CORPORATE SAFETY MANUAL
The Elliott-Lewis Safety Manual
THE CORPORATE SAFETY PROGRAM
TO ALL EMPLOYEES:
As a member of our organization, you automatically accept a moral obligation to your fellow employees and an economic obligation to the company to see that operations under your care, custody, and control are carried out in an efficient and safe manner.
Along with other responsibilities, safety consciousness must always exist in your thinking and planning. Because of this obligation, you must not only prevent obvious unsafe acts on the part of those you work with, but you must anticipate potential hazards. After an accident occurs, it is too late to prevent it. All employees must recognize that working in an unsafe manner is counter-productive. Most important, each employee is encouraged to demonstrate leadership ability by setting a good example.
To make our approach to safety more effective and uniform throughout our organization, you are receiving this manual, outlining and formalizing our Corporate Safety Program. We feel this will be a useful tool to help in understanding and discharging our mutual responsibilities.
William R. Sautter CEO, Elliott-Lewis Corporation
WRS/jtm
An Equal Opportunity Employer
REV2.1 February 13, 2018 Page 2 | 165 The Elliott-Lewis Safety Manual POLICY STATEMENT
It is the policy of ELLIOTT-LEWIS CORPORATION to strive for the highest safety standards in all our operations. Safety does not occur by chance; it is the direct result of careful attention to all company operations by those who are directly and indirectly involved. Employees at all levels must work diligently to execute the company's policy of maintaining safety and occupational health.
Our Safety Program has been developed to assure compliance with Federal, State, and Local regulations with particular emphasis on the Occupational Safety and Health Act of 1970 (OSHA), and the OSHA requirements that apply to our operations. It is the obligation of all employees to be knowledgeable of the standards established by these agencies and to implement the rules and regulations contained therein on the projects under their direction.
Regard for the safety of the general public, our own employees, and the employees of our subcontractors is a supreme responsibility of all levels of our organization. We intend to prevent any human suffering. Accidents, even minor ones, cause pain, both physical and mental. Prevention of injury and illness is a goal worthy of our achieving.
A safe operation is organized, clean, and efficient. If every employee views accidents in the same way we consider all other aspects of our operations, we will be in a better position not only to control accidents but also to improve the total performance of our company. It is, therefore, of utmost importance that all aspects of our Safety Program be strictly adhered to and that the intent of this program be followed to the letter. Any recommendations to improve our Safety Program are encouraged.
William Schwartz Safety Director Elliott-Lewis Corporation An Equal Opportunity Employer
REV2.1 February 13, 2018 Page 3 | 165 The Elliott-Lewis Safety Manual Table of Contents 1 Objectives ...... 12 1.1 General...... 12 1.2 Definitions ...... 14 1.3 References ...... 15 1.4 Organization and Responsibilities ...... 15 2 Project First Aid and Safety Services ...... 18 2.1 First Aid ...... 18 2.2 Safety Services ...... 18 2.3 Care and Transportation of Injured Employees ...... 19 3 Accident Reporting and Investigating ...... 19 3.1 General...... 19 3.2 Incident Report Form ...... 20 3.3 Treatment Authorization Form ...... 21 3.4 Benefit Changes ...... 22 3.5 Medical Changes ...... 23 3.6 Employee’s Rights & Duties Under Section 306(f.1) of the Pennsylvania Worker’s Compensation Act ...... 23 3.7 Acknowledgement of Rights and Duties ...... 24 3.8 PENNSYLVANIA WORKER’S COMPENSATION - DOCTOR'S PANEL ...... 25 3.10 Return to Work Policy ...... 26 3.11 Return to Work/Job ...... 27 4 Record-Keeping and Posting Requirements ...... 28 4.1 Injury Log ...... 28 4.2 OSHA 300 Log...... 28 4.3 Incident Report Form ...... 29 4.4 Report of Injury to Insurance Company / First Report of Injury ...... 29 4.5 Safety Records and Documentation ...... 29 5 Employee Disciplinary Warnings...... 31 5.1 General...... 31 5.2 Enforcement Guidelines ...... 31 5.3 Minor Violations ...... 32 6 Substance Abuse Policy ...... 33 7 DOT Drug and Alcohol Policy ...... 34 7.1 Requirements and Responsibilities...... 34 7.2 Definitions ...... 34 7.3 Alcohol and Drugs ...... 37 REV2.1 February 13, 2018 Page 4 | 165 The Elliott-Lewis Safety Manual 7.4 Circumstances for testing ...... 38 7.5 Fit for Duty ...... 39 8 Safety Training and Employee Education ...... 40 8.1 Employee New-Hire Orientation ...... 40 8.2 Foreman Orientation ...... 40 8.3 Project Safety Meeting ...... 41 8.4 Superintendent Training ...... 41 8.5 Right to Know/Hazardous Substances and GHS Training ...... 41 8.6 Special Operations Training ...... 41 8.7 Short Service Employees ...... 42 8.8 Behavior Based Safety ...... 42 9 Jobsite Inspections ...... 44 9.1 Self-Inspection Program ...... 44 9.2 Safety Audits ...... 45 9.3 OSHA Inspections ...... 45 9.4 Risk Assessment/Job Hazard Analysis ...... 46 10 Personal Protective Equipment ...... 47 10.1 Basic Protective Equipment ...... 47 10.2 Fall Protection, Safety Harnesses, Lifelines ...... 51 10.3 Gloves and Hand Protection ...... 52 10.4 Rain gear and Boots ...... 52 11 Scaffolds and Ladders ...... 52 11.1 Ladders ...... 52 11.2 Scaffolds ...... 53 11.3 Mobile/Rolling Scaffolds ...... 54 11.4 Two-Point Suspended Scaffolds (Swing-lo's) ...... 54 11.5 Tagging ...... 55 12 Fall Protection ...... 55 12.1 General...... 55 12.2 Alternate Fall Prevention Systems ...... 59 12.3 Open-Sided Floors, Floor-Openings and Hoist ways, Barricades and Hole Covers ...... 59 12.4 Protection from Falling Objects ...... 60 12.5 Fall Protection during Rigging of a large air conditioning unit ...... 61 12.6 Revisions ...... 61 13 Welding and Burning Safety ...... 61 13.1 General...... 61 REV2.1 February 13, 2018 Page 5 | 165 The Elliott-Lewis Safety Manual 14 Hand and Power Tools ...... 63 14.1 Tools, Guards and Precautions ...... 63 14.2 Grinders ...... 63 14.3 Drills ...... 63 14.4 Impact Tools ...... 64 14.5 Chisels ...... 64 14.6 Woodworking Tools ...... 64 14.7 Power Tampers ...... 64 14.8 Hand Tool PPE ...... 64 15 Housekeeping and Waste Management ...... 65 15.1 General...... 65 15.2 General Rules ...... 65 16 Excavating and Trenching ...... 66 16.1 Responsibilities ...... 66 16. 2 Competent Person ...... 66 16.3 Pre-Plan Operations ...... 66 16.4 Protection from Cave-In ...... 68 16.5 Definitions and Soil Classification ...... 68 16.6 Testing Requirements ...... 70 17 Electrical Requirements ...... 72 17.1 General...... 72 17.2 Ground Fault Circuit Interrupters (GFCI's; GFI's) ...... 73 17.3 Assured Grounding Continuity Program ...... 73 17.4 Electrical - General Requirements ...... 74 17.5 Lockout / Tagout - Control of Hazardous Energy ...... 74 17.6 ARC Flash Protection Program / NFPA 70E-2015 ...... 78 17.7 Revision ...... 82 18 Right to Know/ Hazard Communication/Globally Harmonized System ...... 83 18.1 General...... 83 18.2 Requesting Information ...... 84 18.3 Non-Discrimination ...... 84 18.4 Compliance Methods ...... 85 18.5 Multi-Employer Jobsites ...... 85 18.6 Hazardous Material Control Environmental Protection ...... 85 18.7 Purchasing ...... 86 18.8 Labeling Requirements ...... 87 REV2.1 February 13, 2018 Page 6 | 165 The Elliott-Lewis Safety Manual 18.9 Storage and Handling ...... 87 18.10 Subcontractor Requirements ...... 88 18.11 Hazardous Waste Disposal Area ...... 88 18.12 Employee Training ...... 89 18.13 Waste Removal ...... 91 18.14 Spills, Leaks and Accidental Contamination ...... 91 18.15 Safety Data Sheets ...... 92 19 Fire Prevention and Fire Protection ...... 92 19.1 General...... 92 19.2 Fire Prevention Plan ...... 92 19.3 Flammable Liquids and Solvents ...... 92 19.4 On Site Building Maintenance Services ...... 94 20 Jobsite Contaminants...... 95 20.1 Training ...... 95 20.2 Asbestos Safety ...... 95 20.3 Lead Safety ...... 95 20.4 Silica Exposure ...... 97 20.5 Revision ...... 99 20.6 Ozone Depleting Refrigerant ...... 100 21 Confined Space Entry Program: Permit-Required and Non-Permit Required ...... 100 21.1 General...... 100 21.2 Procedure for Identifying Confined Spaces ...... 101 21.3 Coordination with Host Employer ...... 101 21.4 Preparations for Entry into Permit Space ...... 102 21.5 Pre-Entry Testing of Confined Space ...... 104 21.6 Preparing the Entry Permit ...... 106 21.7 Training and Education ...... 106 21.8 Rescue and Emergency Services ...... 107 22 Respiratory Protection Program ...... 108 22.1 General...... 108 23 Corporate Field Technician Vehicle Policy ...... 109 23.1Purpose ...... 109 23.2 Scope ...... 109 23.3 Administration ...... 109 23.4 Driver Qualification ...... 109 23.5 Personal Vehicle Use ...... 109 REV2.1 February 13, 2018 Page 7 | 165 The Elliott-Lewis Safety Manual 23.6 Vehicle Operation ...... 110 23.7 Vehicle Maintenance ...... 110 23.8 Accident Reporting ...... 110 23.9 Vehicle Violations ...... 111 23.10 Appeals ...... 112 24 Sub-Contractor Safety Program ...... 112 24.1 General...... 112 25 Crane Safety Program ...... 113 25.1 Purpose ...... 113 25.2 Operators ...... 113 25.3 Crane-Suspended Work Cages ...... 115 25.4 Procedure...... 115 25.5 Gantry Cranes ...... 116 25.6 Helicopter Cranes ...... 116 25.7 Safe Rigging Practices ...... 116 25.8 Wire Rope ...... 118 26 Emergency Response Program ...... 119 26.1 General...... 119 26.2 Emergency Planning ...... 119 26.3 Sara Title III Emergency Planning ...... 120 26.4 PA State Emergency Response Commission (SERC) ...... 121 27 Boiler Safety Policy ...... 122 28 Forklift Safety ...... 123 28.1 General...... 123 28.2 Definitions ...... 123 28.3 Operator Qualification and Training ...... 124 28.4 Forklift Safety Checklist ...... 124 28.5 Safe Forklift Operating Rules ...... 124 28.6 Forklift Operation Area ...... 125 28.7 Forklift Maintenance ...... 125 29 Emergency Action Plan ...... 125 29.1 General Purpose ...... 125 29.2 Emergency Control Committee ...... 125 29.3 Emergency Alarms ...... 125 29.4 Bomb Threats ...... 125 29.5 Tornado/Earthquake ...... 126 REV2.1 February 13, 2018 Page 8 | 165 The Elliott-Lewis Safety Manual 29.6 Emergency Phone Numbers ...... 126 29.7 Bomb Threat Checklist ...... 126 30 Emergency Recovery Plan ...... 127 30.1 General Purpose ...... 127 30.2 Coordination ...... 127 30.3 Communication ...... 127 30.4 Vendor Supplies ...... 127 30.5 Safety ...... 127 31 Security Policy ...... 128 31.1 General Purpose ...... 128 31.2 Building Security ...... 128 31.3 Warehouse Security ...... 128 31.4 Off-Site Security ...... 128 31.5 Van, Tool, and Equipment Security...... 128 31.6 Computer Security ...... 129 31.7 Telephone Security ...... 129 31.8 Handling Suspicious Packages ...... 129 31.9 Pandemic Preparedness ...... 129 32 Home-Based Employees ...... 130 32.1 General Purpose ...... 130 32.2 Requirements...... 130 33 Bloodborne Pathogens ...... 131 33.1 General Statement ...... 131 33.2 Training ...... 131 33.3 Definitions ...... 131 33.4 Exposure Control Plan ...... 132 33.5 Exposure Incident ...... 133 33.6 Record Keeping ...... 133 34 Pressure Testing ...... 134 34.1 General Statement ...... 134 34.2 Goals and Responsibilities ...... 134 34.3 Testing Procedures ...... 135 35 Process Safety Management ...... 137 35.1 Purpose ...... 137 35.2 Training ...... 137 36 Mine Safety and Health ...... 138 REV2.1 February 13, 2018 Page 9 | 165 The Elliott-Lewis Safety Manual 36.1 General...... 138 36.2 MSHA Headquarters ...... 139 36.3 Educational Video and Training Materials ...... 139 37 Electronic Hazards on the Worksite...... 139 37.1 Cell Phones ...... 140 37.2 Headphones ...... 140 38 Aerial Lift Safety ...... 140 39 Mobile Equipment ...... 140 39.1 General...... 140 39.2 Scope ...... 140 40 Core Drilling Safety Program ...... 141 40.1 Purpose ...... 141 40.2 Training ...... 141 40.3 Procedure...... 141 40.4 Subcontractors ...... 142 40.5 Personal Protective Equipment ...... 142 40.6 Job Hazard Analysis ...... 142 41 Heat/Cold Stress Identification ...... 145 42 Pandemic Preparedness Program ...... 147 42.1 Purpose ...... 147 42.2 Training ...... 147 42.3 Procedures ...... 147 43 Radio Frequency Safety ...... 147 43.1 Purpose ...... 147 43.2 Training ...... 147 43.3 Ionizing vs. Non-Ionizing Radiation ...... 148 43.4 Health Effects ...... 148 43.5 RF Energy Levels ...... 148 43.6 Identify Antennas and Emission Patterns ...... 148 43.7 Safe Distances ...... 148 43.8 Protective Clothing and Equipment ...... 148 44 Ammonia Refrigeration ...... 149 44.1 Purpose ...... 149 44.2 Scope ...... 149 44.3 Definitions ...... 149 44.4 Health Effects ...... 149 REV2.1 February 13, 2018 Page 10 | 165 The Elliott-Lewis Safety Manual 44.5 Personnel Protective Equipment (PPE) ...... 150 44.6 Pre-job set up ...... 150 44.7 System Piping Isolation ...... 151 44.8 Line Opening ...... 151 44.9 Hot Work ...... 151 45 Working alone ...... 152 45.1 Purpose ...... 152 45.2 Requirements...... 152 45.3 Situations covered by this policy ...... 152 46 Hearing Conservation ...... 153 46.1 Purpose ...... 153 46.2 Definitions ...... 153 46.3 Action Levels for Mechanical Construction, Service and Fabrication Shops ...... 153 46.4 Workplace Noise Sampling ...... 154 46.7 Audiometric Testing ...... 154 46.8 Hearing Protection and Follow-Up for Workers with Hearing Loss...... 155 46.9 Training and Information ...... 155 Appendix ...... 157 Table 1: Specified Exposure Control Methods When Working with Materials Containing Silica ...... 157
REV2.1 February 13, 2018 Page 11 | 165 The Elliott-Lewis Safety Manual 1 Objectives
1.1 General The objective of the Company Safety Program is to reduce the probability of injury or property loss from foreseeable causes. By achieving this objective, the Company protects our employees and the public, and also benefits by reducing the needless losses caused by decreased efficiency, work interruptions, or equipment/property damage. Project safety must become an integrated function with other well-thought-out controls, such as scheduling, costs, production and quality. Universal management controls are equally adaptable to safety and are best integrated through planning/scheduling and adopting standard safety procedures. Safety is a regulated function, through the use of OSHA regulations and safe industry practices, yet acceptance of the safety procedures on a project begins with project management and is of paramount importance in order for regulatory guidance to work. Several myths are no longer valid arguments for not accepting safety as part of performing construction work. Unsafe acts on the part of an employee are no longer the primary cause of accidents, but rather, are only proximate causes. Behind most unsafe acts and unsafe conditions are slack management controls in areas such as training, adequate materials, adequate equipment and adequately trained line supervision. Methods of Obtaining Objectives
The effectiveness of the Safety Program is dependent upon the participation and cooperation of all Company personnel. The coordination of their efforts relies on effective inter-communication of any information that will benefit the Safety Program.
