL PROTECTIVE GEAR Personal protective gear for welders is required to protect the operators eyes from radiation and to protect the operator form hot weld slag. Sunglasses or colored glass will not provide sufficient protection against radiation. Specially designed helmets equipped with filter plates to protect against ultraviolet, infrared and visible radiation must be worn when arc welding. Cover bare skin to protect against both sparks and radiation. Woolen clothing gives better protection than cotton because it is less flammable. If cotton clothing is worn it should be treated chemically to reduce flammability. Clothing should be free of grease and oil and other substances which may burn. Do not wear clothing with cuffs or pockets where sparks can lodge. Flame proof gauntlet gloves, a leather or asbestos apron and high top shoes provide good protection against sparks and hot slag.

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WELDING PROCEDURES FIRE PREVENTION Misuse of portable welding equipment is a frequent cause of industrial fires. Stationary equipment is less hazardous because it is usually located in an area designed with fire prevention in mind. Portable equipment can be carried to almost any location on the job and improper use of the equipment can result in a fire and/or explosion. Do not allow welding in areas which have not been made fire safe. BEFORE BEGINNING WELDING OPERATIONS Clear the floor of paper, wood shavings and other flammable materials for a space of 35 feet. Move other flammable materials at least 35 feet from the work area, or cover them with fire resistant shields. Cover the cracks and openings in the floor to prevent sparks from falling through to the lower floors. If it isn't possible to do this, check the lower floor and make sure there are no combustibles which could be exposed to sparks. When possible move the work to be welded to a safe location. Cover wooden floors with a fire resistant material. Cover nearby combustible walls and partitions with fire resistant shields. If the walls are made of metal, remove the combustible material from the other side. If they can not be removed, station a "fire watch". Shut down ventilation and close ducts if there is a chance they could transmit sparks to other areas in the facility. Maintain a "fire watch" during the work and for 1/2 hour after the work is completed. Train "fire watchers" in the proper use of fire extinguishing equipment and how to sound alarms. (See Fire Watch Instructions) Provide fire extinguishers or sprinkler systems in welding areas. Portable welding equipment should be equipped with an extinguisher.

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CAUTION TOXIC SUBSTANCES MAY BE PRESENT WHEN WELDING When hazardous substances are used as base metals, fluxes, plating or filler metals, local exhaust ventilation must be used. Beryllium, cadmium, chromium, fluorides, lead, mercury, zinc, or any inert gas metal arc welding, and oxygen cutting of stainless steel, all require the use of local exhaust ventilation to bring toxic concentrations within the Permissible Exposure Limit (PEL). If it is not possible to supply adequate ventilation, use supplied air respirators. Remove coatings along the line of the weld (lead paint, galvanize, coal tar pitch, plastic, etc.) so they can't burn. Clean all work which has been degreased, and do not operate electric arc welding equipment near a degreasing operation. The degreasing agents trichlorethylene and perchlorethylene (or any other agent) decompose when exposed to the arc and can irritate the eyes and respiratory tract.

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WELDING IN CONFINED SPACES The threat posed by toxic gases, fumes, and dust is intensified when the welding work is done in a confined space. Concentrations of toxic substances can rapidly reach hazardous levels without adequate ventilation. OSHA regulations governing work in confined spaces require that the area be adequately ventilated and free from flammable or explosive substances. No welding or cutting may take place until the atmosphere has been tested and shown not to be dangerous nor likely to become dangerous. Workers in the confined space must be equipped with a safety belt and life line. A trained worker with approved respiratory equipment must remain on "standby" outside the confined space ready to provide assistance in case of emergency. REFER TO THE CONFINED SPACE ENTRY PROGRAM FOR COMPLETE DETAILS.

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FIRE WATCH INSTRUCTIONS Because of the important responsibilities you assume when you become a Fire watch, you should be thoroughly familiar with the duties. READ THE FOLLOWING INSTRUCTIONS CAREFULLY. A. Primary Responsibilities Your primary responsibilities are: 1. Prevent ignition of any flammable material. 2. Should a fire occur, immediately extinguish it or turn in a fire alarm. CALL 911 OR THE EMERGENCY ALARM NUMBER 3. Maintain the conditions and requirements listed on the safety permit. 4. STOP THE JOB if you observe any condition which you consider to be

hazardous. B. BASIC DUTIES Circumstances and conditions of the job determine what the safety requirements

and fire watch duties will be. However, the following duties are basic to all jobs: 1. Do not leave the job site while welding or spark-producing operations are in

progress. If other duties require you to leave the job site, you must first STOP THE JOB.

2. Before the job starts and during its progress, survey the entire area for

potential release of flammable liquids or vapors. In this connection, be on the lookout for possible operating upsets. Make sure that operations at nearby job sites are aware of the work in progress.

3. Prevent the taking of samples, venting or opening of piping or equipment in

the immediate area of the hot work where such action would release flammable liquids or vapors and expose our workers to their danger.

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4. Determining the exact location of fire fighting equipment in the immediate

area. Be certain that you know how to operate this equipment, ie., fire extinguishers, hydrants, hose carts, fixed monitors.

NOTE: Do not pre-charge fire extinguishers. 5. If you have any questions regarding the job, check with your Supervisor. 6. BE ON THE ALERT. Try to anticipate and prevent any condition that would

be hazardous. 7. Upon completion of the job and before departing from the site, make sure

there are no hot sparks, burning embers, etc. still present. Return any fire fighting equipment to its original location.

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"SAFETY WATCH INSTRUCTIONS" (For Jobs Other Than Welding Which Require a Fire Watch) The Safety Watch duties are to observe other employees while they are performing their work and identify potentially unsafe conditions that may cause an accident. In addition you are to act as a communication link for employees performing the work. Requirements of the Safety Watch 1. The "Safety Watch" must understand how the job is to be performed and

what the conditions or limitations are on the permit. Should these conditions change or employees not follow instructions on the permit, the "Safety Watch" shall shut the job down and report the change in conditions or that the employees are not following instructions on special jobs.

2. The "Safety Watch" must maintain a constant means of communication with

the employees requiring the "Standby". Visual and voice contact will be kept when possible. A means of voice contact must be maintained whenever visual contact cannot be constant. The "Safety Watch" must be familiar with "sound powered" telephones or "walkie-talkies" if they are used.

3. The "Safety Watch" should discuss the job with the Foreman assigning the

job and those employees performing the job in order to determine what action should be taken in the event of an accident or emergency.

4. The "Safety Watch" must stay at the work site until authorized to leave as

directed by the Foreman assigning the job. If for any reason the "Safety Watch" should have to leave the job site, STOP THE JOB and notify those employees you are "standing-by-for" that you are leaving the job.

5. The "Safety Watch" must be familiar with the location, operation, and use of

the fire and safety equipment in the work area. A fire extinguisher must be at the work site when burning or welding is in progress.

6. The "Safety Watch" shall immediately shut down the job if conditions

change, presenting a hazard to workers or if directed to shut down the job by a responsible person.

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7. The "Safety Watch" may be responsible for other duties not listed above, as

directed by the Foreman assigning the job. 8. It may be a requirement that the "Safety Watch" be ready to wear a self-

contained breathing apparatus. If this is required, you must be qualified to wear it. NOTE: Facial hair and spectacle bar (glasses) interfering with the seal area of respiratory equipment shall not be permitted.

Should there be any doubt or misunderstanding about the above requirements, you are to contact your Supervisor immediately.

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EXCAVATION, TRENCHING, AND SHORING I. PURPOSE The purpose of this policy is to establish safe operating procedures for any

earthwork or underground work that is done on a job site. It is to ensure the safety of personnel who are required to enter/work in excavations and trenches that are 5'0" or deeper and to maintain compliance with the applicable OSHA regulations. The policy also applies to work when conditions warrant that are less than 5'0" in depth.

II. SPECIAL REQUIREMENTS A. COMPETENT PERSON All earthwork in excavations and trenches will be over-seen by a

competent person at all times. OSHA's definition of a competent person is "one who is 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".

A competent person within the organization would include but is not limited

to: the Safety Coordinator, the General Foreman of Civil Operations, a designated foreman, and executive management.

B. PREPLANNING Prior to beginning any earthwork, the foreman and competent person are

required to review the job for the primary hazardous exposures to workers and the public.

Exposures include but are not limited to the following: surface hazards or encumbrances; underground installations; means of access or exit from trenches or excavations; exposure to vehicular traffic; exposure to falling loads; warning system for mobile equipment; hazardous atmospheres; contaminated soil; emergency rescue equipment; water accumulation; stability of adjacent structures; protection from loose rock or soils; fall protection; support systems; and materials and equipment.

C. UNDERGROUND INSTALLATIONS 1. Prior to beginning any excavation, the Regional Notification Center,

Underground Alert, will be called to assist in the location of utility installations.

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2. The Regional Notification Center and all owners of underground

facilities in the area who are not members of the Notification Center must be advised of the proposed work at least 2 working days prior to the start of any digging or excavation work, except in the case of emergency repair work.

3. Prior to opening an excavation, efforts shall be made to determine

whether underground installations; i.e., sewer, telephone, water, fuel, electric lines, etc., will be encountered, and if so, where such underground installations are located.

4. The exact location and depth of these lines will be marked by stakes

indicating type of service. After all underground services have been checked and marked, work may begin at the direction of the competent person.

D. ACCESS AND EGRESS 1. Structural Ramps: If structural ramps are to be used as a means of

access and egress, they must be designed by a competent person and constructed in accordance with the design.

2. Means of egress: A stairway, ladder, ramp, or other safe means of

egress will be located in trench excavations that are 4 feet or more in depth, and will be located so as to require no more than 25 feet of lateral travel by employees.

E. VEHICULAR TRAFFIC Employees exposed to vehicular traffic must be provided with and must

wear reflectorized highly visible warning vest. F. EXPOSURE TO FALLING LOADS No person must be permitted under loads handled by lifting or digging

equipment including power shovels, derricks, or hoists. Employees will be required to stand away from any vehicle being loaded or unloaded to avoid being struck by any spillage or falling materials. Operators may remain in the cabs of vehicles being loaded or unloaded when the vehicles are equipped to provide adequate protection for the operator during loading and unloading operations.

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G. WARNING SYSTEM FOR MOBILE EQUIPMENT When mobile equipment is utilized or allowed adjacent to excavations,

substantial stop logs or barricades must be installed. If possible, the grade should be away from the excavation.

If it is necessary to place or operate power shovels, trucks, materials, or

other heavy objects on a level above and near an excavation, the side of the excavation must be sheet-piled, shored, or braced as necessary to resist the extra pressure due to such superimposed loads.

H. HAZARDOUS ATMOSPHERES 1. TESTING AND CONTROLS: In addition to the requirements set forth

in the CAL/OSHA safety orders, for both construction and general industry, the following requirements will apply:

Testing for oxygen deficiency (19.5% minimum) or hazardous

atmosphere will be performed in any excavation greater than 4 feet in depth, or at any depth where employees are doing hand work or repairs within the walls of any trench, where the above conditions exist or could reasonably be expected to exist, such as in areas of contaminated soils or areas where hazardous substances are stored nearby.

2. ADEQUATE PRECAUTIONS: The following precautions will be taken

to prevent employee exposure to hazardous atmospheres: a. Provide proper respiratory protection or ventilation where

exposure to atmospheres containing less than 19.5% oxygen and/or other hazardous atmospheres exists.

b. Provide proper ventilation to prevent exposure to atmospheres

containing a concentration of flammable gas in excess of 20% of the lower flammable limit of the gas.

c. When any of the above controls are used, periodic retesting of

the atmosphere will be conducted as often as necessary to ensure the atmosphere remains safe.

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I. EMERGENCY RESCUE EQUIPMENT 1. Emergency rescue equipment, such as breathing apparatus, a safety

harness and lifeline, or a basket stretcher, must be readily available where hazardous atmospheric conditions exist or may reasonably be expected to develop during work in an excavation.

2. Emergency rescue equipment, when required, will be attended when

in use by a "safety watch". 3. Prior to entry into any deep and confined footing excavations, bell-

bottom pier holes, or other similar deep holes, employees are required to wear a harness with a lifeline securely attached to it. The lifeline must be separate from any line used to handle materials, and must be individually attended by a "safety watch" at all times while an employee is in the excavation with this equipment.

J. WATER ACCUMULATION 1. Employees are not permitted to work in excavations where there is

an accumulation of water or where water is accumulating, unless adequate precautions have been taken to protect the employees against the hazards. Special precaution which can be taken include but are not limited to: a special support or shield system to protect from cave-ins; water removal to control the level of accumulating water; and use of a safety harness and lifeline.

2. When water removal equipment is used to prevent or control the

water from accumulating, then the equipment and operations will be monitored by the competent person to ensure proper operation.

3. Diversions, ditches, dikes, or other suitable means will be used to

prevent surface water from entering an excavation and to provide adequate drainage of the area adjacent to the excavations. Any excavation subject to runoff from heavy rains will require an inspection by a competent person and compliance with the above (1 & 2).

K. STABILITY OF ADJACENT STRUCTURES 1. If the stability of adjoining buildings or walls is endangered by

excavation operations, support systems such as shoring, bracing, or underpinning must be provided as necessary to ensure the stability of such structures for the protection of employees' safety. Such shoring, bracing, or underpinning must be inspected daily or more often, as conditions warrant, by a competent person and the protection effectively maintained.

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2. Except in hard rock, excavations below the level of the base footing

of any foundation or retaining wall is not permitted, unless the wall is provided with a support system such as underpinning to ensure the safety of employees and the stability of the structure.

3. Sidewalks, pavements, and appurtenant structures are not permitted

to be undermined unless a support system or another method of protection against collapse is provided for the safety of employees.

L. LOOSE ROCK OR SOILS 1. Adequate protection must be provided to protect employees from

loose rock or soil that could pose a hazard by falling or rolling from an excavation face. Protection may consist of scaling to remove loose material; installation or protective barricades at intervals as necessary on the face to stop and contain falling material; or other means that provide equivalent protection.

2. Sides of trenches in unstable or soft material, five feet or more in

depth, must be shored, sheeted, braced, sloped, or otherwise supported by means of sufficient strength to protect the employees working within them.

3. Excavated or other materials must be placed 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 rolling into excavations, or a combination of both methods if necessary.

M. INSPECTIONS Daily inspections of excavations, the adjacent areas, and protective systems

must be made by the competent person who is assigned to the project for evidence of possible cave-ins or slides, indications of failure of protective systems, hazardous atmospheres, or other hazardous conditions as follows:

1. At the start of work and as needed throughout the shift. 2. After every rain storm or other hazard increasing occurrence. 3. These inspections are only required when employee exposure can be

reasonably anticipated.