The following methods are an integral part of this program:
1.1.1 Safety Committee
This workplace committee is composed of an equal number of employer and employee representatives.
1. Conduct monthly Safety Meetings 2. Maintain minutes and attendance forms 3. Evaluate existing accident and illness prevention programs 4. Establish procedures for periodic workplace inspections to identify and document in writing the location of safety and health hazards 5. Make recommendations to correct these hazards 6. Review all incidents and "near misses" resulting in workplace injuries, illnesses and deaths 7. Review safety concerns of the employer, the employees, and the client 8. Establish, review, and appropriate the safety budget 9. Conduct follow-up evaluations of newly implemented safety procedures and equipment 1.1.2 Pre-Planning
Plan all work in advance to anticipate correctable hazards and ensure that all necessary equipment is available to protect the employee, including:
1. Bid planning 2. Budgeting for appropriate safety equipment 3. Pre-job pre-planning. 4. Pre-job coordination meetings, including subcontractors.
REV2.1 February 13, 2018 Page 12 | 165 The Elliott-Lewis Safety Manual 1.1.3 Training
Establish a program of supervisory and employee education designed to increase awareness of hazards through:
1. New Hire Orientation of Employees 2. Periodic project craft safety meetings (Tool Box Meetings) 3. Supervisor and superintendent safety orientation and training. 4. Periodic bulletins and newsletters 5. Training sessions for specialized operations, high hazard operations, and handling hazardous materials 1.1.4 Enforcement
System of employee discipline to deter unsafe acts by the employee, by
1. Consistent and equitable verbal warnings 2. Documenting warnings 3. Imposing suspension or terminations 1.1.5 Monitoring
Maintain a system of inspections, audits and reporting of project work conditions to ensure the correction of unsafe conditions, including
1. Daily Project Self-Inspections 2. Periodic Site Safety Audits 3. Tool and Equipment Inspections 4. Crane and Heavy Equipment Maintenance and Inspections 5. Hazardous Material Control 6. Inspections by Insurer Loss Control Representatives 1.1.6 Accident Reporting
Establish a confidential method of documenting and reporting accidents and "near misses" to determine the cause(s). Convey the accident causes to supervisory personnel to prevent reoccurrence, through:
1. Incident report reviews 2. Supervisory training on accident investigating 3. Special bulletins and training 1.1.7 Effectiveness
Establish a method of tracking accident statistics and accident costs. Use these effectiveness measurements to gain accountability on the project level for trends in achievements and losses, through:
1. Safety Performance Reports 2. Project Safety Audit Scores 1.1.8 Awards and Incentives
Establish a method of rewarding personnel for significant achievement in accident prevention and jobsite safety, through:
1. Safety Awards and Recognition Program
REV2.1 February 13, 2018 Page 13 | 165 The Elliott-Lewis Safety Manual 1.2 Definitions Accident: Any unexpected or unusual event that interrupts or interferes with the orderly progress of an activity or process. An accident may not always result in an injury or property damage, as is the case in numerous "near miss" accidents. Accident Cause - Proximate: The final factor or part of a series of events that directly contributes to an accident, such as an unsafe act or unsafe condition, or a combination thereof. Accident Cause - Root: Actual accident causes may lie beyond the proximate cause and may have initiated a series of failures, usually beginning with management or supervision failures - such as the failure to follow established procedures, lack of training, inadequate supervision, or the poor division or lack of acknowledgement of responsibility for safety. Hazard: Any existing or potential condition in the workplace that, by itself or by interacting with other variables, can result in death, injury, property damage, or other losses. Hazardous Material: Any material, chemical solvent, insulation, or lubricant, which, by nature of its ingredients can pose a potential immediate or long-term health effect to the employee, should exposure beyond recommended guidelines occur without recommended protective equipment. Hazardous Operation: Any work operation that requires the employee to perform “other than normal” tasks, or any work operation in a potentially hazardous area, or work with a Hazardous Material. Hazardous Operations usually require special training for the supervisor and the employee. Mechanism of Accountability: The generation and use of data about loss control efforts that are seen by line managers and supervisors as a legitimate measure of performance. Any method of counting or measuring with sufficient reliability and validity that managers will accept it for appraisal, praise, blame, correction or reward. Monitoring: A term generally used to mean atmospheric or environmental monitoring for specified contaminants. Monitoring is commonly performed for air, noise, soil or groundwater contamination. NIOSH: The National Institute for Occupational Safety and Health. A government sponsored research institute that advises OSHA. NIOSH establishes exposure levels in industrial hygiene that are generally later adopted by OSHA. Non-Compliance: Failure to follow established rules or regulations. OSHA: An acronym for the Occupational Safety and Health Administration; a division of the Federal Department of Labor that regulates and enforces laws applicable to the workplace. Most of the Company's projects are specifically regulated under 29CFR1926 "Federal Standards for the Construction Industry." Project Safety Monitor: A Company employee whose incidental duties include monitoring a specific project safety program. The safety monitor will assist with first aid treatment, process incident reports and perform a daily inspection of selected active work areas. The safety department will provide training for the safety monitor. Project Safety Representatives: An individual whose primary responsibility on a project will be to develop and initiate a site-specific safety program and monitor compliance. The safety representative should be experienced in construction safety with several years of field experience. Incidental duties may include assisting with payroll or office duties as deemed necessary by the project manager. Safety (First Definition): A judgment of the acceptability of risk. An operation is “safe” if its risks are judged to be acceptable. Unsafe Act: Any action by an employee that may cause, in whole or in part, to the accident, whether the act was willful or unknowing. Such unsafe acts can include working on energized or pressurized equipment; failure to wear protective equipment as instructed; failure to warn or adequately guard horseplay; using the wrong tool;
REV2.1 February 13, 2018 Page 14 | 165 The Elliott-Lewis Safety Manual failure to follow instructions; inattention to hazards in the work area; failing to correct hazards in the work area as instructed; haste; using condemned equipment or violating posted warnings. Unsafe Condition: Any physical condition that may cause, in whole or in part, to an accident cause. Such conditions can include defects, such as broken or poorly operating equipment; unexpected sharp objects or slippery floor surfaces; inadequate guarding; inadequate lighting; inadequate ventilation. Unsafe conditions may generally be recognizable by a knowledgeable employee or supervisor, or may be a latent condition created by a lack of maintenance or repair. 1.3 References 1. OSHA - Federal Register 29CFR1926 - Construction Safety Standards 2. OSHA - Federal Register 29CFR1910 - General Industry Safety Standards 3. Workers Compensation Act and Rules of the Industrial Accident Board, General Laws, Commonwealth of Pennsylvania; State of New Jersey 4. NIOSH - National Institute for Occupational Safety and Health, Hazardous Material and Substance Control and Guidelines. 5. Dangerous Properties of Industrial Materials, J. Irving Sax. 6. The Associated General Contractors of America 7. Accident Prevention for Industrial Operations, National Safety Council 8. Worker and Community Right to Know Act of New Jersey, Florida and Pennsylvania 9. Handbook for Riggers, 2nd Edition, W. G. Newberry 10. National Fire Protection Administration, Life Safety Code, Batterymarch Park, MA 11. ANSI - American National Standards Institute, various sections 12. Liberty Mutual Insurance Company, Loss Prevention Guidelines 1.4 Organization and Responsibilities All safety processes begin with Senior Management. The Chief Operating Officer and the Chief Financial Officer are members of the State Certified Safety Committee and attend all monthly meetings. In support of the company’s philosophy to eliminate behavioral risk, they take the lead in all post-accident/injury reviews that are held to investigate and analyze for root cause and corrective actions. 1.1.9 Safety Director
The Safety Director reports directly to the President on a confidential basis. The Safety Director formulates, administers and coordinates programs for the company to reduce the risk of loss due to employee injury, regulatory non-compliance, public liability or injury, fire, theft or environmental damage.
Operational duties include:
1. Authorize appropriate expenditures for equipment, materials, training and monitoring 2. Maintain necessary records, reports and information for tracking progress, project accountability and insurance information. Submit monthly reports and special reports to the company Officers and Divisional Manager(s) 3. Oversee the administration, implementation and staffing of jobsite safety/first aid facilities 4. Perform comprehensive accident investigations in cases of serious injury, fatalities, questionable claims or major property or equipment damage 5. Formulate and initiate training programs for employees, project safety monitors and supervisors 6. Perform regular periodic jobsite audits to ensure continued compliance. Ensure the correction of violations through submission of punch-lists of correctable items following the audits. 7. Document critical conditions, and determine accountability 8. Report evidence of continued noncompliance to the President and Divisional Manager(s) utilizing internal communications in a confidential manner REV2.1 February 13, 2018 Page 15 | 165 The Elliott-Lewis Safety Manual 1.1.10 Project Manager
Each Project Manager has full responsibility for ensuring that the policies and procedures outlined in the Safety Manual are implemented on respective project(s). The Project Manager maintains communications with the Safety Department to assist in the formulation of specific project procedures. The Project Manager establishes by example, an attitude of concern for safety matters and assists field supervision to recognize and resolve safety violations and items of noncompliance. The Project Manager will be kept informed of safety performance on their projects through monthly safety performance reports and copies of jobsite safety audits. 1.1.11 Project Superintendent
The Project Superintendent has operational responsibility for the specific field implementation of the safety program on the project.
Project Superintendent’s responsibilities include:
1. Ensures that weekly safety meetings, new hire orientations and other required training are held for employees; performs foreman and subcontractor orientations in the absence of a project safety monitor/representative 2. Ensures that work areas are inspected daily for compliance with this manual and unsafe conditions and unsafe acts are corrected promptly; document any problems and corrective actions 3. Ensures that accident reports and attendance sheets are submitted to the Safety Monitor or Safety Department promptly 4. Performs a thorough initial investigation of all accidents and injuries and promptly submit required reports; promptly notifies the Safety Department of unresolved problems or situations requiring assistance 5. Enforces and issues warnings, suspensions and terminations; notifies the Safety Department and Project Manager of any unresolved safety problems 6. Directs stop work orders as needed on the project, including subcontractor operations, that pose an immediate hazard or which have the potential for injury, serious damage or for continued noncompliance
1.1.12 Project Safety Monitors/Safety Representatives
On projects with designated Safety Monitors or full-time Safety Representatives, the duties of the Safety Monitor/Representative include:
1. Monitors and ensures attendance of the periodic craft safety meetings; processes completed attendance sheets 2. Reviews and processes Incident Reports; initiates an investigation when necessary 3. Performs new-hire employee, foreman or subcontractor orientations and hazard communication training 4. Performs an inspection each day of selected work area(s); submits a list of items for correction to the Project Superintendent; follows-up and ensures that items are corrected promptly 5. Maintains the Hazardous Material Inventory and labels incoming containers 6. Contacts the Safety Department with any unresolved safety problem or in case of a jobsite emergency 7. Directs stop work orders as needed on the project, including subcontractor operations, that pose an immediate hazard or which have the potential for injury, serious damage or continued noncompliance 1.1.13 Field Superintendent
A Field Superintendent’s responsibilities include:
1. Plans work to include safety equipment and safety procedures 2. Orders required safety equipment in advance of an operation to ensure delivery in time for the operation REV2.1 February 13, 2018 Page 16 | 165 The Elliott-Lewis Safety Manual 3. Attends the periodic safety meeting and remains available to answer/correct problems and complaints from their foreman 4. Takes prompt action to have unsafe conditions corrected; takes immediate action to stop unsafe acts by employees; issues disciplinary warnings to employees for violating safety rules and properly documents the warnings 5. Surveys the crew's work areas each day for unsafe conditions 6. Promotes awareness of the safety program by taking immediate action to resolve the safety problems of their crew(s) 7. Notifies the Project Superintendent or the Safety Department of unresolved safety problems 1.1.14 Foreman
A Foreman's responsibilities include:
1. Holds a periodic safety meeting with their crew using the weekly safety bulletin as a guideline 2. Enforces the use of required safety equipment 3. Inspects the work areas for correctable unsafe conditions 4. Ensures that tools used are in good repair and return broken/damaged tools for repair or replacement 5. Reports safety problems to the superintendent that the foreman cannot resolve 6. Sets a good example by following the safety rules 1.1.15 Employee
An Employee’s responsibilities include:
1. Is attentive at all safety meetings and toolbox talks 2. If one does not understand the safety scope of the project, asks questions immediately 3. Inspects and wears the required PPE for the project 4. Reports any dangerous situations to the Project Manager immediately 5. Reports any un-safe acts by any fellow employees or any sub-contractor’s employees immediately to the Project Manager 6. Sets a good example for one’s fellow employees 1.1.16 Safety Committee
The Elliott-Lewis Corporation Safety Committee has been certified by the State of Pennsylvania since 2005. The committee is made up of six dedicated full time employees in which 50% are from the employee group and 50% are from the employer group in addition to a group of conscientious alternates. This ensures a balance of representation and opinions. All members are required to be trained yearly in accident investigation, hazard inspection, and safety committee operation. Following are the full-time members of the Safety Committee:
Bill Schwartz-employer Kevin Dooley-employee
Jim Pizzi-employer Anthony Iezzi-employee
Mike Stepnowski -employer Paquito Cubero -employee
The Safety Committee is created to ensure a safe workplace for all employees. The following are the functions and duties of the committee:
1. Hold monthly meetings and develop and make available a written agenda and minutes of the meetings 2. Evaluate the employer’s safety/health policies and procedures 3. Review reports of all injuries, accidents, illnesses and death. Find a root cause and make recommendations for corrective actions to prevent reoccurrence REV2.1 February 13, 2018 Page 17 | 165 The Elliott-Lewis Safety Manual 4. Establish procedures for workplace inspections to identify safety and health hazards 5. Make recommendations to improve supervisor and employee accountability for safety and health 6. Develop initiatives to maintain and improve all aspects of the Corporate Safety Program
2 Project First Aid and Safety Services
2.1 First Aid 1. Each project shall have a first aid kit on location that is of sufficient size and inventory for the projected number of employees on the project. The size of the first aid kit(s) should be in accordance with OSHA guidelines. Contact the company Safety Department for assistance. 2. The first aid kit shall be inspected each week by the project Safety Monitor and missing items replaced promptly by ordering them from a local supplier or providing for periodic on-site service by the vendor of the kit. 3. The designated project Safety Monitor or project Safety Representative may assist with the treatment of injuries within the scope of their training. The designated employee should have a minimum of a Red Cross Standard First Aid certification or equivalent. First Aid and safety training and re-certification for this individual will be provided by the Company 4. In areas where 911 is not available, the numbers of physicians, hospitals, or ambulances shall be conspicuously posted. 5. Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities shall be provided within the work area. 2.2 Safety Services 1. Each company project shall have a designated Safety Monitor whose project duties include monitoring compliance with the company safety program. On smaller projects (less than 25 employees), the safety monitor may be a foreman or superintendent. 2. On civil building projects or heavy/highway projects where the Company is the prime contractor and where more than 100 Company employees are anticipated, the Company safety manager should be contacted to determine if an experienced safety representative is necessary based on the site population and scope of work. Primary responsibility of the safety representative would be to monitor the safety program, but the individual may be assigned incidental duties on the project as time allows, at the discretion of the Project Manager. 3. On projects with a total population of more than 300 employees, including subcontractors to the Company, a full-time safety representative/first aid attendant should be considered. 4. Projects with a full-time safety representative/first aid attendant should have a separate first aid room where sanitary treatment can be rendered. The treatment area shall be equipped and operated as outlined in the Company's First Aid Treatment and Protocol Manual, which required adequate lighting, hot and cold wash sink and basic treatment equipment. 5. The company Estimating Department is responsible for notifying the company Safety Department in advance of estimating a project where the workforce population would require a full-time safety representative/first aid attendant so that bid allowances may be arranged for staffing and equipment. 6. The company Safety Department will be responsible for hiring project safety personnel and establishing the project treatment room. When a first aid treatment room is established and a qualified first aid attendant is available, project employees will be required to report their injuries to the first aid trailer.
REV2.1 February 13, 2018 Page 18 | 165 The Elliott-Lewis Safety Manual Injuries will be initially treated by the first aid attendant and any necessary medical care or follow-up visits will be arranged by the first aid/safety representative. 7. The first aid/safety representative will perform any necessary accident investigations and will maintain any required injury logs, will process insurance related forms and will maintain safety related documentation for the project. 2.3 Care and Transportation of Injured Employees Evaluation
1. Determine if an employee can safely be moved. If there is any question as to whether an employee should receive emergency treatment for an injury, then summon an ambulance. 2. If the employee does not require emergency treatment and the injury is relatively minor, on-site treatment should be attempted with assistance from the safety monitor or other first-aid trained employees. 3. Examination and treatment by a physician should be arranged promptly if there is any question as to whether the injury requires treatment beyond simple first aid. 4. Employees with complaints of back, neck or knee injuries should always be sent for examination, regardless of the employee’s desire. 5. If an employee is injured, as described in No. 4 above, and refuses treatment, and in the opinion of the employee's superintendent, the safety monitor or first aid attendant, the employee may aggravate the injury by continuing to work, then the employee must not be allowed to return to his work area. Immediately contact the company Safety Department for assistance. 6. The company "TREATMENT AUTHORIZATION FORM" should be completed before the employee leaves the project, except in an emergency. See Section 3.0 for information and instruction regarding completing accident reports and investigating accidents. 7. Transportation to a clinic or hospital must be provided for the employee by: a. Calling a Taxi b. Having the employee driven to the hospital in a company vehicle 8. Employees may not drive themselves or use a personally-owned vehicle for transportation to treatment while on company payroll. The company remains responsible for the employees as long as they are on our payroll. 9. Another employee, such as a craft steward, may not drive an injured employee for treatment in any personal vehicle while on the payroll.
Following treatment, injured employees generally return to the project. When the employee returns, be sure to check with physicians' section of the Treatment Authorization Form or an equivalent work release from the physician for instructions or work limitations. See Section 3.0, TREATMENT AUTHORIZATION FORM, for further instructions.
3 Accident Reporting and Investigating
3.1 General The purpose of an accident investigation is to find identifiable causes and take corrective action to prevent reoccurrence. All factors that contribute to an accident should be examined to eliminate those factors that could result in reoccurrence. Influencing factors are not always obvious and may include equipment material defects, inadequate communication or job instruction, failure to follow procedures or failure to pre-plan the work. A “root
REV2.1 February 13, 2018 Page 19 | 165 The Elliott-Lewis Safety Manual cause analysis” process shall be utilized to understand why the incident occurred and the severity. The incident must be reported immediately to the Safety Department and the Owner Client so the investigation can begin as soon as possible. That investigation shall proceed to the appropriate level based on the severity. However, all incidents are reviewed by the Safety Committee which includes the company Chief Operating Officer. 3.2 Incident Report Form 1. The investigation and resulting incident will always be reported by the assigned superintendent or foreman in conjunction with the Safety Director within one workday following any report of: a. Employee injury or subcontractor employee injury (Workers' Compensation) b. Fire Incidents (Fire Loss) c. Company Automobile Accident (Auto Loss) d. injury to a member of the public (General Liability) e. Property damage to Company Property (Property Damage) f. Property damage to others' property (General Liability) g. Equipment failure due to defective parts that results in property damage or injury (Property Damage or General Liability) h. Theft of materials or equipment (Theft Loss) i. Any unusual incident, or "near-miss" requiring documentation 2. The incident report is an important legal document. When investigating an accident, keep in mind that the information you are obtaining may be the only information available to defend the company several years later. Proper equipment to ensure recording of the incident such as cameras and forms and procedures showing how and what to document are maintained on every company vehicle and jobsite. 3. Timely reporting is extremely important in expediting and completing incident investigations. The Safety Department should be notified immediately in the event of an incident. In the case of an injury, this will ensure the injured employee receives treatment as quickly as possible within the company’s panel of physicians. This is very important because Pennsylvania state law (the law varies by state) requires that the employee treats with a panel physician. This allows us to better manage the employee’s care. Of course, if necessary, 911 should be called to administer emergency treatment. In most cases, our owner clients require notification within 24 hours of all incidents, including injuries, property damage, spills, fires, explosions, and vehicle accidents. If a death occurs, the Safety Department is required to notify OSHA within eight hours. If an employee becomes hospitalized and is emitted for treatment, the Safety Department is required to notify OSHA within 24 hours. 4. All Safety Committee members, Project Managers and Foremen shall be trained yearly in their roles as first responders and investigators. Possible first responders shall also have first aid/CPR training as required to assist when needed to control losses. 5. After an incident occurs, it may be necessary to impound any equipment or vehicles that may have been involved. This will ensure the integrity of the accident scene and any evidence that may be important to the investigation. Maintenance or engineering personnel may be needed to assess the integrity of a building or equipment to ensure it is structurally or mechanically sound. It may be necessary to call in special equipment or response groups to ensure the safe rendering of any hazardous materials or waste. 6. Accident investigating is fact-finding, not fault finding. Always be objective and as thorough as possible. The information you record may be valuable to the company's defense. Include as much information as possible on the report. Initial identification of evidence immediately following the incident might include a listing of people, equipment, positions of the equipment, parts, and materials involved and a listing of weather conditions, lighting, temperature, and noise. All information collected shall be preserved,
REV2.1 February 13, 2018 Page 20 | 165 The Elliott-Lewis Safety Manual secured, and collected, through notes, photos, witness statements, flagging, and impoundment of documents and equipment. 7. Always and immediately interview and collect statements from any potential witnesses at the scene. Witnesses may have firsthand knowledge about the event and can help certify important facts that may be pertinent to the investigation. Follow-up interviews will usually be completed by our insurance adjustors. 8. The written report shall include a detailed narrative statement concerning the events. The format of the narrative report should include a summary of the details of the incident, who performed the investigation, the findings and recommendations. Photographs, witness statements, and drawings should be included. 9. Utilize the information obtained from an incident to develop corrective actions with foremen and supervisors assigned responsibilities to track these actions and make the necessary adjustments to ensure a repeat incident does not occur. Address the changes with all employees to ensure they understand why the procedure changes were enacted. 10. Do not give an employee a copy of an accident report. Only those parties listed in the distribution should receive copies, unless otherwise instructed to do so by the company safety department. Direct any information requests to the company safety department. 11. All incidents shall be reviewed and communicated to all who may have been directly or indirectly affected by them. Any changes to processes due to lessons learned by the incident shall be communicated to all personnel.