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When there is evidence of a situation that could result in a possible cave-in,

or indications of a failure in the protective systems, or a hazardous atmosphere has developed, or other hazardous conditions are found, all employees must be removed from the hazardous area until the necessary precautions have been taken to safeguard employees.

N. FALL PROTECTION Where employees or equipment are required or permitted to cross over

excavations, walkways, or bridges with standard guardrails must be provided.

Adequate barricades providing physical protection must be provided at all

excavations. All wells, pits, shafts etc., must be barricaded and covered. Upon completion of operations, temporary wells, pits, shafts, etc., must be backfilled.

Barricades Types of excavations and trenches four (4) feet or deeper must be shored

or sloped back to angle of repose in compliance with OSHA requirements. All open trenches and excavations must be barricaded.

1. Excavations (Trenches) requiring wooden barricades constructed

with 2" x 4" rail at 42 inches in height and 2" x 4" midrail, including 2 x 4 uprights no further than 3 feet apart are:

A. Any Excavation to be opened more than 48 hours. B. Any Excavation that cuts an accepted established walkway,

sidewalk or aisleway. 2. Excavations requiring saw horse-type barricades with flashing lights

are: Any excavation cutting into an accepted or established non-public

roadway or walkway, or temporary roadway where vehicles may travel.

3. All Excavations (Trenches) not covered by 1 and 2 above must be

barricaded with Yellow and Black barrier tape, erected at approximately 42 inches high with uprights no further apart than twelve (12) feet.

4. All excavations on public streets require that they be completely

covered prior to leaving the site at the end of the work shift. If natural cover is not possible steel plates anchored to the street with asphalt nosing must be employed.

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III. REQUIREMENTS FOR PROTECTIVE SYSTEMS A. PROTECTION OF EMPLOYEES IN EXCAVATIONS 1. Each employee in an excavation will be protected from cave-ins by

an adequate protective system designed in accordance with applicable CAL/OSHA standards and the requirements of Section B below except when:

a. excavations are made entirely in stable rock; b. excavations are less than 5 feet in depth and examination of

the ground by a competent person provides no indication of a potential cave-in.

2. Protective systems must have the capacity to resist, without failure,

all loads that are intended or could reasonably be expected to be applied or transmitted to the system.

B. DESIGN OF SLOPING AND BENCHING SYSTEMS The slopes and configurations of sloping and benching systems are to be

selected and constructed in accordance with the requirements of this policy and CAL/OSHA as listed below:

1. Excavations are to be sloped at an angle not steeper than one and

one-half horizontal to one vertical (34 degrees measured from the horizontal) unless one of the following options are used:

a. OPTION #1 - Use Appendices A & B to determine the proper

slopes and configurations. b. OPTION #2 - Slopes and configurations are designed using

written tabulated data such as tables and charts, to include: The identification of the parameters that affect the selection of

a sloping or benching system including its limit of use, size and configuration to be safe, and the necessary information to aid in selecting a correct system approved by a Registered Professional Engineer, and a copy of the approved data is maintained at the job site during construction, and a copy made available to CAL/OSHA upon request.

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c. OPTION #3 - Design by a Registered Professional Engineer

in written form to include: The calculations, magnitude, and configurations determined to

be safe for the project, with a copy to be maintained at the job site, and one made available to CAL/OSHA upon request.

C. DESIGNS OF SUPPORT SYSTEMS, SHIELD SYSTEMS, AND OTHER

PROTECTIVE SYSTEMS If used, these systems are to be designed in accordance with the

requirements of Section 1541.1 (C) (1) or (2) or (3) or (4) of the CAL/OSHA Construction Safety Orders.

D. MATERIALS AND EQUIPMENT 1. All materials and equipment used for protective systems is to be used

free from damage or defects that might impair their proper function, and used and maintained according to manufacturer's specifications.

2. When material or equipment is damaged, the company's competent

person will examine it for approval for suitability and continued use. E. INSTALLATION AND REMOVAL OF SUPPORT SYSTEMS 1. General a. Members of support systems must be securely connected

together to prevent sliding, falling, kickouts, or other predictable failure.

b. Support systems must be installed and removed in a

manner that protects employees from cave-in, structural collapses, or from being struck by members of the support system.

c. Individual members of support systems must not be subjected

to loads exceeding those which the members were designed to withstand.

d. Before temporary removal of individual members begins,

additional precautions must be taken to protect employees, such as installing other structural members to carry the loads imposed on the support system.

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e. Removal must begin at, and progress from, the bottom of the

excavation. Members must be released slowly and carefully removed so as to note any indication of possible failure of the remaining members of the structure of possible cave-in of the sides of the excavation.

f. Backfilling must progress together with the removal of support

systems from excavations. 2. Additional requirements for support systems for trench excavations. a. Excavation of material to a level no greater than 2 feet below

the bottom of the members of a support system will be permitted, but only if the system is designed to resist the forces calculated for the full depth of the trench, and there are no indications while the trench is open of a possible loss of soil from behind or below the bottom of the support system.

b. Installation of a support system must be closely coordinated

with the excavation of trenches. F. SLOPING AND BENCHING SYSTEMS Employees are not permitted to work on the faces of sloped or benched

excavations at levels above other employees except when employees at the lower levels are adequately protected from the hazards of falling, rolling, or sliding material or equipment.

G. SHIELD SYSTEMS Should a shield system be used on any job, it must be designed for the job

requirements and approved safety procedures followed (Ref. CAL/OSHA Sec. 1541.1(g) of the Construction Safety Orders).

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IV. PERMITS Prior to the start of any work which involves substantial risk of injury, a permit is

required to be obtained from CAL/OSHA. Such is the case for all trenches or excavations which are 5 feet or deeper.

A. ISSUANCE OF PERMITS Recently the requirement have changed which make the annual review

process longer and more comprehensive. This program has been amended to meet the most recent requirements of CAL/OSHA.

1. ANNUAL PERMIT: The company will maintain an annual permit with

CAL/OSHA when it becomes aware of jobs that require excavation or trenching work in excess of 5'0". If this were to be necessary, during the first part of each January, the safety coordinator or executive officers, will meet with the local office of CAL/OSHA to renew the annual permit. At that time a Permit Application Form will be completed by one of the company's competent persons. Before the permit is issued, CAL/OSHA's personnel will normally review this safety policy and their own files for our company. This is normally an informal conference. However, it may be necessary for CAL/OSHA to conduct an investigation or hearing if prior negative experience warrants. Upon successful review by CAL/OSHA, the permit will be issued.

2. JOB PERMITS: Each job which requires a trench or excavation to be

5 feet or deeper will require formal notification to CAL/OSHA that the company will be doing work. This is a requirement even though the company may have an annual permit on file with CAL/OSHA. There is however no cost for this service.

The permit can be obtained by simply calling CAL/OSHA by phone and

providing them the necessary information, which they will document. This must be done at least 24 hours prior to the start of work. However, it is recommended, for purposes of documentation, that this call is followed by the job superintendent completing a blank permit form and then fax or send a copy of the form to the local office of CAL/OSHA. If no forms are available on site, one can be requested from CAL/OSHA.

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HEARING CONSERVATION PROGRAM The Company has established a Hearing Conservation Program to protect workers from the hazards of noise on the job. OSHA regulations require that each employer implement a hearing conservation program when workers are exposed to noise levels exceeding 85 db. It is not hard to exceed this level of noise on many of the jobs within our job sites. Typically, noise levels exceeding 85 Db are experienced when working with any type of pneumatic chipper or hammer, metal saws, and grinders. COMMERCIAL SCAFFOLD, INC. has taken a conservative approach to this environmental hazard by establishing this program. The following elements establish the program: 1. An Audiometric Testing Program 2. An Employee Education and Training Program 3. Monitoring and Analysis of Workplace Noise Levels 4. Provide Suitable Engineering Control When Appropriate 5. Provide Hearing Protectors Where Required 6. Maintain Pertinent Records for The Above AUDIOMETRIC TESTING Each new employee whose work exposes them to noise levels above the "OSHA action level" will receive an Audiometric test as part of a pre-screening physical examination. Annually, each construction employee and any others who are exposed to noise levels exceeding 85 Db will be given a follow-up Audiometric examination to monitor for any significant changes in their hearing ability. Employees will be formally notified if their is any change in their hearing as the result of this testing. EMPLOYEE EDUCATION AND TRAINING Each new employee upon hire and annually thereafter will receive training in the Company's hearing conservation program. This annual training will include the following: a. A summary of the State noise standard; b. Information on the effect of noise on hearing;

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c. Specific information about job site machine noise; d. The role of administrative and engineering controls; e. The contents of the Company's noise control plan; f. A discussion of hearing protectors - the advantages and disadvantages of various

types, and instructions on the selection, fitting, use, and care of the protectors; g. An explanation of the purpose of the audiometric testing and the test procedure, as

well as the specific noise exposure for employees. MONITORING AND ANALYSIS OF WORKPLACE NOISE LEVELS The Company will periodically or as necessary, conduct noise level surveys of the workplace. The results of these surveys will be made available to employees upon request. Any job area or company location found to be in excess of the allowable designated noise levels that cannot be brought into compliance with the noise standard will be designated as an area where hearing protectors are to be worn. PROVIDE SUITABLE ENGINEERING CONTROLS Where appropriate, the Company will provide suitable engineering controls to reduce noise exposure. Due to the complexity of most construction job sites, it is many times difficult if not impossible to institute effective engineering controls for most noise exposures. Should this be the case, then employees will be required to wear suitable hearing protectors. PROVIDE HEARING PROTECTORS WHERE REQUIRED The Company will provide and require workers hearing protectors if their 8 Hr. TWA is above 90dB. The Company will also make hearing protectors available to all employees exposed to a TWA above 85dB. Any employee who may have a significant threshold shift of hearing level will be required to wear hearing protectors if they are exposed to a TWA of 85dB. The Company will provide workers with a choice of at least one type of ear plug and one type of ear muff. On most job sites, there will be a choice of two different types of ear plugs. The Company will make a concerted effort to find the right protector for each worker, one that offers the right attenuation, is accepted on the terms of comfort, and is used by the employee.

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MAINTENANCE OF RECORDS All record-keeping for this program will be maintained by the Corporate Office. Records will include: audiometric testing results; noise surveys; employee training; engineering controls implemented; and distribution and purchase of hearing protectors. WORK REQUIRING HEARING PROTECTORS There are many jobs or type of work generally produce noise levels that intermittently or for short durations exceed the permissible TWA. It is the policy of COMMERCIAL SCAFFOLD, INC. to require all workers who are engaged in the following jobs to wear hearing protectors: 1. Workers using or adjacent to the use of pneumatic tools such as chippers,

hammers, grinders, or others making excessive noise. 2. Metal Saw Cutting Use. 3. Extensive use of metal hammering, cutting, drilling, or forming. 4. Work around operating compressors and other noisy machinery.

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CONFINED SPACE ENTRY PROCEDURES I. INTRODUCTION: Personnel are at times required to enter enclosed spaces (hereafter called confined spaces) to clean, inspect, repair, and perform other duties associated with a job. II. PURPOSE: Entry into any confined space can be dangerous if the safety and integrity of the confined space is not known and properly controlled and maintained. It is important to understand and know what a confined space is, how to recognize the hazards associated with it, and how to eliminate or control any adverse exposure. It also important to establish emergency procedures to assist in the removal of workers should the need arise. III. DEFINITIONS: 1). CONFINED SPACE: A space defined by the concurrent existence of the

following conditions: A). Existing ventilation is insufficient to remove dangerous air

contamination and/or oxygen deficiency which may exist or develop. B). Ready access or egress for the removal of a suddenly disabled

employee is difficult due to the location and/or size of the opening. 2). DANGEROUS AIR CONTAMINATION: An atmosphere presenting a threat

of causing death, injury, acute illness, or disablement due to the presence of flammable and/or explosive, or toxic, or otherwise injurious or incapacitating substances.

A). Dangerous air contamination due to the flammability of a gas or vapor

at a concentration greater than 20% (percent) of its lower explosive (lower flammable) limit.

B). Dangerous air contamination due to a combustible particulate is

defined as a concentration greater than 20% (percent) of the minimum explosive concentration of the particulate.

C). Dangerous air contamination due to the toxicity of a substance is

defined as the atmospheric concentration immediately hazardous to life or health. This does not preclude the requirement to control harmful exposures to toxic substances at concentrations less than those immediately hazardous to life or health.

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3). OXYGEN DEFICIENCY: An atmosphere containing oxygen at a

concentration of less than 19.5% (percent) by volume. IV. SCOPE: Confined spaces which are potentially hazardous, can be found on some jobs, include but are not limited to: 1. Enclosures with limited access openings for personnel, such in as process

or storage vaults; 2. Tanks, pits, tubs, vaults, vessels, or other confined areas and spaces where

it is difficult to have a free exchange of clean air, or where hazardous ingredients had been processed prior to entering the area or space;

3. Confined spaces such as ventilation, process, or exhaust ductwork, sewers,

underground utility tunnels, pipelines, or piping of any type; V. HAZARDS: The hazards commonly encountered in a confined space include: Toxic vapors in unhealthy or fatal concentrations may result from residue of known or unknown material in a vessel, tank, or pit by gradual release from sludge or scale. The vapors may be introduced by leakage from interconnected systems, or be introduced by use of cleaning solvents, welding, cutting, etc. Flammable gases or dust with the potential of fire or explosion. Lack of oxygen causing asphyxiation may result from chemicals absorbing or replacing oxygen in the space, or from inert gases used to exclude oxygen from a specific area of work. Air in clean enclosures closed for an extended period may become deficient in oxygen because of oxidation of the metal of the tank. Improper or inadequate ventilation during work may also result in a lack of oxygen. Electrical shock from portable lights, tools or associated electrical equipment. Injury from mechanical equipment which may be defective or inadvertently or incorrectly operated. Injury from physical hazards such as slipping, tripping or falling from elevated work areas, platforms, scaffolding, or ladders; falling objects such as debris created during demolition, storage of tools, and equipment which are not properly stored in elevated work areas.

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VI. GENERAL (PERSONNEL GUIDELINES) Supervision and all personnel who may be required to enter confined spaces shall review this instruction to ensure compliance with all applicable paragraphs. 1. Personnel with respiratory problems shall not be permitted in confined

spaces. (All employees should have had an approved physical examination prior to using any respiratory equipment);

2. All personal protective apparel and respiratory equipment herein specified

will be NIOSH approved and shall be worn when entering any hazardous enclosure as required;

3. Supervision over the area to be entered and supervision responsible for

other work conducted in such area shall coordinate and regulate operations in their organizations in a manner which will reduce hazards to personnel entering such a confined space.