If there are any questions as to the procedures for initiating an accident investigation, please contact the company Safety Director. In case of a serious accident or significant property or equipment damage, the company Safety Director should be contacted immediately to assist. with an on-site investigation. 3.3 Treatment Authorization Form 3.3.1 General 1. A TREATMENT AUTHORIZATION FORM should be given to the employee before being sent for medical treatment by any hospital, physician, chiropractor or clinic. 2. THE TREATMENT AUTHORIZATION FORM provides our company with an information release, documentation of treatment, and information on any work restrictions. 3. Employees are instructed during their orientation that they are required to report injuries and medical treatment to the employer. In some states, the employer can require that an employee is to go to an employer selected physician, and if the employee does not follow the employer's instructions, any subsequent medical bills may be denied by the employer's insurance carrier. a. Employees should request permission from the employer before seeking treatment. b. If an employee fails to report an injury, or reports a minor injury on one date and later reports that they sought physician care for the injury, then the employee must submit a return to work authorization within 24 hours after reporting the medical treatment to the company. c. If an employee fails to submit a return to work authorization from the attending physician within the 24-hour period, then the employee should not be permitted to work and should be restricted from the project at the start of their next work shift. 3.3.2 Insurance Company Notification
The insurance carrier must be notified of each injury that required treatment by a physician or other health care provider. The insurance carrier does not need to be notified of an injury that does not require physician, hospital or clinic treatment. However, it is policy to report all injuries to the insurance company, no matter how minor. REV2.1 February 13, 2018 Page 21 | 165 The Elliott-Lewis Safety Manual The insurance carrier is notified by completing and distributing an Employers’ Report of Injury (also known as the First Report in some states). The Employers Report of Injury is provided by each state and accepted by the insurance carrier as ample notification.
The Employers Report of Injury should be completed and distributed to the state and to the insurance carrier within 24 hours following an injury that required medical treatment (some states allow notification within three- five days, but prompt distribution is preferred).
On projects with a designated office manager or clerical assistance, the Employers’ Report of Injury may be completed by the office manager based on the information in the company Incident Report Form completed by the superintendent.
Distribution of the Employers’ Report of Injury generally includes:
a. State Workers Compensation Commission (Dept. of Labor) b. Insurance Carrier - Local Claim Office c. Home Office Safety Department d. Employee (in some states) e. Physician (in some states) f. Project Copy
Note: Each project will have different distribution requirements. These requirements will be outlined by the safety department upon mobilization.
On projects without a designated office manager, the original page of the Incident Report Form must be sent to the home office safety department within one work shift so that the home office safety department can complete and distribute the Employers Report of Injury and any other insurance related documentation. 3.3.3 Emergency Notification of Corporate Personnel
In cases of serious employee injury, lost time injury, unresolved safety problem, questionable insulation material, serious property or equipment damage or jobsite fire or theft:
First attempt to contact the Company Safety Department:
Safety Director: Bill Schwartz Assistant Safety Director: Kraig Safety Coordinator: Dan Mullen Office: (215) 698-4499 Wicklund Office: (215) 689-4425 Home: (302) 479-5054 Office: (215) 698-5976 Cell: (215) 399-7417 Cell: (215) 341-8221
3.4 Benefit Changes 1. Unemployment benefits will be offset against Worker's Compensation benefits, no double dipping. 2. No compensation will be paid during an employee's incarceration after a conviction. 3. Burial expenses are increased from $1,000 to $3,000. 4. Employers can now recover worker's comp benefits paid to an employee injured in an auto accident that was the fault of another. 5. Injured employees are prohibited from receiving benefits from the Federal government or any state for the same injury in excess of the maximum benefit. 6. Average weekly wage calculations are now based upon the average earnings of the three highest quarters of the last four quarters.
REV2.1 February 13, 2018 Page 22 | 165 The Elliott-Lewis Safety Manual 7. The definition of “fraud” is expanded to include the failure of claimants to report other earnings received. 3.5 Medical Changes 1. The injured employee must now go to the doctor panel for treatment for the first 90 days following his first visit. 2. The injured employee must provide notice to the employer of a change in doctors after the 90-day period. Five days’ notice is required. 3. Payment of medical treatment must be made within 30 days of receipt of invoice. 4. All benefits can be denied if the injury is the sole result of drug or alcohol abuse. You will be tested after an injury.
Worker's compensation accidents must still be reported immediately to the company for proper reporting and handling requirements. The employer/employee/insurer cannot request a utilization review as to the necessity of any medical treatment. 3.6 Employee’s Rights & Duties Under Section 306(f.1) of the Pennsylvania Worker’s Compensation Act If you are injured at work and medical treatment is necessary, you are required to visit one of the physicians or health care providers on the list designated by your employer for a period of 90 days from your first visit with the physician or health care provider.
All reasonable medical treatment and supplies related to the injury will be paid for by the employer provided treatment is by a designated physician or health care provider on the list during the 90-day period. Charges for treatment and supplies are specified by the ACT. You are not responsible for the payment of any charges in excess of those specified by the ACT.
During the 90-day period, you may change from one designated physician or health care provider on the list to another physician or health care provider on the list, and the treatment will be paid for by the employer.
If the designated physician or health care provider refers you to a non-designated provider, the employer will pay for the treatment by the non-designated provider.
You have the right to obtain emergency treatment from a non-designated physician or health care provider however; the subsequent non-emergency treatment must be by a designated physician or health care provider for the remainder of the 90-day period.
You may seek treatment or consultation from a non-designated physician or health care provider during the 90- day period however, you are responsible for the charges for this treatment during the 90-day period.
If the employer designated physician or health care provider recommends invasive surgery, you are permitted to obtain a second opinion from a non-designated physician health care provider. Your employer will pay for the cost of this opinion. If this opinion differs from the opinion of the designated physician or health care provider and provides a specific and detailed course of treatment, you may elect to undergo this treatment. The treatment, however, must be provided by a designated physician or health care provider for 90 days from the date of the visit to the non-designated physician.
You have the right to seek treatment from any physician or health care provider after the 90-day period has ended, and your employer will pay for this treatment provided it is reasonable and necessary.
You have the duty to notify your employer of treatment by a non-designated physician or health care provider within five days of your first visit to this physician or provider. Your employer may not be required to pay for REV2.1 February 13, 2018 Page 23 | 165 The Elliott-Lewis Safety Manual treatment by a non-designated physician or health care provider prior to notification. The employer, however, shall pay for this treatment once notified unless the treatment is found to be unreasonable.
Signing this form is an acknowledgment of your rights and duties. You may not refuse to sign this acknowledgment in order to avoid your duties.
If you have any questions, please feel free to contact the Bureau of Worker’s Compensation at 1-800-482-2383 or 1-717-783-5421.
I acknowledge that I have been informed of and understand the above rights and duties.
______
Employee signature Date
______
Employer signature Date 3.7 Acknowledgement of Rights and Duties In accordance with the 1993 Worker's Compensation Reform, Elliott-Lewis Corporation has provided a list of six designated health care providers (attached).
In order to insure that your medical treatment will be paid for by the company or the insurance company if you suffer a work-related injury, you MUST visit one of the physicians listed, if you require treatment, for the first 30 days from the date of your first visit.
If you do not visit one of these six physicians listed, after the initial emergency treatment, Elliott-Lewis will be relieved from liability for the payment of any treatment.
I acknowledge that I have been informed of my rights and duties, and I understand them.
______
Employee's Name (Printed)
______
Employee's Name (Signature)
REV2.1 February 13, 2018 Page 24 | 165 The Elliott-Lewis Safety Manual 3.8 PENNSYLVANIA WORKER’S COMPENSATION - DOCTOR'S PANEL Elliott-Lewis Corporation has obtained worker’s compensation insurance coverage from: Gallagher Bassett Services P.O. Box 1508 Mt. Laurel, NJ 08054 P: (856)778-5595 |F:(856)778-7490
Insurance Representative: The Simkiss Agency, Inc. P:(877)928-4531 | F:(866) 691-7068
The Policy Number is WC25893728 with an effective date of December 31, 2016. In the event of a work-related injury, your reasonable, necessary and related medical and surgical expenses that could include the physician, medicine, supplies, orthopedic appliances and prostheses and the training in their use, will be paid. Additionally, you are entitled to a formulated wage benefit after seven (7) days of missed work. According to the Pennsylvania Worker’s Compensation Act, if you suffer a work-related injury or illness and after obtaining emergency medical treatment, you must be treated by one of the following health care providers for a period of 90 (ninety) days to insure payment of your medical expenses: WorkNet Referral by Safety Department based
on Concentra Occupational Medicine Location 2804 Southampton Rd., Philadelphia, Allmed Occupational PA () Premier Orthopaedics Referral by Insurance or Physician by location
Orthopedic Rothman Institute (1) 3300 Tillman Dr., 2nd Fl., Bensalem, PA Rothman Institute (2) 19020 (800) 321-9999 925 Chestnut St. Philadelphia, PA Philadelphia Hand Center (1) 19107
(800) 321-9999 Philadelphia Hand Center (2) 120 Huntingdon Pike, Rockledge, PA Einstein General Surgery 9880 Bustleton Ave, Suite 205
Philadelphia, Pa. General Surgery 19115 (215) 676- 2222
Wills Eye Hospital 840 Walnut St. Suite 1230, Ophthalmology Philadelphia, PA 19107 (215) 928- 3041 You will be required to submit a urine sample for Drug and Alcohol testing prior to being treated ALL INJURIES -- NO MATTER HOW MINOR -- SHOULD BE REPORTED TO THE SAFETY DEPARTMENT IMMEDIATELY NOTE: Questions regarding worker’s compensation should be directed to William Schwartz, Elliott- Lewis Safety Director: Voice: (215) 698.4499 (215) 399.7417; Fax: (215) 698.4427.
REV2.1 February 13, 2018 Page 25 | 165 The Elliott-Lewis Safety Manual 3.10 Return to Work Policy It is the policy of Elliott-Lewis' management to implement and support a Return to Work Program that is beneficial to both the Company and the injured employee. Even an aggressive Safety Program that strives for an accident free work place can be obscured by reality. 3.10.1 Achieving the Goals
The Return to Work Program begins the moment an employee is injured. After obtaining emergency medical treatment, the Program Coordinator, who is our Safety Director, will be in constant communication with the medical provider and injured employee. 3.10.2 Communication
Communication is the key to our program. By communicating concern to the employee and his family, the employee feels valued and secure, which builds morale and creates loyalty. Providing the physical job demands of the employee's position enables the physician to aim the rehabilitation techniques to obtain those requirements.
Constant follow-up with the treating physician, the employee, and the insurance company, insures a proper flow of information. Is the employee obtaining the proper medical treatment? Does the employee need help in satisfying the needs of his family? Is the employee happy with his physician? Is the physician requesting unnecessary tests? Is the insurance company satisfying its obligation to remit in a timely fashion to the medical providers and the employee? Is the employee following the format developed to rehabilitate his injury?
Second to communication is job adaptation. Job adaptation can mean changing the work hours or returning to a modified, light duty job. Most work place injuries result in a minimum of lost workdays. However, returning to work after a serious injury requires several techniques. Returning to work on a Thursday instead of a Monday allows the recovering employee to accustom himself to "working hours" and regain his confidence by knowing that he only has to work two days before he can rest. Elliott-Lewis has the unique opportunity to create a job specifically designed for our recuperating employee.
By judicious use of these tools, Elliott-Lewis can reap the benefits of case management. The program coordinator will strive to control lost workdays, reduce the Worker's Compensation expense, reduce the experience modification rate, and help the Company retain a knowledgeable employee.
3.10.3 The Path of Recovery from a Work-Related Injury
1. See immediate, emergency medical treatment. 2. Contact your supervisor. 3. Report the accident as soon as possible to the Safety Department. 4. A supervisor will conduct an accident investigation to determine the accident cause and a method to prevent a recurrence. 5. Employees requiring more than first aid will be immediately referred to U.S. Regional Health for evaluation. The company will provide transportation if required. U.S. Regional will be the only medical provider for the next 30 days. 6. The attending physician will determine any required physical therapy and the probably length of recovery. He will also determine if the employee is eligible for our "light duty job" as a tool room assistant. 7. If the employee is eligible, he will begin immediately within the limitations or restrictions set by the physician. 8. The light duty job pays $325 per 40-hour week or the employee's salary if less. Time is allotted for doctor's visits and therapy during working hours. REV2.1 February 13, 2018 Page 26 | 165 The Elliott-Lewis Safety Manual 9. If the employee’s salary is above $325, our insurance company will pay two-thirds of the difference between $325 and the employee’s average weekly pay, to the Worker's Compensation maximum of $561. The company continues to pay union benefits. 10. If the employee is out of work for seven days or less, he will not receive worker's compensation wages. 11. The light duty job will continue until the employee is allowed to return to his pre-injury job. 3.10.4 Non-Work-Related Injuries
In the event an employee sustains an injury outside the workplace, prior to returning to their original position, the employee may be required to undergo a Fitness for Duty Physical Exam. This could also include a Functional Capacity Exam to ensure the employee is fully recovered and can perform their specific duties so as not to risk injury to themselves and others in the future. 3.11 Return to Work/Job Job Name: (Light Duty Return to Work/Job)
Job Description: (To be used in conjunction with physical job demands)
Duties include assisting the tool room manager, checking small tools and equipment in and out of tool room log, ordering replacement tools and equipment.
Job Salary: $8 per Hour / $320 per week Notes:
1. Job Purpose a. To assist tool room manager b. To help employee get back into the work routine through physician-approved light duty work while recovering c. To show the employer's concern for employee's job security 2. To Attending Physician a. Start Date: ______b. Hours: ______c. Full Time: ______Part Time: ______d. List any restrictions for walking, sitting, standing, lifting that you want to apply to this employee: ______
(Please print legibly)
e. Call the Safety Department (215-698-4499) if there is a status change.
REV2.1 February 13, 2018 Page 27 | 165 The Elliott-Lewis Safety Manual 4 Record-Keeping and Posting Requirements
4.1 Injury Log 1. An Injury Log must be maintained on each project for every reported injury, illness, and fatality. A sample log is included at Attachment A to this section of the Safety Manual. On projects where there is no temporary trailer or office where such a log can be maintained, the log will be maintained by the home safety office. 4.2 OSHA 300 Log 1. An OSHA 300 Log must be maintained to record work-related fatalities, injuries and illnesses that are defined as reportable to OSHA. They must be recorded on the log within seven calendar days of receiving information the injury occurred. 2. The criteria outlined below should be used to determine if an injury is reportable to OSHA. Use the OSHA 300 Log to record only those injuries defined as reportable to OSHA, as outlined below. Contact the home safety office if there is any difficulty making such a determination. On projects where there is no temporary trailer or office where such a log can be maintained, the log will be maintained by the home office.
Generally, injuries that should be recorded/reported include:
a. Injuries requiring any loss of more than one scheduled work day b. Injuries requiring restricted work (light-duty) for more than one scheduled workday c. Injuries treated off-site by a physician where: d. X-rays were positive for fracture(s) e. Sutures were required, or other mechanical wound closure f. Splinters were surgically removed (other than tweezers removal) g. Foreign bodies of the eye are surgically removed (embedded) or the eye is treated with a prescription healing agent h. Treatment of any second or third degree burn i. Hospital admission j. Any loss of consciousness due to injury
Generally, injuries that should not be recorded/reported include:
a. Injuries not treated off-site by a physician b. Injuries treated off-site by a physician that are only first aid treatments, as defined in attachment A c. Illnesses that are not occupational, such as the flu, unless the physician determines that the illness is work-related d. Treatment off-site where: e. Wounds were simply cleaned, examined and dressed without use of sutures other mechanical closures f. X-rays were negative for fracture(s) g. One-time medications were administered, including tetanus shots h. Splinters were removed by simple procedure (tweezers removal) i. Foreign bodies in the eye were irrigated out or removed by cotton tipped applicator 3. If there is any question regarding the ability to report of a particular injury, call the Safety Department for assistance. REV2.1 February 13, 2018 Page 28 | 165 The Elliott-Lewis Safety Manual 4. An OSHA 300A Summary is completed at the end of each work year. This summary totals the number of injuries, hours worked, and lost/restricted days. This document is signed by the highest ranking company official and is posted in a visible location for all employees to view each year from February 1 through April 30. 5. All recordkeeping forms must be maintained for five years. 4.3 Incident Report Form 1. An Incident Report Form must be completed by the superintendent responsible for the injured employee for each reported injury, as explained in Section 3.0 Accident Reporting, of this manual. 4.4 Report of Injury to Insurance Company / First Report of Injury 1. Each state requires a Notice of Injury to be filed with the state Department of Labor as well as the company insurer for any injury requiring treatment by a medical care provider outside of a company first aid station (also often called an Employer’s First Report of Injury). A required state form is used and requires personal and wage information not required for the company Incident Report Form. Each state form is different and is titled differently. 2. The state Notice of Injury must be completed by the designated safety monitor or the office manager for each injury that resulted in medical treatment. Do not use or distribute this form for injuries requiring simple on-site first aid where there was no treatment by an outside medical provider. 3. The Notice of Injury may be completed by the office manager using the information provided by the superintendent on the Incident Report Form. A full explanation of this report can be found in Section 3.0 ACCIDENT REPORTING in this manual. 4.5 Safety Records and Documentation
4.5.1 Training Attendance Records
The signed attendance sheets from the following training sessions should be maintained on-site as safety records. On sites without an established office or office manager to maintain such records, each original document should be forwarded to the Safety Director.
1. Safety Bulletin/Meeting Attendance Sheets 2. New Hire Orientation Attendance Sheets/Handout Receipts 3. Hazard Communication Training Attendance Sheets 4. Confined Space Entry 5. Excavation/Trenching Competent Person Training 6. Trenching and Excavating 4.5.2 Records Retention
At project completion, all safety related files and records should be boxed separately and delivered to the home office safety department.
Records retention varies, but generally, injury records, and health and safety records must be maintained for 30 years.
The following records should be retained by the project until project completion:
1. Safety Bulletins 3. New Hire Orientation Attendance Records 2. Safety Bulletin Attendance Sheets 4. Safety Booklet/Handout Receipts REV2.1 February 13, 2018 Page 29 | 165 The Elliott-Lewis Safety Manual 5. Hazard Communication Training Record 10. Confined Space Entry Log/Permits 6. Daily Project Self-Inspection Reports 11. Hazardous Material Inventory/Purchase Log 7. Injury Log 12. Crane Inspection Records 8. OSHA 300 Log 13. Disciplinary Records/Safety Warnings 9. Injury Records - Incident Report Form; 14. Trenching Protection Designs/Certifications Employers Report of Injury; Treatment Authorization Form; Return to Work Notices 4.5.3 Posting Required Notices
1. Certain notices must be posted in a conspicuous location where employees frequent, such as in change trailer. Each project shall establish as area where the following notices may be displayed. a. OSHA “Job Safety and Health” e. Hazard communication Notice b. State Workers Compensation f. Safety Posters - 'Herman' Series Notices Posters c. State Notices of "Right to Know" g. Training/Educational Posters Regulations h. Crane Signal Poster d. Emergency Evacuation Instructions (where applicable) 4.5.4 Hazardous Material Inventory/Location Log (Note: Bi-lingual posters may be available) 2. At job inception, each project will receive a copy of this manual with all necessary forms to document properly safety activities. This manual should remain on the project through to completion. 3. At job inception, each project will receive a copy of the OSHA Construction Safety Standards that must be kept on location. 4. Each project should have a separate binder marked “MSDS” for the Material Safety Data Sheets on the project. The Hazard Communication Program is incorporated in the Safety Manual. Keep the MSDS book with the Safety Manual. 4.5.6 Releasing Information and Records
1. Client representatives are permitted copies of the following only if required by contract. a. Incident Reports b. Employers First Report of Injury (Insurance Form) c. Project Inspection/Audit Records 2. Any other information requested by a client must be released from the home office. Contact the company Safety Director. 3. Craft Employees are permitted copies of their accident reports, exposure records or first aid records if the request is provided in writing. The request should be forwarded to the company Safety Director who will send a copy of the report to the employee. 4. Information concerning an accident or injury may not be given to any union representative, the press, or other contractor or government agent (such as OSHA) without permission from the Safety Director.
REV2.1 February 13, 2018 Page 30 | 165 The Elliott-Lewis Safety Manual 5 Employee Disciplinary Warnings
5.1 General Employee behavior is best controlled by a supervisor, as follows:
1. Continually provide positive reinforcement to the employees for exercising proper safety precautions, good housekeeping and personal compliance with personal protective equipment (i.e., hardhats, safety glasses, proper work clothes). 2. Provide a good project example by enforcing safety requirements equitably for all trades and all contractors.
Enforce safety rules through individual verbal warnings to employees and foreman, and by issuing written warnings for continued noncompliance, and finally, supporting disciplinary actions, such as suspending or terminating any employee for continued noncompliance.
OSHA imposes responsibility on the employer for enforcing safety rules. Documentation of warnings is an important part of our company's defense in case of an OSHA citation, injury or liability claim caused by an employee’s negligence. For non-compliance of safety rules, the Safety Director and Safety Coordinator will issue company safety citations for violations of company policies. It also the responsibility of supervisory personnel to perform physical inspections to ensure commitment to company safety goals and shall enact disciplinary action when appropriate. Although guidelines can be used to evaluate disciplinary action, each case must be evaluated individually based on the severity of the issue, and whether or not continued noncompliance has caused or may cause an accident. 5.2 Enforcement Guidelines 1. The employee's superintendent is primarily responsible for documenting and issuing employee warnings. Document verbal employee warnings in a project diary/daily log. Include any verbal instructions given to the employee. Incidents that warrant documentation include chronic tardiness or absenteeism, out of work area without permission, failure to follow instructions, etc. Be sure to copy or notify the project office manager of all written warnings. 2. If an employee continues to violate work rules following a verbal warning, a written warning should be issued to the employee. (A sample written warning can be found as Attachment A of this section) a. If, during a jobsite safety audit, the Safety Director or Safety Coordinator feels the need for action due to an employee disregarding company policies, an internal safety citation will be issued. This citation will document the employee’s name, violation, the supervisor’s name, and project manager’s name. This citation will be kept on file to maintain a history of offenses by the employees involved for later evaluation. When an employee reaches three safety offenses, an evaluation of the severity of the offenses will determine the future work status of the employee. 3. One copy of the citation will be given to the employee by the superintendent, a copy will be kept in the jobsite file, and one copy will go to the chief executive officer. If the employee is terminated or suspended as a result of the warnings, a copy of any warning slips issued to the employee should be copied and sent to the Project Office Manager, and the in-house payroll and safety offices. 4. Employees who are suspended or terminated for violation of work or safety rules may be included on the company ineligibility list to prevent hiring at other company projects. 5. The following guidelines are provided to assist you in determining appropriate disciplinary action for violation of work or safety rules:
REV2.1 February 13, 2018 Page 31 | 165 The Elliott-Lewis Safety Manual 5.3 Minor Violations 1. Failure to use protective equipment, such as safety glasses, hardhats or hearing protection 2. Violating signs 3. Excessive absenteeism or tardiness 4. Out of work area or off the project without permission 5. Failure to keep guards in place 6. Smoking or eating in a restricted area 7. Late returns from lunch or coffee breaks
First Violation - Verbal warning to employee. Notify employee's foreman. Warnings should be documented in diary.
Second Violation - Issue warning slip to employee. Notify employee's foreman and steward/craft representative. Advise employee of the consequences of repeated violations.
Third Violation - Issue second warning slip. Consider suspending the employee for one to five days without pay. Copy the warning slip and send copies to the in-house payroll and safety offices. Notify the Project Manager. Notify the employee's foreman and steward/craft representative.
Fourth Violation - The employee should be terminated for the length of the project. (Depending upon the severity of the violation and the productivity of the employee, the employee may be restricted from future employment with the Company) Issue a third warning slip. Notify the in-house payroll office and the Project Manager. Notify the employee's foreman and steward/craft representative. Attach warning slips to the termination notice.
Serious or Willful Violations:
1. Repeat failure to wear or tie-off a safety belt or harness 2. Repeat failure to perform work as directed 3. Creating an unsafe condition that injures or endangers another employee 4. Behavior or impairment similar to alcohol or drug use 5. Fighting, verbal or physical abuse of a supervisor 6. Repeated excessive absenteeism or tardiness (frequency to be determined by the project)
First Violation - Serious violations must be handled promptly and documented thoroughly, and should generally warrant suspension or termination. Repeat noncompliance should have been documented previously through verbal and written warnings.
1. Issue a Warning Notice to the employee that thoroughly describes the circumstances and seriousness of the violation. 2. Recommended disciplinary action for serious violations is immediate suspension or termination of the employee for the length of the project. (The employee will be added to the ineligibility list and will not be eligible for re-hire during the suspension period.) 3. Notify the employee's steward/craft representative, the employee's foreman, client representative and the Project Manager.
REV2.1 February 13, 2018 Page 32 | 165 The Elliott-Lewis Safety Manual 6 Substance Abuse Policy
Elliott-Lewis Corporation is committed to maintaining a safe workplace and to providing dependable services to its clients and customers. Successful attainment of these goals is directly dependent upon the establishment and maintenance of a workplace that is free from the adverse effects of drug use and alcohol misuse. Consistent with these goals, it is strictly prohibited for any employee:
1. To use, possess, distribute, purchase, introduce, sell, traffic or be under the influence of alcohol, illegal drugs or controlled substances while (a) on Company premises or in Company vehicles at any time, whether or not engaged in Company business, or (b) engaged in Company business anywhere, including off Company property. 2. To in any way use Company property or an employee’s position within the Company to make, distribute, purchase, introduce, sell or traffic in illegal drugs or controlled substances. 3. To be convicted of a felony attributable to the use, possession, or sale of illegal drugs or controlled substances on or off Company property.
The legal use of prescribed drugs is permitted on the job only if it does not impair an employee's ability to perform the essential functions of the job effectively and/or in a safe manner. Any employee who is taking a drug or medication, whether or not prescribed by the employee’s physician, which may adversely affect that employee’s ability to perform work in a safe or productive manner (including but not limited to any task which may cause harm to the employee or other employees), is required to report such use of medication to his or her supervisor or manager. This includes drugs which are known or advertised as possibly affecting judgment, coordination, or any of the senses, including those drugs that may cause drowsiness or dizziness. The supervisor, in conjunction with the Human Resources department, will determine whether the team member can remain at work and whether any work restrictions are necessary.
An employee may be required to submit to drug and/or alcohol testing whenever there is reason to believe, because of physical, behavioral or performance indicators, that the employee is under the influence of illegal drugs and/or alcohol while on the Company's premises or while on duty. In addition, any employee who is involved in an accident for which a person seeks outside medical treatment, or which results in property damage, will be required by the Company to submit to a drug and/or alcohol test.
As a condition of employment, all employees must submit to pre-employment, post-accident, reasonable suspicion and random drug and/or alcohol testing. The new hire drug testing will occur prior to the first day of employment. All active employees are subject to post-accident, reasonable suspicion and random drug and/or alcohol testing.