4. Job supervision should consult the Safety Coordinator prior to beginning

work on any job should there be any question whether a particular area or job involves a confined space.

No deviations from the safety requirements specified in these instructions

will be permitted without prior approval from the Safety Coordinator. VII. PROCEDURES FOR CONFINED SPACE ENTRY: The hazards inherent in confined space entry can be avoided or overcome if the following principles are applied properly each and every time a confined space is entered. As such, the items below will have been completed prior to our starting work. In all cases, it will be the responsibility of the job supervisor to ensure that each of these requirements have been met. VIII. PRE-ENTRY Prior to entry into any confined space, the following provisions should be reviewed and conditions documented as part of the ENTRY PERMIT: 1. CLEANING. The confined space should be made clean and void of any

residue or contamination as necessary. This can be done by hot or cold water flush, by steaming, by chemical neutralization or by air purge, with harmful vapors vented safely to the outdoors where practicable.

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2. VENTILATION. The confined space should be thoroughly ventilated. After

the space is cleaned and ventilated, a mechanical exhaust system should be kept operating. Should decontamination involve flammable liquids, vapors, gases, or dusts all sources of ignition must be eliminated. Should ventilation be necessary to be continued in the event that flammable vapors remain, all air moving equipment shall meet Class I requirements and compliance with the low voltage safety orders.

3. ISOLATION. The confined space should be completely isolated from all

other systems and equipment. Positive and adequate measures must be taken to prevent harmful materials from entering the confined space while workers are inside.

In all cases where lines have contained hazardous fluids of flammable or

inert gas, or where they contain fluids at high pressures or temperatures, the lines should be physically disconnected by removal of valves, etc., and blank flanges placed in the lines as close to the work area as practical.

If applicable, any drains or overflow lines should be disconnected or

blanked. Other lines to be disconnected or blanked should include steam connections, water, refrigerants, or air lines of any exterior jacket. Open ends of disconnected lines should be blanked or capped to prevent flow from disconnected ends entering an opening or falling on workmen. All blanks should be of sufficient thickness and tensile strength to withstand maximum pressures which may be imposed.

4. LOCKOUT. Line-disconnect switches supplying power to any mechanical

mixers, agitators, pumps, and cover or door actuators should be tagged and locked in the "OFF" position. It is not adequate to lock a push-button station as it still may be possible to energize the circuit. The keys to any locks should be kept by the foremen in charge of the job and he alone shall be authorized to unlock the any switches.

5. TESTING OXYGEN (19.5%) AND GAS. Before entry is made into any

confined space (or tank), a test for oxygen and gas content shall be made. The Safety Coordinator or his designate, in the absence of the Safety Coordinator the supervisor is responsible for the testing, can then give the OK to issue an ENTRY PERMIT. Under no condition will entry be made until this procedure is carried out.

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If dangerous air contamination and/or oxygen deficiency does not exist

within the space, as demonstrated by tests performed, entry into and work within the space may proceed subject to the following:

a). Testing shall be conducted with sufficient frequency to ensure that

the development of dangerous air contamination and/or oxygen deficiency does not occur during the performance of any work. Testing should be conducted at minimum: prior to the beginning of any work, and after any time period where the workers may be on break or lunch.

b). If the development of dangerous air contamination and/or oxygen

deficiency is shown by tests performed, existing ventilation shall be supplemented by appropriate means.

c). When additional ventilation has been provided and dangerous air

contamination and/or oxygen deficiency has been removed as demonstrated by conducting and recording additional testing, entry into and work within the space may proceed subject to the above periodic monitoring.

d). If it is not possible to eliminate the air contamination or oxygen

deficiency, then all workers, including the "safety watch", will be required to wear self-contained breathing apparatus (SCBA) or airline respirators.

6. ISSUANCE OF CONFINED SPACE ENTRY AUTHORIZATION. The

Confined Space ENTRY PERMIT certifies and records approval for entry. It serves as a method of formalizing agreed-upon procedures and also as a checklist to ensure that all existing hazards are considered, evaluated, and correct protective measures taken. No employee should enter any confined space without reporting to and securing approval from his immediate supervisor and the Safety Coordinator, when on the site.

Each supervisor who will send employees into a confined space work area

must ascertain by personal investigation, immediately before entry and before signing the authorization, that the entry and incidental work will be safe. To ensure continuation of safe conditions, if a pause of appreciable duration (i.e., 8 hours) occurs during the work on a job, the site must be reinvestigated by the signers before the job can be allowed to resume. Entry permits are valid for one shift only.

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IX. PRECAUTIONS The following precautions are an integral part of this Confined Space Entry

Procedure. Each element should be reviewed in its entirety prior to beginning work in order to maintain compliance for safe operations.

1. EQUIPMENT AND TOOLS. a). Hand tools should be clean, in good condition, and should be

selected carefully according to the use intended. b). Electrical tools and equipment, such as hand lamps and extension

cords should be grounded, and when used in a Class I enclosure, of the explosion-proof type.

c). Ground fault circuit interrupters must be connected in line and located

outside the confined space for all power tool connections before use. d). In any Class I or Class II exposure, use air-operated power tools. e). Ladders used should be lashed at the top and, if possible, at the

bottom. f). Employees performing welding in a confined space should be

provided with and required to use air line/supplied respiratory protection.

g). Welding and cutting torches must not be taken into the space until

ready to be used and must be removed from the confined space immediately after use.

h). Cylinders of oxygen or other gas shall never be taken into confined

spaces and should be turned off at the cylinder valve when not in use.

2. CLASSIFICATION OF LOCATIONS: A. CLASS I locations are those enclosed areas in which flammable,

volatile liquids, gases, and vapors or mixtures are or may be present in quantities sufficient to produce explosive or ignitable mixtures.

B. CLASS II locations are those enclosed areas which are hazardous

because of the presence of combustible dust.

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3. SIGNS. Signs posted near the entrance to the confined space help keep

unnecessary people away, assist in notification to others on the site that potentially harmful operations should not be started independently nearby without consultation, and help guide rescuers should they be necessary.

4. BARRICADES. Open pits and hazardous confined space operations

require barricading with substantial railing 42" high with toe boards. Rope with streamers at the 42" level is recommended for closing adjacent work areas and aisles. Flashing lights on barricades are necessary when pits are open at night or in dimly-lit areas inside.

5. PROTECTIVE CLOTHING. Special protective clothing may be required by

the Safety Coordinator and job supervisor. It may range from specially-designed, complete coverall suits for protection against highly toxic chemicals - harmful by absorption through the skin, to the standard of chemical goggles, hard hats, gloves and sturdy work shoes normally worn to protect against routine hazards.

Employees should never unduly expose the skin when working in a confined

space especially when it involves exposure to acids, solvents, or caustics. Workers should wear a full coverage of clothing at all times. In most cases, coveralls will be furnished on the job. It will be the responsibility of the foremen to ensure that the proper clothing is being worn.

6. RESPIRATORY PROTECTION. Certified breathing air from self-contained

units, or airline respirators should be supplied and worn if the integrity of the atmosphere cannot be guaranteed and if there is any possibility of air contamination of a harmful nature or of oxygen deficiency while employees are within a confined space.

Such is the case when any electric arc or gas welding or cutting is done. All

welders will be required to wear airline respirators or the equivalent due to the toxic nature of the welding rod and metals and their immediate exposure to these contaminants.

Canister type respirator masks should be worn when any repairs are made

as long as there is an adequate exchange of air and oxygen provided by forced ventilation fans or air movers in the space. Welders helpers and other workers may also use canister type respirator masks when welding is being done in the confined space provided that the air movement is adequate to remove the welding contaminants from the worker's breathing zone and out of the space.

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Canister type respirators, when used in a confined space, do not always

provide adequate protection and should not be used in the following cases: 1). by welders unless air movement is adequate to keep the contaminated air from building up in the work area, 2). when there is a deficiency of fresh air or oxygen in the space, or 3). by rescue workers when condition #2 above exists.

7. EMERGENCY AND RESCUE. Where potential exposure in the confined

space is acute due to the lack of oxygen, air contamination, or exposure to flammable or explosive atmospheres, or where rescue may be difficult, the worker(s) must be provided with a body harness with life line attached. Such safety harness and life line should be used when the shape, size and location of the confined space permits the safe emergency removal of workers by standby personnel without requiring entry into the confined space. The line shall be at least 1/2 inch in diameter and load tested at 2000 pounds.

When the shape, size, and location of the confined space does not meet this

requirement, a specific procedure for the rescue of personnel must be developed in the pre-planning stage of the confined space entry work and made a specific part of the entry permit. In some cases, it is advisable to have a block and tackle positioned on a tripod or otherwise fastened above the manhole. For obvious reasons, manholes large enough to accommodate the man and his safety gear should be provided, such as 24" diameter for circular ones. Where existing manholes are smaller than 20" in the largest dimension, consult the Safety Coordinator for possible use of wrist harnesses. The free end of the life line should be secured to a fixed object and should be attended by a "safety watch" who will keep the man in the confined space always within his view.

8. SAFETY WATCH. At least one safety watch shall be assigned to stand

by on the outside of any confined space opening ready to give assistance in case of emergency. In cases where the atmosphere within the confined space cannot be ensured to be free of dangerous air contamination and/or oxygen deficiency at least one additional employee who, may have other duties, shall be within sight or call of the safety watch.

In case of emergency, the safety watch must never enter the confined

space until he is relieved at this post. It is his job to summon aid immediately, to attempt to remove the victim by use of the life line, and to perform all other necessary rescue functions from outside. Upon arrival of help, he may enter the confined space for rescue work only when he is assured that adequate outside assistance is present.

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The safety watch should be well trained in basic first-aid principles such

as rescue breathing techniques. Rescuers entering the confined space must be protected with the safety equipment required by the situation; i.e., lifeline and harness, and proper personal protective equipment.

The safety watch shall be aware of the conditions of personnel within the

space at all times. They shall not leave their position until the confined space is vacated or they are relieved by other suitably attired personnel.

For rescue purposes, at least one unit of self-contained breathing

equipment or its equivalent should be located outside the confined space and convenient to the safety watch together with harness, rope, and such other emergency equipment as may be needed and indicated above (See Emergency and Rescue).

The safety watch may pass tools, but he must have no other job which will

take his attention away from the man in the confined space and/or which will interfere with his attempts to withdraw a victim by use of the lifeline, or which will require his leaving the vicinity of the confined space for any time whatever.

9. FIRST AID & CPR. At least one person trained in first aid and

cardiopulmonary resuscitation (CPR) shall be immediately available whenever the use of respiratory protective equipment is required. The standards for CPR training shall follow the principles of the American Heart Association or the American Red Cross.

10. COMMUNICATIONS. An effective means of communication between

employees inside a confined space and the safety watch must be provided and used whenever the use of respiratory protective equipment is required or whenever employees inside a confined space are out of sight of the safety watch and other standby employees. All affected employees must be trained in the use of such communication system. The system must be tested before each use to confirm it effective operation.

11. EMERGENCY SIGNALS. A clearly understood signal system shall be

established prior to the start of the operation. The following example can be used when it is necessary for the worker in the space to communicate quickly with the safety watch:

one pull - allow more slack in the line two pulls - lead line is inadequate three pulls - emergency, pull man from space

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One additional safety line will be available for each person within the

confined space. In the event a worker has fouled his life line on a structural member to such an extent that the clearing of the line to effect a rescue would be time consuming and dangerous, the life line to the man will be unsnapped. A new life line will be hooked on and a rescue effected.

X. SUMMARY: It will be the responsibility of the Safety Coordinator and the job supervisor to determine the environmental condition inside the confined space and prescribe the necessary precautions required for safe entry as outlined herein. A minimum of workers will be permitted to work within any confined space at any one time. While personnel are inside the space, a qualified and certified safety watch shall be observing the operation from outside the confined space. The safety watch shall have safety equipment available. The foremen and supervisor concerned must be alert before and during the job to detect and correct immediately new and different hazards, or to stop the work until the new hazards are corrected. The Safety Coordinator should be notified before beginning any unusually hazardous confined space operation.

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"SAFETY WATCH INSTRUCTIONS" The Safety Watch duties are to observe other employees while they are performing their work and identify potentially unsafe conditions that may cause an accident. In addition you are to act as a communication link for employees performing the work. Requirements of the Safety Watch 1. The "Safety Watch" must understand how the job is to be performed and

what the conditions or limitations are on the permit. Should these conditions change or employees not follow instructions on the permit, the "Safety Watch" shall shut the job down and report the change in conditions or that the employees are not following instructions on the permit, to the signer or countersigner of the permit.

2. The "Safety Watch" must maintain a constant means of communication with

the employees requiring the "Standby". Visual and voice contact will be kept when possible. A means of voice contact must be maintained whenever visual contact cannot be constant. The "Safety Watch" must be familiar with "sound powered" telephones or "walkie-talkies" if they are used.

3. The "Safety Watch" should discuss the job with the supervisor assigning the

job and those employees performing the job in order to determine what action should be taken in the event of an accident or emergency.

4. The "Safety Watch" must stay at the work site until authorized to leave as

directed by the supervisor assigning the job. If for any reason the "Safety Watch" should have to leave the job site, STOP THE JOB and notify those employees you are "standing by" for that you are leaving the job.

5. The "Safety Watch" must be familiar with the location, operation, and use of

the fire and safety equipment in the work area. A fire extinguisher must be at the work site when burning or welding is in progress.

6. The "Safety Watch" shall immediately shut down the job if conditions

change, presenting a hazard to workers or if directed to shut down the job by a responsible person.

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7. The "Safety Watch" may be responsible for other duties not listed above, as

directed by the supervisor assigning the job. 8. It may be a requirement that the "Safety Watch" be ready to wear a self-

contained breathing apparatus. If this is required, you must be qualified to wear it. NOTE: Facial hair and spectacle bar (glasses) interfering with the seal area of respiratory equipment shall not be permitted.

Should there be any doubt or misunderstanding about the above requirements, you are to contact your Supervisor immediately.

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ENTRY PERMIT

Nature of Work Equipment Specific Identification Date Entry Requested Location Requested By Date Time The following equipment shall be tagged in the positions indicated in order to isolate the tank, vessel, or piping from external energy sources.

Equipment Position Equipment Position Reviewed and Approved Date Safety Coordinator Protective Equipment Required YES NO Precautions YES NO Safety Belt & Life Line Lines Blocked or Disconnected Supplied Air Mask Vessel Emptied/Cleaned Self Contained Breath. App. 6 or 12V light Rubber Boots & Gloves Explosimeter Test Chemical Goggles Oxygen Test Fire Extinguisher Other Test Coppus Blower or Air Mover _ Other Switches & Valves Locked/Tag Safety Watch Assigned Outside Employees Briefed On Work and Precautions Others Approved: Date Approved: Date Safety Coordinator Supervisor Safety Watch (Name): Employees Entering Space (Names): Authorized By: Date Person to certify that all have exited: Date Time RETURN COMPLETED FORM TO SAFETY COORDINATOR AND MAINTAIN REFERENCE COPY This Permit is good for only one shift; an additional permit is required to continue work. See Safety Coordinator.