An employee who refuses to provide a specimen at the date and time requested for testing, refuses to provide written consent to testing as may be required, provides an adulterated, substituted or invalid specimen, or refuses to consent to a search of his or her person, possessions, work area, or vehicle when requested, shall be subject to immediate discharge.
Violations of this policy, including a positive test result on a drug and/or alcohol test, may lead to disciplinary action, up to and including immediate termination of employment.
The President or COO may waive, with prior notification and approval, the prohibition with respect to the use of alcohol with respect to events sponsored by the company or held on company property.
LEGAL/109718889.v1 REV2.1 February 13, 2018 Page 33 | 165 The Elliott-Lewis Safety Manual 7 DOT Drug and Alcohol Policy
Elliott-Lewis is dedicated to the health and safety of our employees. Drug and/or alcohol use may pose a serious threat to driver health and safety. Therefore, it is the policy of Elliott-Lewis to prevent the use of drugs and abuse of alcohol from having an adverse effect on our drivers.
The serious impact of drug use and alcohol abuse has been recognized by the federal government. The Federal Motor Carrier Safety Administration (FMCSA) under the direction of the Department of Transportation (DOT) has issued regulations which require the company to implement an alcohol and controlled substances testing program.
The purpose of the FMCSA-issued regulations is to establish programs designed to help prevent accidents and injuries resulting from the misuse of alcohol or use of controlled substances by drivers of commercial motor vehicles.
We at Elliott-Lewis will comply with these regulations and are committed to maintaining a drug-free workplace.
It is the policy of Elliott-Lewis that the use, sale, purchase, transfer, possession, or presence in one's system of any controlled substance (except medically prescribed drugs) by any driver while on the company premises, engaged in company business, operating company equipment, or while under the authority of Elliott-Lewis is strictly prohibited. Disciplinary action will be taken as necessary.
Neither this policy nor any of its terms are intended to create a contract of employment or contain the terms of any contract of employment. The company retains the sole right to change, amend, or modify any term or provision of this policy without notice. This policy is effective 2/21/17 and will supersede all prior policies and statements relating to alcohol or drugs. 7.1 Requirements and Responsibilities Regulatory requirements -All drivers who operate commercial motor vehicles that require a commercial driver's license under 49 CFR Part 383 are subject to the FMCSA's drug and alcohol regulations, 49 CFR Part 382.
Non-regulatory requirements -The Federal Motor Carrier Safety Regulations (FMCSRs) set the minimum requirements for testing. Elliott-Lewis’s policy in certain instances may be more stringent. This policy will clearly define what is mandated by the FMCSRs and what Sautter Cranes procedure is.
Who is responsible -It is Elliott-Lewis’s responsibility to provide testing for the driver to ensure they are in compliance with all federal and state laws and regulations, and within the provisions of this policy. We will retain all records related to testing and the testing process in a secure and confidential matter.
The driver is responsible for complying with the requirements set forth in this policy. The driver will not use, have possession of, abuse, or have the presence of alcohol or any controlled substance while on duty.
All supervisors must make every effort to be aware of a driver's condition at all times the driver is in service of the company. The supervisor must be able to make reasonable suspicion observations to determine if the driver is impaired in some way, and be prepared to implement the requirements of this policy if necessary. 7.2 Definitions Adulterated specimen-a urine specimen containing a substance that is not a normal constituent or containing an endogenous substance at a concentration that is not a normal physiological concentration.
REV2.1 February 13, 2018 Page 34 | 165 The Elliott-Lewis Safety Manual Alcohol concentration (or content)-the alcohol in a volume of breath expressed in terms of grams of alcohol per 210 liters of breath as indicated by an evidential breath test.
Alcohol screening device (ASD)-a breath or saliva device, other than an evidential breath testing device (EBT) that is approved by the National Highway Traffic Safety Administration (NHTSA) and placed on a conforming products list (CPL) for such devices.
Collection site-a place designated by the company, where individuals present themselves for the purpose of providing a urine specimen for a drug test.
Commercial motor vehicle-a motor vehicle or combination of motor vehicles used in commerce to transport passengers or property if the motor vehicle:
• Has a gross combination weight rating of 26,001 or more pounds (11,794 or more kilograms) inclusive of a towed unit with a gross vehicle weight rating of more than 10,000 pounds (4,536 kilograms); or • Has a gross vehicle weight rating of 11,794 or more kilograms (26,001 or more pounds); or • Is designed to transport 16 or more passengers, including the driver; or • Is of any size and is used in the transportation of materials found to be hazardous for the purposes of the Hazardous Materials Transportation Act and which require the motor vehicle to be placarded under the Hazardous Materials Regulations (49 CFR Part 172, subpart F).
Confirmatory drug test-a second analytical procedure to identify the presence of a specific drug or metabolite which is independent of the initial test and which uses a different technique and chemical principle from that of the initial test in order to ensure reliability and accuracy. (Gas chromatography/mass spectrometry (GC/MS) is the only authorized confirmation method for cocaine, marijuana, opiates, amphetamines, and phencyclidine).
Confirmatory validity test-a second test performed on a different aliquot of the original urine specimen to further support a validity test result.
Controlled substances-those substances identified in 49 CFR, Section 40.85. In accordance with FMCSA rules, urinalyses will be conducted to detect the presence of the following substances:
• Marijuana • Opiates • Phencyclidine (PCP). • Cocaine • Amphetamines Detection levels requiring a determination of a positive result shall be in accordance with the guidelines adopted by the FMCSA in accordance with the requirements established in 49 CFR, Section 40.87.
Designated employer representative (DER)-is an individual identified by the employer as able to receive communications and test results from service agents and who is authorized to take immediate actions to remove drivers from safety-sensitive duties and to make required decisions in the testing and evaluation processes. The individual must be an employee of the company. Service agents cannot serve as DERs.
Dilute specimen-a urine specimen with creatinine and specific gravity values that are lower than expected for human urine.
Direct observation-means the observer must request the employee to raise his or her shirt, blouse, or dress/skirt, as appropriate, above the waist; and lower clothing and underpants to show, by turning around, that he/she does not have a prosthetic device. After observer has determined that the employee does not have such a device, he/she may permit the employee to return clothing to its proper position for observed urination.
REV2.1 February 13, 2018 Page 35 | 165 The Elliott-Lewis Safety Manual Disabling damage-damage that precludes departure of a motor vehicle from the scene of the accident in its usual manner in daylight after simple repairs.
Driver-means any person who operates a commercial motor vehicle. This includes, but is not limited to: full time, regularly employed drivers; casual, intermittent or occasional drivers; leased drivers and independent, owner- operator contractors who are either directly employed by or under lease to an employer or who operates a commercial motor vehicle at the direction of or with the consent of an employer.
Evidential breath testing device (EBT)-a device approved by the National Highway Traffic Safety Administration (NHTSA) for the evidential testing of breath at the 0.02 and 0.04 alcohol concentrations, placed on NHTSA's Conforming Products List (CPL) for "Evidential Breath Measurement Devices'' and identified on the CPL as conforming with the model specifications available from NHTSA's Traffic Safety Program.
FMCSA-Federal Motor Carrier Safety Administration, U.S. Department of Transportation.
Initial drug test (also known as a Screening drug test)-an immunoassay test to eliminate “negative” urine specimens from further consideration and to identify the presumptively positive specimens that require confirmation or further testing.
Initial validity test-the first test used to determine if a urine specimen is adulterated, diluted, or substituted.
Invalid result-the result reported by a laboratory for a urine specimen that contains an unidentified adulterant, contains an unidentified interfering substance, has an abnormal physical characteristic, or has an endogenous substance at an abnormal concentration that prevents the laboratory from completing testing or obtaining a valid drug test result.
Licensed medical practitioner-a person who is licensed, certified, and/or registered, in accordance with applicable federal, state, local, or foreign laws and regulations, to prescribe controlled substances and other drugs.
Medical Review Officer (MRO)-is a person who is a licensed physician (Doctor of Medicine or Osteopathy) and who is responsible for receiving and reviewing laboratory results generated by the company's drug testing program and evaluating medical explanations for certain drug test results.
Non-negative specimen-a urine specimen that is reported as adulterated, substituted, positive (for drug(s) or drug metabolite(s)), and/or invalid.
Performing (a safety-sensitive function)-a driver is considered to be performing a safety-sensitive function during any period in which he or she is actually performing, ready to perform, or immediately available to perform any safety-sensitive functions.
Prescription medications-the use (by a driver) of legally prescribed medications issued by a licensed health care professional familiar with the driver's work related responsibilities.
Refuse to submit (to an alcohol or controlled substances test)-a driver:
1. Fails to appear for any test (except pre-employment) within a reasonable time, as determined by the company, consistent with applicable DOT regulations, after being directed to do so by the company. This includes the failure of a driver (including an owner-operator) to appear for a test when called by a C/TPA; 2. Fails to remain at the testing site until the testing is complete (except pre-employment if the driver leaves before the testing process begins); 3. Fails to provide a urine specimen for any DOT required drug test (except pre-employment if the driver leaves before the testing process begins); REV2.1 February 13, 2018 Page 36 | 165 The Elliott-Lewis Safety Manual 4. In the case of a directly observed or monitored collection in a drug test, fails to permit the observation or monitoring of the driver's provision of the specimen; 5. Fails to provide a sufficient amount of urine when directed, and it has been determined, through a required medical evaluation, that there was no adequate medical explanation for the failure; 6. Fails or declines to take a second test the employer or collector has directed the driver to take; 7. Fails to undergo a medical examination or evaluation, as directed by the MRO as part of the verification process, or as directed by the DER (In the case of a pre-employment drug test, the employee is deemed to have refused to test on this basis only if the pre-employment test is conducted following a contingent offer of employment); 8. Fails to cooperate with any part of the testing process (e.g., refuse to empty pockets when directed by the collector, behave in a confrontational way that disrupts the collection process, fail to wash hands after being directed to do so by the collector). 9. For an observed collection, fails to follow the observer’s instructions to raise his/her clothing above the waist, lower clothing and underpants, and to turn around to permit the observer to determine if he/she has any type of prosthetic or other device that could be used to interfere with the collection process. 10. Possesses or wears a prosthetic or other device that could be used to interfere with the collection process. 11. Admits to the collector or MRO that he/she adulterated or substituted the specimen. 12. Is reported by the MRO as having a verified adulterated or substituted test result.
Safety-sensitive function-all time from the time a driver begins to work or is required to be in readiness to work until the time he/she is relieved from work and all responsibility for performing work. Safety-sensitive functions include:
• all time at an employer or shipper plant, terminal, facility, or other property, or on any public property, waiting to be dispatched, unless the driver has been relieved from duty by the company; • all time inspecting equipment as required by Secs. 392.7 and 392.8 or otherwise inspecting, servicing, or conditioning any commercial motor vehicle at any time; • all time spent at the driving controls of a commercial motor vehicle in operation; • all time, other than driving time, in or upon any commercial motor vehicle, except time spent resting in a sleeper berth (a berth conforming to the requirements of Sec. 393.76); • all time loading or unloading a vehicle, supervising, or assisting in the loading or unloading, attending a vehicle being loaded or unloaded, remaining in readiness to operate the vehicle, or in giving or receiving receipts for shipments loaded or unloaded; and • all time repairing, obtaining assistance, or remaining in attendance upon a disabled vehicle.
Substituted Specimen-a urine specimen with creatinine and specific gravity values that are so diminished or so divergent that they are not consistent with normal human urine. 7.3 Alcohol and Drugs Alcohol-Part 382, Subpart B, prohibits any alcohol misuse that could affect performance of safety-sensitive functions.
• use while performing safety-sensitive functions; • use during the 4 hours before performing safety-sensitive functions; • reporting for duty or remaining on duty to perform safety-sensitive functions with an alcohol concentration of 0.04 or greater; • use of alcohol for up to 8 hours following an accident or until the driver undergoes a post-accident test; or REV2.1 February 13, 2018 Page 37 | 165 The Elliott-Lewis Safety Manual • refusal to take a required test.
NOTE: Per FMCSA regulation (Sec. 382.505), a driver found to have an alcohol concentration of 0.02 or greater but less than 0.04 shall not perform, nor be permitted to perform, safety-sensitive functions until the start of the driver's next regularly scheduled duty period, but not less than 24 hours following administration of the test.
Drug-Part 382, Subpart B, prohibits any drug use that could affect the performance of safety-sensitive functions. This drug prohibition includes:
• use of any drug, except when administered to a driver by, or under the instructions of, a licensed medical practitioner, who has advised the driver that the substance will not affect the driver's ability to safely operate a commercial motor vehicle. • testing positive for drugs; or • refusing to take a required test. 7.4 Circumstances for testing Pre-employment
1. In accordance with §382.301, all driver applicants will be required to submit to and pass a urine drug test as a condition of employment. 2. Driver applicant drug testing shall follow the collection, chain-of-custody, and reporting procedures set forth in 49 CFR Part 40. 3. A pre-employment alcohol test will also be conducted as part of the pre-hire employment process. All pre-employment alcohol tests will follow the alcohol testing procedures outlined in 49 CFR Part 40. 4. The pre-employment alcohol test will be conducted in conjunction with the drug screen. An individual may not begin performing work duties until he/she has received a test result that indicates an alcohol concentration of less than 0.04.
Reasonable suspicion testing
1. If the driver's supervisor or another employee believes a driver is under the influence of alcohol or drugs, the driver will be required to undergo a drug and/or alcohol test. 2. The basis for this decision will be specific, observations concerning the appearance, behavior, speech, or body odors of the driver. 3. The driver's supervisor or fellow employee will immediately ask the driver to not drive his/her vehicle. The safety department must then be notified of the situation to make arrangements for the driver to be taken to a testing facility. 4. Per FMCSA regulation, reasonable suspicion alcohol testing is only authorized if the observations are made during, just preceding, or after the driver is performing work activities. 5. Per FMCSA regulation, if the driver tests 0.02 or greater, but less than 0.04, for alcohol the driver will be removed from driving a commercial motor vehicle, until the start of the driver's next regularly scheduled duty period, but not less than 24 hours following administration of the test. a. If an alcohol test is not administered within two hours following a reasonable suspicion determination, the safety department will prepare and document a record with reasons why the test was not able to be administered. 6. An Elliott-Lewis Witness Statement of the observations leading to an alcohol or controlled substance reasonable suspicion test, signed by the supervisor or by the employee who made the observation, will be completed after the observed behavior.
REV2.1 February 13, 2018 Page 38 | 165 The Elliott-Lewis Safety Manual Post-accident testing
1. Drivers are to notify the Safety Department as soon as possible if they are involved in an accident. 2. According to FMCSA regulations the driver will be tested for drugs and alcohol as soon as possible following the accident. The driver must remain readily available for testing. If the driver isn't readily available for alcohol and drug testing, he/she may be deemed as refusing to submit to testing. A driver involved in an accident may not consume alcohol for 8 hours or until testing is completed. a. If the alcohol test is not administered within 2 hours following the accident the safety department will document and maintain a record stating why the test was not administered within two hours. If the employee was not able to take the post-accident drug and alcohol screen before 32 hours after the incident, all attempts will stop. This will be documented, along with the reasons why the test was not administered.
Random Testing
1. The FMCSA Administrator's decision to increase or decrease the minimum annual percentage rate for alcohol and controlled substances testing is based on the reported violation rate for the entire industry. All information used for this determination is drawn from the management information system reports required by §382.403 for two consecutive calendar years. At this time, the company is doing testing on a minimum of 25% for all driver positions. The testing will be unannounced and will be spread reasonably throughout the calendar year. a. The company requires that each driver who is notified of selection for random testing proceeds to the test site immediately; provided, however, that if the driver is performing a safety-sensitive function, other than driving a commercial motor vehicle, at the time of notification, the company shall instead ensure that the driver ceases to perform the safety-sensitive function and proceeds to the testing site as soon as possible. 7.5 Fit for Duty In order to provide a safe work environment, employees must be able to perform their job duties in a safe, secure, productive, and effective manner, and remain able to do so throughout the entire time they are working. Employees who are not fit for duty may present a safety hazard to themselves, to other employees, to the facilities, or to the public.
The purpose of this policy is to establish procedures by which the managers, supervision, and HR department will evaluate an employee’s fitness for duty when an employee is:
1. Having observable difficulty performing work duties in a manner that is safe for the employee, for the employee’s coworkers, for the University, or for the public, as determined by the supervisor; or 2. Posing an imminent and serious safety threat to self or others. 3. Pre-employment physicals during the hiring process, and also when changing into certain job functions and different environments. 4. Employees must be responsible for ensuring they are physically and mentally fit to perform their job functions safely. Employees must take responsibility for their own safety as well as not reporting to work in a condition as to endanger the safety of their fellow workers.
REV2.1 February 13, 2018 Page 39 | 165 The Elliott-Lewis Safety Manual 8 Safety Training and Employee Education
8.1 Employee New-Hire Orientation 1. Each employee shall receive an orientation/indoctrination upon hire. The orientation is designed to provide the employee with information about the company work rules and safety requirements as well as emergency procedures specific to a project. OSHA requires employers to provide basic safety education to employees on a continuing basis. The orientation outline (included as Attachment B to this section of the Safety Manual) contains the minimum basic information needed to comply with the training requirements and the requirements of the Hazard Communication Training. The orientation is outlined to take approximately eight hours. The orientation topics include: a. Project emergency information n. Hot work/weld permits, site-specific, b. Injury reporting instructions when applicable c. Minimum clothing requirements o. Electrical safety awareness training d. Availability of safety equipment p. Blood borne pathogen awareness e. Basics of fall protection including fall training arrest and fall restraint, the q. Ladder safety importance of guardrails, hazard r. Motor vehicle safety warning lines, floor opening covers, s. Mine safety, where applicable proper scaffold construction and t. Job hazard analysis proper wearing and use of u. Proper lifting techniques equipment v. Importance of reporting near misses f. Importance of housekeeping w. Hazardous communication/GHS g. Reporting unsafe conditions right to know training, including: h. Drug and alcohol prohibition i. Location and purpose of i. General project work rules material safety data sheets j. Safety rule enforcement ii. Location and use of any toxic k. Employee responsibility for safety project chemicals l. Safety during crane operations iii. Use and availability of m. High hazard operations, trenching or protective equipment confined spaces, where applicable
2. The orientation should be presented by the project safety monitor/representative, a foreman, or a superintendent. 3. A Company handout of general safety rules and site-specific rules will be provided by the company safety department and should be distributed during the orientation. 4. An attendance sheet must be signed by the employees to document the New Hire Orientation Training. The completed attendance sheet should be kept in the jobsite files as part of the project safety records. 5. The orientation process may be waived for any employee who was hired by the Company within six months on the same project. 8.2 Foreman Orientation 1. Each foreman shall receive an orientation from their superintendent or the project safety monitor/representative within one work day following their promotion. The foreman orientation is an important part of controlling unsafe conditions and unsafe acts in the field through recognition by a supervisor. REV2.1 February 13, 2018 Page 40 | 165 The Elliott-Lewis Safety Manual 2. A Foreman Orientation Outline is included as Attachment D to this section of the Safety Manual. The Orientation Outline may be copied and given to the foreman as guidelines. The last page of the outline should be signed by the foreman and kept as part of the project safety records.
Note: Foremen who are not willing to assume the responsibilities found in the outline should not be considered qualified as foreman candidates. 8.3 Project Safety Meeting 1. All craft employees are required to attend a periodic (Tool Box) safety meeting. On most projects, the meeting will be weekly. The periodic safety meeting satisfies OSHA's requirement for continuing safety education in construction. 2. The meeting may be held at any time at the discretion, and can be presented by a crew foreman, the project safety monitor or a superintendent and generally takes 8-10 minutes. 3. During the meeting, the attendance sheet should be signed by the employees. Any other topics of discussion should be listed on the attendance sheet, as well as any safety problems. Be sure to include what corrective action was taken on problems reported during the meeting. 8.4 Superintendent Training 1. Each superintendent that is assigned field supervision responsibilities will receive a copy of the Company Safety Manual and will be given the opportunity to review the manual with the company Safety Director. The superintendent will be expected to comply with the requirements of the manual and contact the Project Superintendent, the Project Manager or the company Safety Director for assistance in resolving safety problems not covered in the manual. 2. Several times each year, the Safety Director shall arrange for continuing education through bulletins, memorandums, seminars or in-house training sessions. 8.5 Right to Know/Hazardous Substances and GHS Training 1. Training will be provided each year to the active employees of the Company projects to satisfy the requirements of OSHA and the State, and will be provided by the Safety Department. 2. Special training may be required for those employees who must work with, or who are exposed to hazardous substances. The training must be provided before the work operation by the company Safety Department at the request of the Project Superintendent. 3. The Project Superintendent should notify the company Safety Director in advance of any of the following operations for assistance in providing appropriate protective equipment: a. Bulk Chemical Solvent Use g. Epoxy Paint Mixing or Application b. Sandblasting h. Confined Space/Tank Welding c. Acid Etching i. Cadmium Welds or other welding d. Chemical Flushes j. Bulk use of any chemical product e. Suspended Asbestos Insulation material containing Cadmium f. Use of Polyurethane Coatings
8.6 Special Operations Training 1. Employees involved in certain special operations shall receive brief instructions before the operation begins. 2. Special Operations training can be given by the foreman, superintendent or project safety monitor.
REV2.1 February 13, 2018 Page 41 | 165 The Elliott-Lewis Safety Manual 3. An outline should be prepared for special operations training and attendance should be taken during the training. Contact the company Safety Department for assistance in developing special operations outlines. 4. Special Operations include: a. Entry into asbestos removal areas d. Confined space entry b. Hazardous material/substance use e. Use of air supplied respirators c. Use of crane suspended work cages f. Purging or venting of gase
8.7 Short Service Employees 1. The purpose of the Short Service Employee (SSE) Management program is to prevent work related injuries and illnesses to new hires and temporary workers. The Short Service Employee (who is covered under the short service employee program) is an employee or sub-contractor employee with less than six months’ experience in the same job or with his/her present employer. 2. Our supervisors and co-workers must be able to readily identify Short Service Employee participants. Elliott-Lewis Corporation will assign experienced employees to oversee the daily activities of those assigned to the SSE program. They may not work alone during their employment. They will be assigned a mentor who is an experienced employee to help and work with the new employee. 3. Short Service Employees must be identified with their company ID as a short service employee. Host facilities must be notified that an SSE will be working on their site. 4. Elliott-Lewis Corporation shall monitor its employees, including SSE personnel, for HES awareness. If, at the end of the six-month period, the SSE has worked safely, adhered to HES policies and has no recordable incident attributable to him/her, the SSE identifier may be removed at the discretion of Elliott- Lewis Corporation. 5. If sub-contractors do not have their own SSE policy or it is not as stringent as ours, they must adhere to Elliott-Lewis Corporation’s SSE Management Program 8.8 Behavior Based Safety The behavior based safety program is a proactive element of safety program. Elliott-Lewis believes the key to eliminating workplace incidents, injuries and illnesses is to modify employee behavior reducing unsafe acts and conditions and increasing safe work practices and habits. Our objective is to pursue this goal by observing employees as they work and talk with them to encourage safe work practices and eliminate at-risk behaviors. Thus, preventing the unsafe conditions/unsafe act from manifesting and becoming an issue.
Participation- Everyone in the company has a clear responsibility for safety and is expected to practice the “highest degree of safety.” This program is designed to help us change attitudes and behaviors so that safety becomes part of the standard operating procedure and is widely valued across all departments and locations. The Safety department will provide and communicate all information and data; so that everyone has a clear understanding of accident causes, trends to address, and correct.
Training - All field employees and direct supervision shall be trained in behavior based safety program techniques. Training for this program will include the following components:
1. How to properly conduct a behavior based safety observation 2. How to complete the observation form. 3. What different behaviors indicate 4. How to conduct feedback sessions. 5. Employees should be informed that they may be observed at any time during their shift. REV2.1 February 13, 2018 Page 42 | 165 The Elliott-Lewis Safety Manual 6. Feedback - Information developed from analysis of observations shall be shared 7. with employees to help improve safe work behaviors and eliminate at-risk 8. behaviors
Responsibilities
Safety Department – is responsible for the following:
1. Ensure that the behavior based safety program is effectively implemented and that the program is reviewed and revised as necessary. 2. Provide training for all users of the behavior based safety program. 3. Provide leadership and support for employees in communicating their responsibility to stop the work when observing unsafe behaviors or unsafe conditions. 4. Provide resources to implement and maintain a behavior based safety program. 5. Observe employees for at risk behaviors and conditions while they are preforming work tasks. Provide feedback on the behaviors to the employees observed. a. Upon completion of an observation, the observer will have a discussion with the observed to get feedback. i. Review the observation with observed employee ii. Start with a positive comment on the correct/safe actions iii. Reinforce safe behaviors observed. iv. Describe any unsafe acts or conditions observed and discuss them with the observed employee. v. Ask observed employee explanation of their unsafe behavior with open-ended questions vi. Re-emphasize no consequence to observed employee. 6. The safety department, safety committee, and the company as a whole will review the data collected. the data collected and results will be tracked to show trends in cultural acceptance of at risk behaviors. These results, known as a trend analysis will be graphed so that numerical and statistical comparisons can be made over time. 7. With the data collected and graphed from the trend analysis, an action plan will be developed to address the unsafe behaviors reviled from the data. The action plan will contain: a. A prioritized list of the most at risk behaviors first, and descending to the least at risk behaviors b. Develop a plan to address the unsafe behaviors c. Establish focus group for action planning. d. Ensure all upper level management has complete back for the behavior based safety initiatives e. Assign tasks to accomplish, duties, and specific timeframe to management and supervision to complete.
Field Supervision – Supervision is responsible for the following:
1. Understand and enforce the behavior based safety program and policy. 2. Participate in performing behavior based safety observations. 3. Evaluate and provide feedback to other participants. 4. Develop corrective action plan to prevent recurrence of unsafe behaviors. 5. Inform employees that they may be observed at any time during a shift.
Employees – Employees are responsible for the following:
1. Stop unsafe behaviors and take action to prevent recurrence.
REV2.1 February 13, 2018 Page 43 | 165 The Elliott-Lewis Safety Manual 2. Participate in observations by providing meaningful feedback to observers when questioned about work procedures, behaviors, and job site conditions.