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SCAFFOLD ERECTION PROCEDURES SURVEY THE JOB SITE Inspect the jobsite for hazards such as untamped earth fills, ditches, debris, high tension wires, unguarded openings or hazardous conditions created by other crafts. INSPECT ALL EQUIPMENT BEFORE USING Scaffold equipment that is broken or deteriorated to the extent that it would weaken the scaffold shall not be used. Defective equipment should be immediately repaired or removed from the job site. WATCH FOR OTHER CRAFTS Do not erect or dismantle scaffolds when other crafts are working directly above or below the area where you must perform your work. ERECTION RULES ESTABLISH A LAYOUT Locate scaffold legs, ladder access, planking size, well pulley support, total height, etc., before starting the scaffold. PROVIDE BASE PLATES Each upright must bear on a base plate. The base plates must have support adequate to sustain the load. When the scaffold is resting on earth or other such material the base plate shall rest on the equivalent of a 2" x 10" x 10" wood base. Wood base pads are not required on firm surfaces such as concrete, steel, asphalt, etc., except under extreme loading conditions. PROVIDE BRACING Plumb, level and tie all frames together as the scaffold is erected. Complete the work area planking and install all braces, guard rails and ties, as required, before moving to the next level.

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SPACE UPRIGHTS CORRECTLY When erecting tube lox scaffold the upright post of the scaffold shall be spaced not more than 6' x 6'. The first stringer should be as close to ground level as possible. The distance between scaffold lifts should be no more than 6'6" in height. A heavy duty scaffold can support a uniformly distributed load of 75 pounds per square foot. A medium duty steel tube scaffold with post spacing of 8' x 6' and again a lift height of not more than 6'6" can support a uniformly distributed load of 50 pounds per square foot. The maximum height of medium duty or heavy duty steel tube scaffold is 125'. PROVIDE DIAGONAL BRACING The inner and outer rows of upright shall be braced by installing diagonal pipes at about a 45 degree angle starting from the lower outside corner upward to the top of the scaffold frame. When the scaffold is long enough, the diagonal bracing should be duplicated beginning at every fifth post. PROVIDE RAILS Rails shall be installed on open sides and ends of all work platforms 4' or more in height. The top rail shall be at a height of not less than 42" or more than 45" from the top of the work platform. A mid rail is required halfway between the top rail and the work platform. PROVIDE TOEBOARDS Toeboards shall be solid and extend not less than 3-1/2" high above the top of the platform. The bottom clearance shall not exceed 1/4". Toeboards shall be provided on all open sides and ends of scaffolds at locations where persons are required to work or pass under the scaffold and at all interior floor, roof, and shaft openings. If loose brick or other material or equipment is stored or stacked next to the guard rail and is higher than the toeboard, a barrier of 1/2" wire mesh, plywood, or equivalent shall be provided between the top rail and toeboard and secured both top and bottom at locations where persons are required to work or pass under the scaffold. When barrier screens are used midrails may be omitted. SECURING SCAFFOLDS All scaffolds must be built solidly and tied-off with a double wrap of No. 12 wire (or equivalent). (Wood pole scaffolds must be tied every 20 feet horizontally and vertically for light trades and every 15 feet for heavy trades.) Metal scaffolds must be tied every 26 feet vertically and every 30 feet horizontally.

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PLANKING RULES Use only scaffold grade plank. The company uses Douglas fir scaffold plank. These planks have been tested and certified to conform with CAL-OSHA regulations pertaining to scaffold plank. Inspect planks prior to use to be sure they are not warped damaged or otherwise unsafe. Tag and return any questionable plank. LAYOUT The working platform shall cover the entire space between scaffold uprights. All voids in the working platform that could constitute a hazard to the workmen must be covered. The scaffold planks should be of such length that they overlap the pipe at each end by at least 6" or be cleated at both ends to prevent sliding off the support. LADDERS Steel ladder sections must be installed for access to the scaffold platforms. The ladder sections are to be held in place with the proper clamp made for the purpose. Do not use wire to hold the ladder sections to the scaffold members. SAFETY BELTS/HARNESS Safety belts must be used when erecting scaffolds and workers must be tied-off when making connections, or any time you are not climbing.

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SCAFFOLD DISMANTLING PROCEDURES Check to see if the scaffolding has been altered in any way which would make it unsafe, and if so, reconstruct where necessary before commencing with dismantling procedures. Visually inspect plank prior to dismantling to be sure they are safe to work on. Discard any severely damaged plank. Components should be lowered, as soon as dismantled, in a safe manner so as to protect personnel below. Do not accumulate excess components or equipment on the level being dismantled. Dismantled equipment should be stock piled in as orderly manner. Any damaged pipe should be tagged and shipped separately so that it can be repaired at the yard. Safety belts must be used when dismantling scaffold.

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MOTOR VEHICLE SAFETY DRIVER SELECTION The selection of employees who will be required to drive full or part-time should be done with care. Drivers of company vehicles can be considered qualified when they meet the following criteria: 1. Possess a valid State driver's license of the proper class. 2. A review of their traffic record shows that they do not pose an unreasonable risk. 3. Successfully passes a road test administered by the Safety Coordinator and/or their

supervisor where required by their department. DRIVER TRAINING All company drivers should be trained in safe driving habits through use of the National Safety Council's Defensive Driving Course or equivalent. The course should be given to each driver at least once every three years. The course teaches skills in: 1. Defensive driving. 2. Split-second decision making. 3. Backing-up rules. 4. Safe distances. 5. Intersection driving. 6. Poor condition driving in dust storms, rain, etc. PREVENTIVE MAINTENANCE Establishment of a preventive maintenance program for all company vehicles is essential. Record jackets should be maintained on all vehicles so that a log can be maintained on all planned maintenance, as well as repairs made from noted defects.

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VEHICLE INSPECTION Each vehicle or piece of equipment shall be inspected on a daily basis by the operator before and after operation. Each operator is responsible for the safe condition of the equipment. Any vehicle having steering or brake problems is not to be operated until repairs have been made by a mechanic. Any other unsafe conditions are to be reported to the operator's supervisor as soon as possible. VEHICLE OPERATION All company vehicles and equipment are to be operated in a safe manner and adhere to all applicable laws. The operator is totally responsible for the safe operation of the equipment. The vehicle operator shall report any accidents or damage to the supervisor.

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SUBJECT: DRIVER SAFETY PROGRAM INTRODUCTION The operation of vehicles is indispensable in conducting company business. The way in which each vehicle is handled will directly affect the loss picture of the entire company. Fleet losses are potentially one of the most costly type of losses that an operation can incur. The types of exposure that involve the fleet program include: property damage, bodily injury, fatalities, liability suits, and Workers' Compensation cases. The claims cost that would result from losses incurred can mount to dollars that will adversely affect our efforts to accomplish company objectives. To help prevent vehicle accidents and the type of loss exposures associated with them, the following guidelines have been established: POLICY: The success and the safety of our employees depends on the mutual cooperation of each employee who has been entrusted with the responsibility of driving a company vehicle or their own vehicle while conducting company business. In order to reduce vehicle accidents and to limit the company's liability because of driver negligence, the company has adopted a Driver Safety Program. PROCEDURE The procedures set forth in the Driver Safety Program will be the guidelines for management adherence to this policy. RESPONSIBILITY The Supervisors have the primary responsibility for the Driver Safety Program. The Safety Coordinator will appoint a responsible representative to report all driver information requested by our Insurance broker. MONITORING The Safety Coordinator is to be responsible for the records of the Driver Safety Program. Duties will include, but not be limited to: 1. Be responsible for monitoring the driving record of those persons who operate the

company vehicles or their own "personal" vehicle while on company business.

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2. Monitor the Driver's Safety Program and report to management any suggestions for

improvement or needed changes. 3. Monitor the maintenance policy of fleet vehicles so that they are kept in safe

condition. 4. Review each vehicle accident report or infraction with management. 5. Monitor renewals of insurance records. DRIVERS Drivers of vehicles that are owned, rented, or leased by the company will be required to follow defensive driving techniques and practices. The basic defensive driving practices is to plan ahead and do everything that one can reasonably do to prevent an accident. This is to include the use of seat belts. The following guidelines will also be followed: 1. Drivers must posses a valid California driver's license in order to operate any

company vehicle or their own personal vehicle on company business. The duties of drivers will be reviewed to see if they will involve the operation of vehicles that require a chauffeur's license or other special license. The requirement will be noted by the employee's supervisor or personnel staff at the time of hire. Job descriptions will state the requirements for a California driver's license to include the type of license.

2. The driver should be physically and mentally capable of driving the vehicle he/she

is assigned to drive, whether the vehicle be a car, van, or truck. PRE-OPERATION OF VEHICLES Prior to the assignment of any vehicle to any employee or prior to allowing an employee to drive THEIR OWN VEHICLE on company business, the following minimum standards will be implemented and records maintained to insure that the driver is qualified to drive the vehicle and minimize the risk of liability to the company: INITIAL ASSIGNMENT 1. Verification and recording of date and type of driver's license held, and renewal

date noted; 2. A review of the driver's state Motor Vehicle Record for the most recent three-year

period to include the following:

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a. Review of the accident report history showing the dates and types of

accident regardless who was at fault; b. Review of the traffic violations for the last three years; Unacceptable limits are 6 points accumulated or any major conviction

during the past 36 months prior to employment. (See Point System below)

3. Confirmation of personal insurance for those driving their personal vehicle on

company business. 4. Physical examinations when required by the state for the driving of specified

vehicles or by funding and licensing contract. POINT SYSTEM The following criteria will be used in order to determine the acceptability of all drivers. 1 point - minor conviction of a moving violation 1 point - minor accident (no injuries) NOTE: These will not be considered if a driver is able to remove the citation

by going to a traffic school. 2 points - serious accident (those involving injury to any person which requires medical

attention) Continuing criteria as company driver: a. Points will be doubled if driving a company vehicle. b. 2 points will be applied for failure to report a violation or accident regardless of how

minor, involving a company vehicle to the driver's supervisor or fleet supervisor. c. A warning letter will be issued at 4 points or at the time of any preventable accident.

At 6 points the matter will be investigated by the Safety Coordinator, corrective action will then be determined.

d. The driver with a major conviction shall be immediately suspended from driving any

company vehicle or their personal vehicle on company business.

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e. Driving a company vehicle while under the influence of drugs or alcohol will subject the employee to disciplinary action up to and including dismissal.

ANNUAL REVIEW Once each year a request for current license information will be sent to each employee. Employees who drive a company vehicle or if they request mileage reimbursement for driving their personal vehicle on company business will have their personal driving record reviewed. It will be the responsibility of the employee to respond in a timely manner. Failure to respond to the requested information by personal vehicle drivers may result in the delay in mileage reimbursements. A review of each driver's file and record will be made annually and will include all of the criteria above as appropriate for each employee. This will not preclude request of driver's records for review by the Safety Coordinator as deemed necessary. DEFINITIONS Major Convictions: Major convictions include but are not limited to: a. driving while intoxicated or under the influence of alcohol or drugs; b. failure to stop and report an accident; c. homicide, manslaughter or assault arising out of the operation of a motor vehicle; d. driving during a period when license is suspended or revoked; e. reckless driving; f. possession of an open container of alcoholic beverage; speed contest, drag or

highway racing; or g. attempting to elude a Peace Officer. Minor Convictions: Any moving traffic violation other than a major conviction except the following: a. Motor vehicle equipment, load or size requirements; b. Improper display or failure to display license plates provided such plates exist; c. Failure to have in possession a valid driver's license.

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Preventable Accident: A preventable accident is defined by the National Safety Council as: "Any vehicle accident involving a vehicle which results in property damage and/or personal injury regardless of who was injured, what property was damaged, to what extent, or where it occurred in which the driver in question failed to exercise reasonable precaution to prevent he accident." Chauffeur: According to the California Department of Transportation Motor Vehicle Division, chauffeur means a person who is employed by another for the principal purpose of driving a motor vehicle, or a person who drives a school bus transporting school children or any motor vehicle when in use for the transportation of persons or property for compensation, but does not include a car pool operator. Vehicular Accident: Any accident occurring between a company vehicle (or private car when employee is on official company business and has been formerly authorized mileage) and another vehicle, pedestrian, animal or fixed object. SPECIAL NOTE: Police shall be called to investigate all company vehicle accidents, and it is incumbent upon the supervisor to insure that all facts are obtained with respect to the driver. Under no circumstances should any employee make any statement relative to liability or draw any conclusions as to the facts asserted at the scene. The occurrence of a vehicle accident may or may not be the fault of the employee. Therefore, it is imperative that the same investigative procedure which was outlined for the industrial accidents be used to determine the cause of accident and corrective action taken by the employee's immediate superior.

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QUESTIONS TO HELP DETERMINE IF A VEHICLE ACCIDENT WAS PREVENTABLE One basic question in determining preventability is: "Did our employee take every reasonable precaution to avoid the auto accident?" If "No," our driver was not driving defensively and, thus, the accident should be judged "preventable." Please note that legal liability or any citations should never influence the decision of determining preventability of an accident. Answer the following questions which adhere to the given situation(s): 1. Intersection Accidents a. Did our employee approach the intersection at a controlled speed which was

reasonable for conditions? b. Was our driver prepared to stop before entering the intersection regardless

of right of way? c. Did our driver avoid entering an intersection on the amber signal? d. Did our driver avoid overtaking or passing at the intersection? e. At a blind corner, did our driver approach slowly, with a foot on the brake

pedal? f. Did our driver make certain all other drivers were stopping for a traffic light or

stop sign? g. Was our driver alert for the turns of other vehicles? h. Did our driver signal his/her change in direction well in advance? i. Did our driver allow oncoming traffic to clear before making a left turn? j. Did our driver turn from the proper lane? 2. We Pulled from Parked Position a. Did our driver look to the front and rear for approaching traffic immediately

before pulling out? b. Did our driver look back, rather than depending upon the rear vision mirrors?

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c. Did our driver signal before pulling away from the curb? d. Did our driver start out only when an action would not require traffic to

change its speed or direction in order to avoid our vehicle? e. Did our driver continue to glance back while pulling out? 3. We Hit The Other Vehicle In Rear a. Did our driver adjust speed to the conditions of the road, visibility, and

traffic? b. Was our driver maintaining a safe following distance for conditions? c. If a vehicle pulled in front of our vehicle, did our driver drop back and re-

establish the proper following distance? d. Did our driver approach the green traffic light cautiously, expecting the driver

ahead to stop suddenly on a signal change? e. Did our driver look ahead of the vehicle in front for possible emergencies? 4. We Were Backing: a. Was it necessary to back? 1. Did our driver have to park so close to the vehicle or obstacle ahead

that backing was necessary when leaving the parking space? 2. Was it necessary to drive into a narrow street, dead-end, alley or

driveway from which backing resulted? b. If our driver could not see where to back: 1. Did the driver try to get someone as a guide? 2. Did the driver walk around the vehicle before getting in? 3. Did the driver back immediately after walking around?

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4. If applicable, did the driver use the cone policy correctly? 5. Did the driver use the horn while backing? 6. Did the driver look to the rear without depending on the rear vision

mirrors? 7. Did the driver back slowly? 5. We Skidded: a. Did our driver travel at a speed safe for the conditions of weather and road? b. Was our driver keeping a safe following distance? c. Was our driver alert for loose gravel, sand, ruts, etc.? 6. Pedestrians a. Did our driver tap the horn to alert pedestrians of our vehicle approach? b. Did our driver pass through congested section anticipating that pedestrians

might step in front of the car? c. Did our driver keep as much clearance between our vehicle and parked cars

as conditions permitted? d. Did our driver interpret the pedestrian's next action or intention? e. Did our driver check the location of pedestrians before staring at a green

signal? f. Did our driver give all pedestrians right of way? g. Did our driver refrain from passing a stopped school bus? h. Did our driver account for all children before starting up? i. Was our driver alert for signs of children who might run into the path (balls

rolling into street, etc.)?

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7. Others Hit Us While We Were Stopped or Parked: a. Did our driver properly signal his/her intention to stop? b. Did our driver avoid coming to a sudden stop? c. Was our driver parked on the proper side of the road? NOTE: In the event that the provisions of this safety manual conflict with the

provisions of the company Vehicle Policy or any other company policy, rule or regulation, the provisions of such other policy, rule or regulation shall control.

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FORK LIFT OPERATING RULES & PROCEDURES The company has adopted the OSHA rules and regulations on the following pages as the basic minimum guidelines for the safe operation of fork lifts. The key to the success of our program the use of qualified and competent drivers. The company will ensure that all operators are "qualified" or trained prior to allowing anyone to operate a fork lift. Each driver will be reviewed at least annually for their ability to perform using the fork lift safely. This will be done by utilizing a planned program of review by qualified oversight personnel within the company or to use the services of an outside agency to "Certify" our fork lift operators. 1. Both drivers and employees who work around these vehicles are required to follow

these operating rules and procedures. 2. Only authorized drivers who are trained in safe operation may operate fork lifts. 3. Do not ride on the forks of any lift truck/fork lift. 4. Passengers are not allowed on any fork lift. 5. Do not place any part of your body outside the running lines of a fork lift, or between

the mast uprights or other parts of the truck where shearing or crushing hazards exist.

6. Do no stand, pass, or work under the empty or loaded elevated portion of any

industrial truck, unless it has been blocked effectively to prevent it from falling. 7. Check the vehicle at least once each shift to ensure that the following are operating

properly: TIRES LIGHTS FUEL SYSTEM BATTERY STEERING MECHANISM CONTROLLER HORN LIFT SYSTEM BRAKES BACK-UP ALARM 8. Any vehicle in need of repair should not be used until repairs have been made. 9. Look in the direction of travel, and don't move the vehicle until you see that your

path is clear of people and objects.

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10. Do not drive toward anyone standing in front of a bench or other structure; if the vehicle fails mechanically, or you misjudge distance, that person may be trapped between your truck and the structure.

11. Do not exceed the authorized safe speed. 12. Do not pass other trucks traveling in the same direction at intersections, blind spots,

or other dangerous locations. 13. Maintain a safe distance from other vehicles. For trucks traveling in the same

direction, a safe distance would be 3 truck lengths or a 3 second time lapse passing the same point.

14. Observe all traffic regulations. 15. Slow down and sound the horn at cross aisles and other locations where vision is

obstructed. 16. Carry the forks as low as possible consistent with safe operation. 17. Cross over railroad tracks diagonally wherever possible. Do not park closer than

eight feet six inches from the center line of the railroad tracks. 18. Do not load industrial trucks in excess of their rated capacity. 19. Do not move a loaded vehicle until the load is secure. 20. If the load obstructs forward view, drive backwards. 21. Ascend or descend a grade slowly with the load upgrade. 22. Do not tilt the load with the mast extended past the center of gravity. 23. Do not drive a vehicle into any elevator unless you are specifically authorized to do

so. 24. Before entering the elevator, make sure that your vehicle and load will not exceed

the rated capacity of the elevator. Once your vehicle is on the elevator, shut the power off, and set the brakes.

25. Before you drive your vehicle on a floor, platform, or into rail cars, trucks, or trailers

be certain the structure will support the loaded vehicle. 26. When you leave the fork lift bring the mast to the vertical position, place the forks on

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USING A FORK LIFT TRUCK TO ELEVATE EMPLOYEES THE PLATFORM: Whenever a fork lift is used to elevate employees, the lift must be equipped with a "safe" work platform. The platform must be at least 24" x 24" square and it must be large enough to accommodate the employee and the material to be elevated. The platform must be securely attached to the forks and/or mast and be equipped with a standard guardrail with mid-rails on all open sides. The platform must have a slip-resistant floor and can not have spaces or holes between the floor sections larger that 1 inch in size. The side of the platform resting against the forklift mast must be equipped with a substantial covering so that an employee cannot reach into the operation of the lifting mechanism. This covering or guard must extend from the floor of the platform to a minimum of 7 feet above the workers feet. THE FORKLIFT: The fork lift must be the proper size and capacity for the intended job. The fork lift must be equipped with overhead protection wherever it is operated under conditions which expose the operator to danger from falling objects. THE OPERATOR: The operator of the fork lift must be at the control position of the lift while employees are on the elevated platform.

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OPERATING RULES WHEN ELEVATING EMPLOYEES ON FORK LIFTS 1. Use a securely attached "safety platform". 2. Make sure the lifting mechanism is operating smoothly. 3. Place the mast vertical and never tilt it forward or backward when it is elevated. 4. Place the gears in neutral and set the parking brake. 5. Lift and lower the work platform smoothly and with caution. 6. Watch for overhead obstructions. 7. Keep hands and feet clear of controls other than those controls being used. 8. Never travel with personnel on the work platform other than to make minor

adjustments for final positioning of the platform.

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EQUIPMENT INSPECTION PROGRAM PURPOSE: The company has established special guidelines for the use of special equipment including vehicles, heavy equipment, forklifts, mobile cranes, etc. Only trained and authorized employees are permitted to operate this and other large equipment. Due to the danger involved in the use and operation of heavy equipment, it is imperative that the equipment is maintained in the best condition possible. The company has established the following "equipment inspection program" to help insure that all equipment will be in working order when needed. SCOPE AND PROCEDURE: All heavy equipment shall be maintained in excellent condition at all times. Prior to using any equipment, it shall be thoroughly inspected for any defects or hazardous conditions that may impair the safe operation of the equipment. INSPECTION CHECKLIST: The following "inspection checklist" should be completed on a daily basis by the operator at the start of the shift. When making an inspection the following items shall maintained: 1. Any item shown on the list that is inspected should receive a check mark (ü)

in the box for each. 2. Any item that needs correction should be identified by placing the letter "C"

in the box. 3. Due to the potential for serious injury to the operator, any mechanical defect

should be reported immediately to the supervisor and explained in the "Comment" section below.

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EQUIPMENT INSPECTION CHECKLIST DIRECTIONS: This inspection report should be completed on a daily basis by the

operator at the start of the shift. Please place a check mark (ü) in the box for each item shown in the list below. For any item that needs correction, place the letter "C" in the box. Any mechanical defect should be reported immediately and explained in the "Comment" section below.

Daily inspection report for the WEEK OF: Equipment: Unit No. Model No. Operator:

ITEM INSPECTION DATE

MON TUE WED THU FRI SAT SUN

STEERING

FOOT BRAKE

PARKING BRAKE

TIRES/TRACK

CONTROLS

HORN (WARNING DEVICE)

CHAINS/LIMIT SWITCHES

MAST/CARRIAGE

GEARS AND DRIVES GUARDED

ATTACHMENTS

OIL AND COOLANT LEVEL

SEAT BELT (IF EQUIPPED)

HYDRAULIC SYSTEM

OTHER

OPERATOR'S INITIALS

COMMENTS:

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EXPOSURE CONTROL PROGRAM FOR EMERGENCY RESPONSE PERSONNEL I. PURPOSE The purpose of this program is for COMMERCIAL SCAFFOLD, INC. to maintain

compliance with applicable OSHA standards and requirements regarding bloodborne pathogens. Provide below is additional information regarding how the OSHA standard is now applicable as it affects Emergency Response Personnel.

II. SCOPE AND APPLICATION This program applies to all COMMERCIAL SCAFFOLD, INC. employees with

occupational exposure to blood and other potentially infectious materials as Emergency Responders. The risk of infection with bloodborne pathogens is dependent on the likelihood of exposure to blood and other potentially infectious materials wherever that exposure occurs.

EMPLOYEES AT RISK COMMERCIAL SCAFFOLD, INC. employees who are at risk from occupational

exposure to blood is limited to Emergency Response Personnel. III. DEFINITIONS Before becoming familiar with the program, there are several definitions that should

be explained which apply specifically to the COMMERCIAL SCAFFOLD, INC. program and OSHA regulation. The following definitions are included in paragraph (b) of the OSHA standard and should be clearly understood by all Emergency Response Personnel:

A. Blood - human blood, human blood components, and products made from human blood.

B. Bloodborne pathogens - pathogenic microorganisms that are present in human blood and can infect and cause disease in humans. These pathogens include but are not limited to, hepatitis B virus (HBV) and human immunodeficiency virus (HIV).

C. Contaminated - the presence or the reasonably anticipated presence of blood or other potentially infectious materials on an item or surface.

D. Exposure incident - a specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious materials that results from the performance of an employee's duties.

E. Occupational exposure - reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee's duties.

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F. Other potentially infectious materials: 1. The following human body fluids: a. semen b. vaginal secretions c. cerebrospinal fluid d. synovial fluid e. pleural fluid f. pericardial fluid g. peritoneal fluid h. amniotic fluid i. saliva in dental procedures j. any body fluid visibly contaminated with blood k. all body fluids-in situations where it is difficult or impossible to

differentiate between body fluids; 2. Any unfixed tissue or organ (other than intact skin) from a human

(living or dead); 3. HIV - containing cells or tissue cultures, organ cultures, and HIV - or

HBV - containing culture medium or other solutions: and 4. Blood, organs, or other tissue from experimental animals infected

with HIV or HBV. G. Regulated waste 1. Liquid or semi-liquid blood or other potentially infectious materials; 2. Contaminated items that would release blood or other potentially

infectious materials in a liquid or semi-liquid state if compressed; 3. Items that are caked with dried blood or other potentially infectious

materials and are capable of releasing these materials during handling;

4. Contaminated sharps; and 5. Pathological and microbiological wastes containing blood or other

potentially infectious materials. IV. EXPOSURE CONTROL A. Introduction Employees incur risk each time they are exposed to bloodborne pathogens. Any

exposure incident may result in infection and subsequent illness. Since it is possible to become infected from a single exposure incident, exposure incidents must be prevented whenever possible.

B. Exposure Control Plan To eliminate or minimize employee exposure to blood and other potentially

infectious materials, COMMERCIAL SCAFFOLD, INC. was required by OSHA to develop a written Exposure Control Plan consists of the following elements:

1. The exposure determination; 2. The schedule and method of implementing other applicable portions of this

program, i.e. methods of compliance and recordkeeping provisions; and 3. The procedures for evaluating circumstances surrounding an exposure

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V. METHODS OF COMPLIANCE There are various methods of compliance or control against exposure to

bloodborne pathogens. It is mandatory that at least one of the following methods be implemented when there is exposure or potential exposure to blood and/or other potentially infectious materials:

Universal precautions; Engineering and work practice controls; Personal protective equipment; and Housekeeping. A. Universal Precautions Universal Precautions is an approach to infection control. According to the concept

of Universal Precautions, all human blood and certain body fluids are treated as if known to be infectious for HIV, HBV, and other bloodborne pathogens. All employees must follow the COMMERCIAL SCAFFOLD, INC. written program for UNIVERSAL PRECAUTIONS as outlined in this manual.

B. Engineering Controls Engineering controls are controls that isolate or remove the bloodborne pathogens

hazard from the workplace. Examples of engineering controls that COMMERCIAL SCAFFOLD, INC. will use include the following:

1. Hand washing facilities and/or antiseptic hand cleaners readily accessible to all employees.

2. Other elements of the program may include the following as necessary: Puncture-resistant sharps containers; Mechanical needle recapping devices; Biosafety cabinets; and Mechanical pipetting devices. Engineering controls and work practice controls shall be used in preference to other

methods as good industrial hygiene practices and are compatible in adherence to traditional controls.

C. Work Practice Controls Work practice controls reduce the likelihood of exposure by altering the manner in

which a task is performed. While work practice controls act on the source of the hazard, the protection they provide is based on management and employee behavior rather than installation of a physical device such as a protective shield.

Some examples of work practice requirements for COMMERCIAL SCAFFOLD,

INC. which are included in the MEDICAL SAFETY PROGRAM are: 1. Hand washing is required when gloves are removed and as soon as

possible after contact with body fluids. 2. Personal protective equipment (PPE) is to be removed after leaving the work

area. It must be properly discarded by placing it in the appropriate container followed by hand washing.

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3. If there is an unusual situation where medical procedures require the disposal of contaminated sharps and/or recapping or removal of contaminated needles, it must be done in accordance with applicable State, Federal, or Local regulations. Otherwise:

a. Never bend or break contaminated sharps; b. Place contaminated sharps in puncture-resistant, leakproof and

labeled containers until properly reprocessed. 4. Where there is a potential for exposure to bloodborne pathogens, the

following activities are strictly prohibited and employees should: a. Never eat or drink in the area; b. Do not apply cosmetics or lip balm; and c. Do not insert or adjust contact lenses. 5. No food or drinks are to be kept in refrigerators, freezers, on counter tops, or

in storage areas where blood or potentially infectious materials may be present.

6. All procedures involving the handling or potential exposure to blood or other potentially infectious material will be performed in such a way as to minimize exposure to splashing, spraying, or related exposure.

D. Personal Protective Equipment 1. Use Personal protective equipment shall be used if occupational exposure

remains after instituting engineering and work practice controls, or if those controls are not feasible.

2. Definition Personal protective equipment is specialized clothing or equipment that is

worn by an employee for protection against hazardous exposure. General work clothes (uniforms, pants, shirts or blouses) not intended to function as protection against a hazard are not considered to be personal protective equipment.

3. Types of Personal Protective Equipment Personal protective equipment includes but is not limited to: Gloves Gowns/Coats Face shields Eye protection Mouthpieces Resuscitation devices Personal protective equipment must be selected based on the specific work

and exposure conditions that will be encountered and the anticipated level of risk.

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4. Provisions COMMERCIAL SCAFFOLD, INC. will provide and ensure that personal

protective equipment is worn by employees. Personal protective equipment will be:

a. Provided at no cost to employees; b. Accessible and in appropriate sizes for employees at the work site; c. Cleaned, repaired, replaced, and disposed of per regulation. E. Housekeeping In addition to the other compliance methods, COMMERCIAL SCAFFOLD,

INC. requires that employees maintain their work area in a clean and sanitary condition.

1. Decontamination Requirements There are several housekeeping requirements listed below that will be

implemented as part of the COMMERCIAL SCAFFOLD, INC. EXPOSURE CONTROL PROGRAM and these procedures are also required as part of the OSHA standard. Some examples include:

a. Contaminated work surfaces shall be decontaminated after completion of procedures; after any contact with blood or other infectious materials; and at the end of the work shift if the surface is contaminated;

b. All reusable containers such as bins, pails, and cans that have a likelihood of contamination shall be inspected and decontaminated on a regular basis or when visibly contaminated; and

c. Reusable items such as sharps shall be stored or processed in a way that ensures safe handling.

2. Waste Management Other requirements include procedures for handling regulated waste and

contaminated clothing (laundry). Employees should be familiar with the applicable requirements as written in the MEDICAL SAFETY GUIDELINES of the PROGRAM.

Regulated waste must be contained, handled, and discarded in a manner

which protects the employees from exposure to blood or other infectious materials. It is mandatory that these requirements and those outlined in accordance with Federal, State, or Local regulations be followed.

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VI. HEPATITIS B VACCINATION AND POST-EXPOSURE EVALUATION AND

FOLLOW-UP A. General Provisions The company 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.

COMMERCIAL SCAFFOLD, INC. shall ensure that all medical evaluations and

procedures including Hepatitis B vaccine and vaccination series and post-exposure evaluation and follow-up including prophylaxis are:

1. Made available at no cost to the employee; 2. Made available to employees at a reasonable time and place; 3. Performed by or under the supervision of a licensed physician or health care

professional; and 4. Provided according to the current recommendations of the U.S. Public

Health Service. In addition, all laboratory tests shall be conducted by an accredited laboratory at no

cost to the employee. B. Hepatitis B Vaccination As required by the OSHA regulations, the Hepatitis B vaccination shall be made

available after the employee has received the required training and within ten days of initial assignment to all employees who have occupational exposure. Availability will be made after the employee has been informed of the vaccine's affects, safety considerations, method of administration, the benefits of being vaccinated, and the "no cost" provision.

In addition to the above provisions, the following considerations will be included: 1. The vaccine will not be provided to employees who exhibit the following: a. antibody testing has revealed that the employee is immune; or b. the vaccine is contraindicated for medical reasons. 2. Pre-screening is not a prerequisite for receiving the vaccine. 3. The vaccine is available to employees who initially decline, but later decide

to accept the vaccine. 4. Employees who refuse the Hepatitis B vaccine must sign the Hepatitis B

Vaccination Declination form. 5. At minimum, booster doses recommended by the Center for Disease

Control will be offered to employees according to the guidelines noted above.

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C. Post-Exposure Evaluation and Follow-up General Provisions: A confidential medical evaluation and follow-up are to be immediately made

available to employees following an exposure incident. This is offered at no cost to the employee. Records will be maintained by the Safety Coordinator and Personnel department.

In addition the evaluation and follow-up shall include: 1. The evaluation will be provided by a licensed health care professional. 2. All laboratory tests are conducted by a accredited laboratory. 3. This evaluation is available 24 hours a day, 7 days a week. Program Goals: 1. Ensuring our employees receive medical consultation and treatment (if

required) as expeditiously as possible, 2. Investigate the circumstances surrounding the exposure incident. Program: 1. Employees will be seen immediately by the supervisor. The circumstances,

route of exposure, and identification of the "source" of exposure should be made unless unfeasible; all exposures are to be documented on required forms.

2. The employee will be referred to a licensed health care professional during working hours. On weekends, holidays or off-hours, arrangements will be made to have the employee seen by a licensed health care professional as soon as possible.

3. Laboratory testing shall be done on the "source" as soon as feasible, after consent is obtained, in order to determine HBV or HIV infectivity. If consent cannot be obtained, the company will establish that legally required consent cannot be obtained. If a "source" individual's HBV and/or HIV status is known these tests do not need to be repeated.

4. Reporting of the results of the "source" individual's testing will be made known to the exposed employee. The employee shall be informed of applicable laws and regulations concerning disclosure of the identity and infectious status of the "source".

5. Laboratory testing shall be done on the employee as soon as feasible, after consent is obtained, in order to determine HBV and HIV status.

6. If the employee consents to baseline blood collection but does not consent at that time to HIV serological testing, the blood sample shall be saved for at least 90 days. If the employee elects to have the baseline sample tested within that time frame, such testing shall be done as soon as feasible.

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7. Administration of post-exposure prophylaxis will be provided when medically indicated.

8. Counseling to include, at a minimum, information related to the HIV test universal precautions, and discussion of emotional concerns shall be provided to exposed employees.

9. Evaluation of illnesses shall be reported by the employee. Exposure Categories and Definitions: There are several factors which must be considered when identifying a "significant

exposure" that may put the health care worker at risk for disease. In each situation, it is important to identify:

* The TYPE of exposure * The LENGTH of the exposure * The length of TIME SINCE the exposure * The SOURCE of the exposure * The HEALTH of the employee, i.e., immune status The following categories are intended to provide guidance. INFECTIOUS BODY

FLUIDS INCLUDE: Semen, vaginal secretions, amniotic, peritoneal, synovial, pleural cerebra-spinal, pericardia] fluids, and any fluid containing visible blood as well as fluid where it is difficult to differentiate the source.

D. Information Provided to Healthcare Professionals COMMERCIAL SCAFFOLD, INC. will provide a healthcare professional with a

copy of the standard who is responsible for an employee's Hepatitis B vaccination. The healthcare professional who evaluates an employee after an exposure incident shall be provided with the following:

1. A copy of the Bloodborne Pathogens Standard (Federal OSHA Regulation 1910.1030, pages 64175 through 64182);

2. A description of the employee's duties relevant to the exposure incident; 3. Documentation of the route of exposure and circumstances under which the

exposure occurred; 4. Results of the source individual's blood tests, if available; and 5. All other medical records relevant to the appropriate treatment of the

employee including vaccination status.

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E. Healthcare Professional's Written Opinion Within 15 days after the evaluation is completed, COMMERCIAL SCAFFOLD,

INC. will obtain and provide the employee with a copy of the healthcare professional's written opinion.

The written opinion for the Hepatitis B vaccination will be limited to whether the

employee requires or has received the Hepatitis B vaccination. The written opinion for post-exposure evaluation and follow-up will be limited to: 1. Information that the employee has been informed of the results of the

evaluation; and 2. Information that the employee has been told about any medical conditions

resulting from exposure to blood or other potentially infectious materials that require further evaluation or treatment.

All other findings or diagnoses shall remain confidential and shall not be included

in the written report. VII. COMMUNICATION OF HAZARDS TO EMPLOYEES COMMERCIAL SCAFFOLD, INC. will use various methods to communicate and

describe the hazardous exposures to employees. This includes the use of labels, signs, and training.

The following requirements must be maintained: A. Labels Warning labels must be attached to: 1. Sharps containers (RED).

2. Containers of regulated waste;

3. Refrigerators and freezers containing blood or other potentially infectious

materials; and 4. Other containers used to store, transport, or ship blood or other potentially

infectious materials. The warning label shall be a fluorescent orange or orange-red color; it must include

the universal biohazard symbol followed by the term "BIOHAZARD" with lettering and symbols in a contrasting color.

The label shall be a part of or attached each object by string, wire, adhesive,

another method to prevent loss unintentional removal.

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These labels are not required when: 1. Red bags or red containers are used for regulated waste; and 2. Regulated waste has been decontaminated. Contaminated equipment shall also be labeled. The label shall state which portion

of the equipment remains contaminated. B. Signs The company shall post the biohazard label where applicable. This sign shall also

be fluorescent orange-red with letters or symbols in contrasting colors. C. Information and Training The COMMERCIAL SCAFFOLD, INC. Safety Coordinator will use various

methods to ensure that all employees with occupational exposure participate in an effective training program.

This training program will be provided during working hours and at no cost to

employees. The provisions of the OSHA standard on training are performance oriented and tailored to the employee's background and responsibilities. Training records will be established and maintained by the Safety Coordinator.

Educational materials will be presented in a manner that is understood by

employees. An opportunity for interactive communication, with time for questions and answers, will be provided.

Training shall be provided as follows: At the time of initial assignment to tasks where occupational exposure can occur; or

within 90 days after the effective date of the OSHA standards; and at least annually thereafter. Some elements of the training program that will be included are:

1. An accessible copy of the regulatory text and explanation of its contents; 2. An explanation of the modes of transmitting bloodborne pathogens; 3. An explanation of the epidemiology and symptoms of HBV and HIV; 4. An explanation of COMMERCIAL SCAFFOLD, INC.'s written exposure

control plan and how employees can obtain a copy; 5. An explanation of the appropriate methods on how to recognize job duties or

activities that might cause exposure; 6. An explanation of the use and limitations of engineering controls, work

practices, and personal protective equipment; 7. Information on the types, selection, proper use, location, removal, and

decontamination and disposal of personal protective equipment; 8. Information on the availability of the free Hepatitis B vaccination, vaccine

efficacy, safety, benefits, and administration;

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9. An explanation of the emergency procedures to follow if an exposure incident occurs;

10. Information and explanation on the post-exposure evaluation and follow-up procedures;

11. An explanation of signs and labels and/or color coding requirements; and 12. Provision for a question and answer session on the training. VIII. RECORDKEEPING Medical and Training records for each employee shall be maintained in the office. 1. Medical Records are part of the employee's health files and shall include: Name and social security number, HBV vaccination status (including

evaluation, report by the medical professional, and dates of all vaccinations received), and records related to reported exposure incidents, including results of examination, medical testing, follow-up health care professional's written opinion, and all information provided to the evaluating health care professional.

CONFIDENTIALITY: As with all employee medical records, the record

created and maintained must be kept strictly confidential, and must not be disclosed to anyone internally or outside the Health Plan Program without legally sufficient consent by the employee.

The medical record must be retained by the company for at least the term of

employment plus thirty years. 2. Training records: Records of each training session conducted including: The date,

summary of the content, names and job titles of attendees, and names and qualifications of the trainers, must be maintained for three years from the date of the training session, and made available for inspection and copying to employees, and authorized OSHA representatives upon request.

Copies of the employee's training is placed in the employee's personnel file. IX. Conclusion This program is provided for the benefit of all employees. Should you have any questions regarding its implementation, contact the Safety Coordinator.

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HEPATITIS B VACCINE DECLINATION (MANDATORY) I understand that due to my occupational exposure to blood or other potentially infectious materials, I may be at risk of acquiring the Hepatitis B Virus (HBV) infection. I have been given the opportunity to be vaccinated with Hepatitis B Vaccine, at no charge to me. However, I decline to receive the Hepatitis B Vaccination at this time. I understand that by declining this vaccine, I continue to be at risk of acquiring the Hepatitis B Virus, a serious disease. If in the future, I continue to have occupational exposure to blood or other potentially infectious materials and I want to be vaccinated with the Hepatitis B Vaccine, I can receive the vaccination series at no charge to me. My reason for choosing not to participate is (It is not compulsory that the above information be provided by the employee.) Signature Date

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PROCESS SAFETY MANAGEMENT PROGRAM INTRODUCTION All refineries and process plants that handle or process hazardous materials are required to implement safety measures that will ensure the safe operation of the facility for the workers, as well as the public. All contractors working in these facilities are required to have implemented their own safety program, plus have been trained in the safety measures that affect the work that they may be doing in a PSM environment. Several industrial incidents at major process facilities, including the explosion and release of toxic material that killed 20,000 people in India in 1985, have heightened awareness concerning the potential for catastrophic accidents in the petrochemical industries. Those accidents promulgated regulatory agencies to request the industry to assist in putting together a plan to ensure a safe work environment for all employees. The principle organization responsible for regulating process safety is the Occupational Safety and Health Administration (OSHA as well as CAL/OSHA) who issued a Standard and Health Administration (OSHA) who has issued a Standard under 29 CFR 1910.119, "Process Safety Management of Highly Hazardous Chemicals" otherwise known as the PSM requirements. This Standard became Law on May 28, 1992. There are other regulatory agencies directly or indirectly affecting PSM. Among these are: • SARA Title III (Community Right-to-know and Emergency Planning) • The Clean Air Act • Resource Conservation and Recover Act (RCRA) The standard is broad in scope and covers process design, process technology, operational and maintenance activities and procedures, non-routine activities and procedures, training programs and all other elements that affect process. Most importantly, the standard affects contractors working on plant sites. The following subjects are part of these requirements: • Process safety information • Hot work permits • Process hazards analysis • Management of change • Operating procedures • Pre-startup reviews • Training (operator and contractor) • Incident investigation • Emergency planning and response • Contractor Safety Program • Mechanical integrity • Compliance audits

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The PSM standard clarifies the responsibilities of both the client and the contractor involved in work affecting regulated processes. The Standard also mandates employee participation in the PSM programs, written operating procedures, employee training, pre-startup review, maintenance of the mechanical integrity of control equipment, and written procedures for managing change. In addition, the Standard requires a permit system for hot work, investigation of incidents, near misses, emergency action plans ,compliance audits and trade secret protection. COMMERCIAL SCAFFOLD, INC. Management and employees must understand the inherent hazards associated with process systems containing highly hazardous chemicals. COMMERCIAL SCAFFOLD, INC. will ensure that employees assigned to work on process facilities are qualified in their crafts and are fully trained in all aspects of safety. Implementation of COMMERCIAL SCAFFOLD, INC.'s "Process Safety Management Program" will begin by requesting the client to submit all pertinent information required by the standard to conduct work safely. GENERAL The following procedure is written to comply with 29 CFR 1910.119 (Process Safety Management of Highly Hazardous Chemicals and applicable CAL/OSHA standard), and will be adhered to by all COMMERCIAL SCAFFOLD, INC. employees working in process facilities where this safety standard applies. In the event that requirements of the client differ from this procedure, the most stringent of the two will take precedence. COMMERCIAL SCAFFOLD, INC. employees will understand and comply with these written procedures that dictate safe working practices in order to minimize or prevent catastrophic results inherent from hazardous environments associated with process plants. Employees disregarding these written procedures are subject to disciplinary action up to and including termination. 1. Responsibilities: a. Client: The Client is responsible for providing COMMERCIAL SCAFFOLD, INC.

with all data pertaining to any or all technological processes where work is to be performed. Information will include but not be limited to flow diagrams, back flow diagrams, toxicity information, corrosive data, chemical stability and all potential hazards involved.

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The Client will further provide information on all equipment used in the process, a

Process Hazard Analysis (PHA) if appropriate, all temporary changes to the process system and an emergency action plan for the facility.

b. COMMERCIAL SCAFFOLD, INC. Project Management: COMMERCIAL SCAFFOLD, INC. will receive and study all information

provided by the client in order to have a complete understanding of the highly hazardous chemical used in the process system. This will ensure the planning of work covers all aspects of safety procedures for chemicals that are detrimental to the health and safety of all COMMERCIAL SCAFFOLD, INC. employees. This information will then be reviewed we all affected employees. The information will consist of, but not be limited to the following:

• Chemical Toxicity Information • Permissible Exposure Limits (PEL) of Chemicals • A Chemicals Physical Data, Reactivity Data, Corrosive Data • Thermal or Chemical Stability • Hazardous effects of inadvertent mixing of chemicals c. COMMERCIAL SCAFFOLD, INC. Safety Coordinator: The Safety Coordinator will assist project management in the planning

phase and obtain all Material Safety Data Sheets regarding chemicals, and other materials used on the project to prepare a Hazardous Communications Program (Right to Know) in accordance with 29 CFR 1910.1200 and CAL/OSHA Section 5194.

The Safety Coordinator will analyze information provided, note all existing

potential hazards, have all safety and personal protective equipment available and conduct orientation/training classes for all employees in order to provide a safe working environment.

2. Employee Responsibilities All employees will be required to take the appropriate substance abuse test that

complies with COMMERCIAL SCAFFOLD, INC.'s and/or the client's requirements prior to start of work.

All employees will be trained in this PSM Program and anyone required by the

client as appropriate.

3. Supervisor's Responsibilities Supervisors are responsible to test all employees to find their level of training and

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Supervisors will assign helpers to experienced foreman/craftsmen to enhance the employee's knowledge and gain experience in their craft and ensure they follow safe work practices.

Supervisors will not allow an employee to work in a facility for which he/she has no

knowledge or training. Supervisors are responsible to train employees assigned to new work areas in a

facility to assure that they all have the knowledge and skills to conduct the work safely. Upon completion, the training will be logged on the safety training log that notes the process system, type of work to be performed, date/time of training and signature of trainer. Copies of this form will be placed in the individual's personnel file.

If a Supervisor has the knowledge of an employees' experience in process units

and feels confident that they fully understand the procedures, he may, in lieu of training, certify in writing that the individuals have the knowledge and skills to safely carry out the work in accordance with the established procedures.

A copy of any and all test results will be maintained in the employee's file on the

project. Original copy of test results will be sent to the office and placed in the employee's training/personnel file.

4. Sequence of Process Management Program a. Employee training: COMMERCIAL SCAFFOLD, INC.'s Commitment to

Safe Construction All employees will receive a safety orientation from the Safety Coordinator

as found in COMMERCIAL SCAFFOLD, INC.'s Safety Manual. The following subjects are to be included:

• Plant Emergency signals • Plant Emergency telephone numbers • Evacuation routes/Assembly areas • Smoking rules • Traffic rules • Use of vehicles in process plants • Reporting hazards • Work permits • Trenching & Excavating • Shielding of welding operations • Highly hazardous chemicals/gases/materials

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If the work requires, selected employees will receive the following additional

training: • Fire Watch training • Cascade System/SCBA (Supplied Air Training) • Rescue • Competent Person (Trenching & Excavating) • HAZWOPER Only employees that have completed the initial safety orientation and the

training in highly hazardous chemicals/gases/materials that have the potential to cause fires, explosions or toxic releases, may be allowed access to work areas. The Safety Coordinator will submit the list of trained employees to the client.

The Safety Coordinator will maintain a master list of all persons that received

the training including the date it was conducted. All employees will be receive retraining in the PSM standard annually as required by Federal and State Regulations.

Employees who are new to the company will be given additional training as

required to ensure they understand safe working practices in a process environment.

Individual state or client requirements may be used in place of any federal

standard providing that they meet or exceed the minimum requirements of the federal regulation.

5. Construction Operations a. The Project Coordinator will submit work permits to the client operations

personnel for approval. b. Prior to commencing work, COMMERCIAL SCAFFOLD, INC. supervisors

will coordinate with client operations personnel to make a Job Safety Analysis (JSA) of the work to be performed, if requested. Supervisors will follow the four basic steps in completing the JSA.

• Select the job

• Separate job into basic steps

• Identify the hazards

• Control each hazard

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Utilizing the information on the JSA Worksheet, supervisors will brief their

employees on the sequence of the operation, potential accidents, all known hazards, and safety procedures prior to starting any work.

6. Incident Reporting All COMMERCIAL SCAFFOLD, INC. employees will report all potential hazards

observed on the jobsite to their supervisor. The supervisor will immediately inform the COMMERCIAL SCAFFOLD, INC. Project Safety Coordinator.

In the event a hazard will or could become detrimental to the safety of the workers,

all employees will immediately evacuate the work are and report the hazard to the client operations personnel and the COMMERCIAL SCAFFOLD, INC. Project Safety Coordinator.

In the event of a fire or explosion, all fire watch personnel will attempt to control the

fire until help arrives. If the fire is uncontrollable all personnel will immediately evacuate the area. COMMERCIAL SCAFFOLD, INC. employees will not place themselves or co-workers in jeopardy.

COMMERCIAL SCAFFOLD, INC. employees will not engage in hazardous waste

response operations unless they are trained and qualified under 29 CFR 1910.120. 7. "Near miss" accidents (Near Accident Reporting): COMMERCIAL SCAFFOLD, INC. employees will regard all "near accidents" as if

they actually caused bodily injury or damage to equipment and will be reported on an accident report form.

An accident investigation review will be held as soon as possible to determine the

cause and methods to prevent future occurrences. Accident investigation and reporting will be conducted in accordance with procedures found in the COMMERCIAL SCAFFOLD, INC. Safety Manual.

The following COMMERCIAL SCAFFOLD, INC. employees will attend this

meeting:

• Project Coordinator

• Project Safety Representative

• Superintendent

• Foreman

• Employees involved

• Witnesses

• Client Representative 237


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A verbal report followed by a written report of all incidents/accidents will be

submitted to the client safety officer and copies maintained on file with the COMMERCIAL SCAFFOLD, INC. Project Safety Coordinator.

8. Work Permits COMMERCIAL SCAFFOLD, INC. will comply with applicable work permits as

required by the client and the Process Safety Management Standard (29 CFR 1910.119, para. K), that may be issued by the client. Permits such as the General Work Permit, Hot Work Permit, Confined Space Entry Permit, and Lock out/Tag out are intended to document fire protection requirements, indicate the authorized date(s), identify the process and object to be worked on, and the need (if any) for Personnel Protective Equipment (PPE) to be worn.

9. Mechanical Integrity/Quality Assurance COMMERCIAL SCAFFOLD, INC. will comply with client procedures in all aspects

of testing and inspections on all work related to process. COMMERCIAL SCAFFOLD, INC. will assure all fabrications and equipment used are suitable for process application, and that they are installed properly and consistent with design specifications. All test and inspections shall be documented.

10. Trade Secrets Process flow and block diagrams are required to be made available to the

contractor in accordance with this standard. The information may be considered a trade secret by the client. In cases where this information is secret, COMMERCIAL SCAFFOLD, INC. management will sign appropriate confidentiality agreement prior to the receipt of the information.

11. Safety Audits Project management must be prepared for unannounced safety audits by

Federal or State regulatory agencies as well as by the client's safety management team. The Process Safety Management standard requires the facility to make periodic audits of the all contractors working in their facility.

The COMMERCIAL SCAFFOLD, INC. Safety Coordinator will conduct a monthly

safety audit and periodic unannounced inspections of the project in order to monitor compliance with the company's safety program and the requirements of the PSM. A copy of all audits will be left with both the Project Safety Representative and the Project Management.

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The COMMERCIAL SCAFFOLD, INC. Safety Coordinator will assure that all

requirements of the COMMERCIAL SCAFFOLD, INC. Safety Program are in compliance including the following records as may be applicable:

• Training records on all assigned employees

• Respirator training records

• Hazardous communications program (MSDS)

• Air monitoring logs

• Crane inspection forms

• Rigging inspection forms

• First aid logs

• OSHA 200 and accident reports

• Weekly safety meeting reports

• Master list of all training conducted All required tests given to employees will be filed in their personnel file.

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CONTRACTOR SAFETY RESPONSIBILITIES PURPOSE: It is the Policy of COMMERCIAL SCAFFOLD, INC. to establish healthy and safe working conditions for all Contractors while performing services. This Policy is in keeping with Federal and State Environment Health and Safety Regulations and other sections of COMMERCIAL SCAFFOLD, INC.'s Safety Policies and Procedures Manual. RESPONSIBILITIES: A. Safety Coordinator: The Safety Coordinator is responsible for the development and maintenance of this

policy and is responsible for the implementation of this policy. The Safety Coordinator will ensure that Project Management is aware of this policy to inform all COMMERCIAL SCAFFOLD, INC. Contractors of its provisions.

B. Project Management: Project Management is responsible for providing this policy to Contractor's

especially those rendering field services. They are responsible for providing assistance and guidance to contracted personnel to ensure compliance with COMMERCIAL SCAFFOLD, INC.'s Health and Safety Policy and Procedure requirements.

Project Management and the Safety Coordinator are responsible for auditing

Contractor's operation where potential hazards exist to ensure that the operation is performed in the most safe standards.

C. Contractors: Each Contractor is responsible for complying with this policy and all provisions of

Federal and State Environmental Health and Safety regulations and applicable standards.

The Contractor is responsible for designating a Health and Safety representative,

who will serve as a Site Safety representative for his employees. COMMERCIAL SCAFFOLD, INC. will designate its own Site Safety Rep.

The Contractor is responsible for all subcontract issues. D. Site Safety Representative: On large projects, a Site Safety Representative is responsible for ensuring that all

persons assigned to work involving hazardous material or operations have appropriate medical surveillance and training.

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PROCEDURE: A. General Each Contractor must use good professional judgement while performing services

for COMMERCIAL SCAFFOLD, INC.. The Contractor will be required to show proof of workers' compensation and public

liability and property damage insurance coverage. B. Field Operations Personal Protective Equipment must be provided by the Contractor for use by the

Contractor's personnel only. The proper use and maintenance of such equipment is the responsibility of the Contractor. COMMERCIAL SCAFFOLD, INC. does not supply Contractors PPE.

Contractors especially those rendering field services, must provide COMMERCIAL

SCAFFOLD, INC. with the name and title of the health and safety representative designated by the Contractor.

Contractors are required to have adequate training for field operations and

participate in a Medical Surveillance Program, as required by Title 8, 5192. Contractors must supply personnel with respiratory protection and comply.

COMMERCIAL SCAFFOLD, INC. takes no responsibility for respiratory protective equipment malfunctions, damage, misuse or otherwise.

If the project site requires a Site Safety and Health Plan, the Contractor is required

to provide COMMERCIAL SCAFFOLD, INC. a copy of that plan for review and approval by the Safety Coordinator, unless such plan will be provided by COMMERCIAL SCAFFOLD, INC. under agreement prior to site entry.

C. Violations or Misconduct of Contractors Violations to COMMERCIAL SCAFFOLD, INC.'s Policy and Procedures and/or

state and federal regulations must be reported to the Contractor's safety representative, who in turn must report the violation to Project Management, or the Safety Coordinator. Project Management will consult with the General Management and decide the course of action.

In any situations presenting "imminent danger" to the health or safety of personnel

or loss of property, the Site Safety Representative has authority to issue a stop work order.

Field activities may be modified to resolve violation or rectify condition which led to

issuance of a stop work order, but must be approved by the Site Safety Representative. If a discrepancy occurs regarding modifications of field activities, the Project Management must be consulted.

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D. Accidents/Incidents All accidents/incidents involving Contractor personnel must be promptly reported. The Contractor and COMMERCIAL SCAFFOLD, INC. Project Management are

responsible for completing Accident/Incident Reports and informing the Safety Coordinator.

TRAINING REQUIREMENTS: All Contractors must have adequate training to comply with Federal and State requirements which include, but are not limited to those appropriate for the work site. SUBCONTRACTOR HEALTH AND SAFETY GENERAL 1. Each Subcontractor shall be directly responsible for preventing their employees

from working under conditions which are unsafe, unhealthy or unsanitary. Their compliance with the Occupational Safety and Health Act, the Mine Safety and Health Act (MSHA) and our Project Safety Program is mandatory. Disregard of accepted health, safety and fire protection standards will not be tolerated.

2. Subcontractors shall prohibit the use of unsafe machinery, tools, materials or

equipment. 3. Subcontractors shall permit only qualified employees, by training or experience, to

operate equipment and machinery. 4. Subcontractors shall instruct employees in the recognition and avoidance of unsafe

conditions and the regulations applicable to their work environment. 5. Subcontractors shall instruct employees required to handle or use flammable

liquids, gases, toxic materials, poisons, caustics and other harmful substances in their safe handling and use. Employees shall be made aware of the potential hazards, the necessary personal hygiene and the personal protective measures required.

6. Subcontractors shall instruct employees required to enter confined or enclosed

spaces as to the nature of the hazards involved, the necessary precautions to be taken and in the proper use of protective and emergency equipment required.

7. Subcontractors shall have material safety data sheets (MSDS) on those materials

brought on the project that require them. Subcontractors shall provide a copy of the project manager.

8. Subcontractors shall have weekly safety meetings and provide a copy of the

meeting record to the project manager.

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CONTRACTOR SAFETY QUESTIONNAIRE YOUR FIRM'S SAFETY PERFORMANCE AND PROGRAM Workers Compensation Insurance - Experience Modification Rate (EMR) 1. Please obtain from your insurance agent (or state fund, if applicable) your interstate EMR's

for the last three rating periods. If you do not have an interstate rating, obtain your intrastate (California, if based in Calif.) EMR's. Then complete the following data:

Policy Year Modification Rate Most Recent Policy Year 1 year previously 2 years previously a. Are the above rates: interstate [ ] or intrastate [ ]? State? b. If your EMR is exactly 1.0 (100%) for any policy year, is it because your firm is (or was)

too new or too small to have an EMR calculated? [ ] Yes [ ] No c. Is your firm self-insured for Workers Compensation claims? [ ] Yes [ ] No We require back-up for the above information. Any of the following methods would

be acceptable: a. Furnish a letter from your insurance agent, insurance carrier, or State Fund (on their

letterhead) verifying the EMR data listed above; or b. Furnish a photostat of the last three years' Experience Rating Calculation Sheets, which

your insurance carrier should forward annually; or c. Furnish a photostat of the page of your last three years' insurance policies that shows

the modification rate and the coverage period; or d. If you're in a "state fund" state, such as Ohio or West Virginia, furnish a photostat of the

state's last three years' annual statement page that shows the modification rate and the coverage period.

OSHA/Lost Workday Incident Rates 1. Total employee hours worked last year: 2. What is your company wide OSHA Recordable Incidence Rate* for the last three years? OSHA Recordable I.R. Last Year - 19 1 Year Previous - 19 2 Year Previous - 19 3. What is your company wide Lost Workday Incidence Rate** for the last three years? Lost Workday I.R. Last Year - 19 1 Year Previous - 19 2 Year Previous - 19 * OSHA Recordable Incidence Rate = # Recordable Injuries X 200,000 Company or Site Man-hours ** Lost workday incidence Rate = # Lost Workday Cases X 200,000 Company or Site Man-hours Industry Comparison Information What Standard Industry Classification (SIC) Code does your company work under?

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WORKPLACE SECURITY PREVENTING VIOLENCE IN THE WORKPLACE

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INTRODUCTION PREVENTING VIOLENCE IN THE WORKPLACE The circumstances associated with workplace violence in California can be divided into three major types. However, it is important to keep in mind that a particular occupation or workplace may be subject to more than one type. Type I - In California, the majority of fatal workplace assaults involve a person entering a small late-night retail establishment, e.g., liquor store, gas station or a convenience food store, to commit a robbery. During the commission of the robbery, an employee, or more likely, the proprietor, is killed or injured. Employees or proprietors who have face-to-face contact and exchange money with the public, who work late at night and into the early morning hours, and who often work alone or in very small numbers are at greatest risk of a Type I event. While the assailant may imitate being a customer as a pretext to enter the establishment, he or she has no legitimate relationship to the workplace. Retails robberies resulting in workplace assaults usually occur between late night and early morning hours and are most often armed robberies. In addition to employees who are classified as cashiers, many victims of late night retail violence are supervisors or proprietors who are attacked while locking up their establishment for the night or janitors who are assaulted while cleaning the establishment after it is closed. Other occupations/workplaces may be at risk of a Type I event. For instance, assaults on taxicab drivers also involve a pattern similar to retail robberies. The attack is likely to involve an assailant pretending to be a bona fide passenger during the late night or early morning hours who enters the taxicab to rob the driver of his or her fare receipts. Type I events also involve assaults on security guards. It have been known for sometime that security guards are at risk of assault when protecting valuable property that is the object of an armed robbery. Type II - A Type II workplace violence event involves an assault or threat by someone who is either the recipient or the object of a service provided by the affected workplace or the victim. Type II events involve fatal or nonfatal injuries to individuals who provide service to the public. These events chiefly involve assaults on public safety and correctional personnel municipal bus or railway drivers, health care and social service providers, teachers, sales personnel, and other public or private service sector employees who provide professional, public safety, administrative or business services to the public.

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Law enforcement personnel are at risk of assault from the "object" of public safety services (suspicious persons, detainees, or arrestees) when making arrests, conducting drug raids, responding to calls involving robberies or domestic disputes, serving warrants and eviction notices and investigating suspicious vehicles. Similarly, correctional personnel are at risk of assault while guarding and transporting jail or prison inmates. Of increasing concern, though, are Type II events involving assaults to the following types of service providers: (1) Medical care providers in acute care hospitals, long-term care facilities, outpatient

clinics and home health agencies; (2) Mental health and psychiatric care providers in inpatients facilities, outpatient

clinics, residential sites and home health agencies; (3) Alcohol and drug treatment providers; (4) Social welfare providers in unemployment offices, welfare eligibility offices,

homeless shelters, probation offices and child welfare agencies; (5) Teaching, administrative and support staff in schools where students have a history

of violent behavior; and (6) Other types of service providers, e.g., justice system personnel, customer service

representatives and delivery personnel. Unlike Type I events which often represent irregular occurrences in the life of any particular at-risk establishment, Type II events occur on a daily basis in many service establishments, and therefore represent a more pervasive risk for many service providers. Type III - A Type III workplace violence event consists of an assault by an individual who has some employment-related involvement with the workplace. A Type III event usually involves a threat of violence, or a physical act of violence resulting in a fatal or nonfatal injury, by a current or former employee, supervisor or manager; a current or former spouse or lover; a relative or friend; or some other person who has a dispute involving an employee of the workplace. Available data indicates that a Type III event is not associated with a specific type of workplace or occupation. Any workplace can be at risk of a Type III event. However, Type III events account for a much smaller proportion of fatal workplace injuries than Types I and II. Nevertheless, Type III fatalities often attract significant media attention and are perceived as much more common than they actually are.

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INJURY AND ILLNESS PREVENTION PROGRAM FOR WORKPLACE SECURITY Our establishment's IIP Program for Workplace Security addresses the hazards known to be associated with the three major types of workplace violence. Type I workplace violence involves a violent act by an assailant with no legitimate relationship to the workplace who enters the workplace to commit a robbery or other criminal act. Type II involves a violent act or threat of violence by a recipient of a service provided by our establishment, such as a client, patient, customer, passenger or a criminal suspect or prisoner. Type III involves a violent act or threat of violence by a current or former employee, supervisor or manager, or another person who has some employment-related involvement with our establishment, such as an employee's spouse or lover, an employee's relative or friend, or another person who has a dispute with one of our employees.

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RESPONSIBILITY

We have decided to assign responsibility for security in our workplace. The IIP Program administrator for workplace security is ___________________________________ and has the authority and responsibility for implementing the provisions of this program for ______________________________________________________________________________________________________________________________________________ All managers and supervisors are responsible for implementing and maintaining the IIP Program in their work areas and for answering employee questions about the IIP Program. A copy of this IIP Program is available from each manager and supervisor. COMPLIANCE We have established the following policy to ensure compliance with our rules on workplace security. Management of our establishment is committed to ensuring that all safety and health policies and procedures involving workplace security are clearly communicated and understood by a employees. All employees are responsible for using safe work practices, for following all directives, policies and procedures, and for assisting in maintaining a safe and secure work environment. Our system of ensuring that all employees, including supervisors and managers, comply with work practices that are designed to make the workplace more secure, and do not engage in threats or physical actions which create a security hazard for others in the workplace, include: 1. Informing employees, supervisors and managers of the provisions of our IIP

Program for Workplace Security. 2. Evaluating the performance of all employees in complying with our establishment's

workplace security measures. 3. Recognizing employees who perform work practices which promote security in the

workplace. 4. Providing training and/or counseling to employees whose performance is deficient

in complying with work practices designed to ensure workplace security. 5. Disciplining employees for failure to comply with workplace security practices. 6. The following practices that ensure employee compliance with workplace security

directives, policies and procedures: __________________________________________________________________

____________________________________________________________________________________________________________________________________

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COMMUNICATION At our establishment, we recognize that to maintain a safe, healthy and secure workplace we must have open, two-way communication between all employees, including managers and supervisors, 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 checked items: ¨ New employee orientation on our establishment's workplace security policies,

procedures and work practices. ¨ Periodic review of our IIP Program for Workplace Security 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. ¨ Addressing security issues at our workplace security team meetings. ¨ Our establishment has fewer than ten employees and communicates with and

instructs employees orally about general safe work practices with respect to work place security.

¨ Other:_______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

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HAZARD ASSESSMENT We will be performing workplace hazard assessment for workplace security in the form of periodic inspections. Periodic inspections to identify and evaluate workplace security hazards and threats of workplace violence are performed by the following observer(s) in the following areas of our workplace: Observer Area Periodic inspections are performed according to the following schedule: 1. __________________________________ (Frequency = daily, weekly, month,

etc.); 2. When we initially established our IIP Program for Workplace Security; 3. When new, previously unidentified security hazards are recognized; 4. When occupational injuries or threats of injury occur; and 5. Whenever workplace security conditions warrant an inspection. Periodic inspections for security hazards consist of identification and evaluation of workplace security hazards and changes in employee work practices, and may require assessing for more than one type of workplace violence by using the methods specified below to identify and evaluate workplace security hazards. Inspections for Type I workplace security hazards include assessing: 1. The exterior and interior of the workplace for its attractiveness to robbers. 2. The need for security surveillance measures, such as mirrors or cameras. 3. Posting of signs notifying the public that limited cash is kept on the premises. 4. Procedures for employee response during a robbery or other criminal act. 5. Procedures for reporting suspicious persons or activities. 6. Posting of emergency telephone numbers for law enforcement, fire and medical

services where employees have access to a telephone with an outside line. 7. Limiting the amount of cash on hand and using time access safes for large bills. 8.

Other:_______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

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INCIDENT INVESTIGATIONS We have established the following policy for investigating incidents of workplace violence. Our procedures for investigating incidents of workplace violence, which includes threats and physical injury, include: 1. Reviewing all previous incidents. 2. Visiting the scene of an incident as soon as possible. 3. Interviewing threatened or injured employees and witnesses. 4. Examining the workplace for security risk factors associated with the incident,

including any previous reports of inappropriate behavior by the perpetrator. 5. Determining the cause of the incident. 6. Taking corrective action to prevent the incident from recurring. 7. Recording the findings and corrective actions taken. 8.

Other:_____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

HAZARD CORRECTION Hazards which threaten the security of employees shall be corrected in a timely manner based on severity when they are first observed or discovered. Corrective measures for Type I workplace security hazards can include: 1. Making the workplace unattractive to robbers. 2. Utilizing surveillance measures, such as cameras or mirrors, to provide information

as to what is going on outside and inside the workplace. 3. Procedures for the reporting suspicious persons or activities. 4. Posting of emergency telephone numbers of law enforcement, fire and medical

services where employees have access to a telephone with an outside line. 5. Posting of signs notifying the public that limited cash is kept on the premises. 6. Limiting the amount of cash on hand and using time access safes for large bills. 7. Employee, supervisor and management training on emergency action procedures. 8.

Other:_____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

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HAZARD CORRECTION (Continued)

Corrective measures for Type II workplace security hazards include: 1. Controlling access to the workplace and freedom of movement within it, consistent

with business necessity. 2. Ensuring the adequacy of workplace security systems, such as door locks, security

windows, physical barriers and restraint systems. 3. Providing employee training in recognizing and handling threatening or hostile

situations that may lead to violent acts by persons who are service recipients of our establishment.

4. Placing effective systems to warn others of a security danger or to summon assistance, e.g., alarms or panic buttons.

5. Providing procedures for a "buddy" system for specified emergency events. 6. Ensuring adequate employee escape routes. 7.

Other:_____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Corrective measures for Type III workplace security hazards include: 1. Effectively communicating our establishment's anti-violence policy to all employees,

supervisors or managers. 2. Improving how well our company's management and employees communicate with

each other. 3. Increasing awareness by employees, supervisors and managers of the warning

signs of potential workplace violence. 4. Controlling access to, and freedom of movement within, the workplace by non-

employees, including recently discharged employees or persons with whom one of our employee's is having a dispute.

5. Providing counseling to employees, supervisors or managers who exhibit behavior that represents strain or pressure which may lead to physical or verbal abuse of co-employees.

6. Ensure that all reports of violent acts, threats of physical violence, verbal abuse, property damage or other signs of strain or pressure in the workplace are handled effectively by management and that the person making the report is not subject to retaliation by the person making the threat.

7. Ensure that employee disciplinary and discharge procedures address the potential for workplace violence.

8. Other:_____________________________________________________________ __________________________________________________________________ __________________________________________________________________

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TRAINING AND INSTRUCTION We have established the following policy on training all employees with respect to workplace security. All employees, including managers and supervisors, shall have training and instruction on general and job-specific workplace security practices. Training and instruction shall be provided when the IIP Program for Workplace Security is first established and periodically thereafter. Training shall also be provided to all new employees and to other employees for whom training has not previously been provided and to all employees, supervisors and managers given new job assignments for which specific workplace security training for that job assignment has not previously been provided. Additional training and instruction will be provided to all personnel whenever the employer is made aware of new of previously unrecognized security hazards. General workplace security training and instruction includes, but is not limited to, the following: 1. Explanation of the IIP Program for Workplace Security including measures

for reporting any violent acts or threats of violence. 2. Recognition of workplace security hazards including the risk factors

associated with the three types of workplace violence. 3. Measures to prevent workplace violence, including procedures for reporting

workplace security hazards or threats to managers and supervisors. 4. Ways to defuse hostile or threatening situations. 5. Measures to summon others for assistance. 6. Employee routes of escape. 7. Notification of law enforcement authorities when a criminal act may have

occurred. 8. Emergency medical care provided in the event of any violent act upon an

employee; and 9. Post-event trauma counseling for those employees desiring such

assistance. In addition, we provide specific instructions to all employees regarding workplace security hazards unique to their job assignment, to the extent that such information was not already covered in other training.

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TRAINING AND INSTRUCTION (Continued) We have chosen the following checked items for Type I training and instruction for managers, supervisors and employees: ¨ Crime awareness. ¨ Location and operation of alarm systems. ¨ Communication procedures. ¨ Proper work practices for specific workplace activities, occupations or assignments,

such as late night retail sales, taxi-cab driver, or security guard. ¨

Other:_____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

We have chosen the following checked items for Type II training and instruction for managers, supervisors and employees: ¨ Self-protection. ¨ Dealing with angry, hostile or threatening individuals. ¨ Location, operation, care, and maintenance of alarm systems and other protective

devices. ¨ Communication procedures. ¨ Determination of when to use the "buddy" system or other assistance from co-

employees. ¨ Awareness of indicators that lead to violent acts by service recipients. ¨

Other:___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

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We have chosen the following checked items for Type III training and instruction for managers, supervisors and employees: ¨ Pre-employment screening practices. ¨ Employee Assistance Programs. ¨ Awareness of situational indicators that lead to violent acts. ¨ Managing with respect and consideration for employee well-being. ¨ Review of anti-violence policy and procedures. ¨

Other:___________________________________________________________________________________________________________________________________________________________________________________________

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