Behavior Guidelines Positive Safety Behaviors
1. Changing the way, you usually do your job to a safer method. 2. 2Reminding co-workers about taking safety precautions. 3. Consistently wearing your personal protective equipment 4. Consistently using safety program procedures and safe work practices. 5. Reminding co-workers that they should be wearing personal protective equipment or using safe work practice (especially when they observe an unsafe behavior). 6. Providing feedback to supervisors that some employees are not following safety procedures or wearing their personal protective equipment.
Negative Safety Attitudes and Behaviors
1. Not wearing personal protective equipment or using general safety equipment. 2. Not following safety procedures or safe work practices (welding procedures, lockout-tagout, tractor safety, ladder safety, lifting/back safety). This includes taking shortcuts. 3. Having a negative attitude. Negative attitudes have been clearly established as a cause of unsafe behaviors. Negative attitudes and unsafe behaviors are considered unacceptable as they usually lead to an unsafe work culture and higher accident rate.
9 Jobsite Inspections
9.1 Self-Inspection Program 1. Each project designated by the Safety Director will participate in a daily inspection program. The project superintendent is responsible for ensuring that the program is initiated and the project safety monitor will ensure that the inspection checklist is completed properly and distributed as directed. 2. The daily inspection program utilizes a compliance checklist. Each day, the safety monitor, or other knowledgeable person designated by the project superintendent, inspects an area of the project using the checklist as a guide. 3. The inspector should be empowered by the project superintendent to direct foreman to make corrections of common safety violations. The project Safety Monitor should make a daily punch list for submittal to the Project Superintendent. The project Safety Monitor should be empowered to suspend temporarily an operation where there is an imminent danger to employees. 4. Each week, the original completed Inspection from should be signed by the project superintendent and forwarded to the home office Safety Department. a. Note: Keep the second copy on file on the project as evidence of our participation in a continuing inspection program. 5. Certain special operations may require a daily or periodic inspection as follows: a. Confined space entry b. Asbestos exposure c. Chemical handling REV2.1 February 13, 2018 Page 44 | 165 The Elliott-Lewis Safety Manual d. Trench entry e. Crane suspended work cage use f. Assured electrical grounding program g. Respirator use in toxic atmospheres 9.2 Safety Audits 1. A member from the Safety Department will audit active projects as needed to ensure compliance with the company safety program. During the audit, the self-inspection checklists, injury records, Hazard Communication Program and field conditions will be surveyed for compliance. 2. Following the audit, a punch list of items will be left for correction. Imminent danger hazards will be immediately brought to the attention of supervision for correction. Other items will be listed for correction on the audit report. 3. As part of the audit, each project will be graded based on conditions and compliance. A copy of the audit will be distributed to the responsible Project Manager, Division Manager and company President. 4. The company Safety Director may choose to suspend temporarily an operation due to an imminent danger situation or other hazardous condition which has not been corrected and continues to pose a threat to employees. 5. The results of all safety audits will be distributed to the project manager, appropriate Vice President and the Company President. 9.3 OSHA Inspections 1. The Safety Director must be notified immediately whenever a Compliance Officer from the Occupational Safety and Health Administration (OSHA) seeks permission to inspect a Company jobsite. Do not allow the Compliance Officer to walk around the jobsite. The Safety Director will come to the site and accompany the officer. 2. An OSHA Compliance Officer (CO) may seek permission to inspect a jobsite for a regularly scheduled inspection or as part of an investigation of an employee complaint. 3. Always cooperate with a CO, within the guidelines established in this manual. 4. Upon arrival of a Compliance Office, the project manager or project superintendent should: a. Verify the CO credentials. Make sure the credentials are current. Obtain a business card from the CO, and record the time that the CO arrived on the project. b. Determine why the CO wants to inspect the project. This will be down in an opening conference meeting with all parties involved. i. The opening conference will establish the parameters of the inspection. Attendance by subcontractor representatives and a company employee representative must be included in the opening conference. The company employee representative(s) is usually a craft steward c. There are generally two reasons for an inspection; a regularly scheduled inspection or an employee complaint. Determining the reason for the inspection is important. Inspections based on a complaint are restricted to the complaint. A general walk-around is generally not permitted. d. If the CO is at the project due to an employee complaint, ask for a copy of the OSHA complaint form. e. Do not allow the inspection to proceed without notifying the Safety Director or a Divisional Manager. f. Notify subcontractor representatives that the project is about to be inspected. Subcontractors working in areas are subject to inspection as well, and are entitled to join the opening conference.
REV2.1 February 13, 2018 Page 45 | 165 The Elliott-Lewis Safety Manual g. Be cooperative and professional with a CO. Do not argue with a CO. Make an attempt to correct any observed violations immediately during the inspection. Be sure the CO documents that corrective action was taken. h. The CO is permitted to look only at certain records, such as the Injury Logs (OSHA 300 or 301 form). i. The CO should not be given copies of any Company records without permission from the Safety Director. j. During the inspection, employees must not perform or demonstrate any unsafe act to recreate an incident. Example: An employee may not climb an incomplete scaffold to show the CO where they were working. k. In the absence of the Safety Director or a site safety representative, comprehensive notes must be taken of all activities and approximate times. l. If the CO takes photographs, try to take identical photographs. m. Before the CO leaves the jobsite, make sure all questions have been answered by the CO and any potential violations found have been fully explained. Be sure any corrective actions already taken are noted by the CO. 9.4 Risk Assessment/Job Hazard Analysis Our Job Hazard Analysis Program is a formal process of analyzing all tasks to identify as many hazards as possible and determine how to address those hazards so that affected workers can safely complete the job. The process includes the evaluation of the job itself, including the affected workers, tools, materials, equipment, and anything else that could impact the safety of those who will be performing the job. The hazard identification process should be used for routine and non-routine activities as well as new processes, changes in operation, products or services as applicable. Safe work procedures are then developed and incorporated into the job process.
All employees, supervisors, foremen, project managers, and subcontractors shall be trained to proactively identify, evaluate, and control hazards throughout the course of their work.
Identify the jobs that require hazard analysis:
1. Begin by determining whether an upcoming job contains one or more potentially hazardous steps by asking yourself the questions below, which represent common hazards in the mechanical construction industry. These questions do not cover every conceivable hazard that you may need to consider, but they do cover our industry’s most common hazards. 2. Could an affected worker experience a fall from an elevation that could result in fractures, contusions, lacerations, loss of consciousness, or death? 3. Could an affected worker be struck by or against an object that could result in crushed body parts, fractures, or loss of consciousness? 4. Could an affected worker get caught in an excavation cave-in? 5. Could an affected worker be exposed to energized electrical conductors? 6. Will the job involve the manual handling of particularly heavy or bulky objects which could result in a back injury, a hernia, a shoulder injury, or a laceration to a worker’s hand? 7. Has a normally routine job become non-routine due to weather, scheduling changes, equipment problems, or similar circumstances? 8. Once you have determined the hazards, those hazards shall be classified or ranked in severity. The following is a guideline for ranking hazards by severity:
REV2.1 February 13, 2018 Page 46 | 165 The Elliott-Lewis Safety Manual Score 1 Minor Will not cause injury/illness Score 2 Marginal May cause minor injury/illness Score 3 Critical May cause severe injury/illness Score 4 Catastrophic May cause death 9. To develop a Risk Assessment/JHA for the project perform the following: a. Examine job components for each potentially hazardous job. b. Identify and record the hazards associated with each job component by considering whether a worker performing the job could fall to a lower level, be struck by or struck against a large or heavy object, get caught in an excavation cave-in, be exposed to an energized electrical conductor, or become overexposed to another health hazard. Be sure to consider any factors that could make a typical job step a hazardous one, such as changes in weather conditions or project plans. c. Record the potential hazards associated with the job components. For example, a worker on a ladder could be exposed to a potential fall from the ladder. The job component would be the ladder. One of the hazards would be the fall. Another example would be a worker preparing to perform electric arc welding. The job component would be electric arc welding. One of the hazards would be electric shock. d. Once you have identified the hazards for each of the job components assign safe work procedures to each job component. The goal is to mitigate all hazards. However, not all hazards can be engineered out of the task. This is when safe work practices and proper PPE shall be employed to ensure the safety of all. e. Now piece them all together. For example, if a job included an aerial lift, electric arc welding, and exposure to manganese, combine each finished set of job components/hazards/safe work procedures to create your JHA for that job.
Performing risk assessments or job hazard analyses (JHA) on jobs that include one or more potentially hazardous steps will significantly reduce the risk of workplace incidences that could result in injury and/or property damage.
10 Personal Protective Equipment
10.1 Basic Protective Equipment 1. Personal protective equipment, also known as PPE, must be available for employee use whenever it is required for their work as outlined in this Manual. On occasion, an employee may request basic protection, regardless of the work requirements. Requested equipment should be made available if the request is reasonable. 2. The job sites, work areas, workplace, and anywhere work may be conducted shall be assessed to determine if hazards are present or likely to be present. Once the evaluation of the work area is complete, the necessity of personal protective equipment will be made. a. Eye protection is required at all times while in work areas. 3. Project Manager, in conjunction with the Safety Department shall select the appropriate personal proactive equipment to mitigate each hazard identified in the work site assessments. Each affected employee will receive a copy of the work site assessment with the selected PPE need to mitigate the identified hazard from the assessment. a. Each employee will be fitted for the selected PPE to ensure proper fit.
REV2.1 February 13, 2018 Page 47 | 165 The Elliott-Lewis Safety Manual 4. The employer is responsible for ensuring that all PPE is available at no cost to the employee and that employees are trained in how to properly don, doff, adjust and wear the equipment. The employee shall be trained in the limitations of the PPE, the proper care, maintenance, useful life and disposal of PPE. Retraining of the employee is required when the workplace changes, making the earlier training obsolete, when the type of PPE changes, or when the employee demonstrates a lack of use, improper use, or insufficient skill or understanding. All Training shall be documented and must include the employee name, dates of training, and the certification subject. 5. If specific additional PPE is needed for a job site, the Project Manager, in conjunction with the Safety Department, shall provide a signed site specific safety plan that will outline the PPE requirements for that site. 6. Where employees provide their own protective equipment, the Safety Department shall inspect and review to assure its adequacy, including proper maintenance, and sanitation of such equipment. 7. The employer shall ensure that all PPE will be maintained in a sanitary and reliable condition to protect body parts from contamination through inhalation, absorption, or physical contact. 8. All PPE is provided by Elliott-Lewis Corporation, including a program providing those employees with prescription glasses to purchase prescription safety glasses. All PPE will be purchased and maintained by the employer. 9. Defective or damaged PPE shall not be used at any time. 10. Project Manager, in conjunction with the Safety Department, shall audit the work sites to ensure the hazard assessment has been completed. They will also ensure all employees are affectively using the required PPE requested by the assessment. a. A formal audit document will be generated from the site visits stating: who completed the evaluation, the date of the assessment, and any issues deviating from the initial hazard assessment.
10.1.1 Hardhats
1. All employees, visitors, vendors and Company subcontractors must wear a hardhat on designated Elliott- Lewis construction and maintenance projects. Only projects or areas designated and posted by the project manager as not requiring a hardhat will be exempt from this company policy.
10.1.2 Clothing
1. Employees must wear clothing suitable for their work. Minimum attire includes full-length pants and a T- shirt that covers the shoulders. 2. Sturdy work shoes must be worn. The shoes must have heavy soles that will resist penetration from sharp objects. Approved steel-toe shoes are recommended, but not required, except where this is a recognized hazard to the feet. Sneakers (except ANSI-approved safety sneakers), sandals or any open toe/open heel shoe is not permitted.
If the construction site General Contractor declares it a steel-toed boot and hard hat area, all employees and sub- contractors must comply.
Note: Safety sneakers may be worn by employees provided they are high-tops with ankle support and the employee can provide proof of ANSI compliance.
3. In circumstances where an employee may report to work not properly dressed, they are to be taken off the payroll and instructed to return to work with the proper attire.
REV2.1 February 13, 2018 Page 48 | 165 The Elliott-Lewis Safety Manual 10.1.3 Eye Protection
1. Eye protection is required whenever the employee is exposed to flying objects, dust, chemicals or harmful rays. Operations requiring eye protection include: a. Chipping f. Drilling k. Solvent us b. Grinding g. Chemical use l. Sand or grit c. Wire brushing h. Power saws blasting d. Welding and i. Lathes m. Vibrating Burning j. Milling concrete e. Concrete pours machines 2. Minimum acceptable eye protection includes safety glasses or goggles, or prescription glasses with goggles. 3. Minimum eye protection must be worn at all times on those projects with mandatory eye protection programs. 4. Face shields do not protect an employee from impact injuries to the eyes. Eye protection must be worn underneath a face shield for grinding, chipping or while using impact tools.
10.1.4 Hearing Protection and Awareness
1. All employees who are exposed to action level noise of 85dbA on an 8-hour time weighted average, shall be trained on hearing protection at the start of the assignment and annually thereafter. Training shall be updated consistent to changes in PPE and work processes. The employer shall make available to affected employees copies of the noise exposure procedures and shall also post a copy in the workplace. 2. The employer shall administer a continuing effective hearing conservation program when employees are exposed to sound levels greater than the action level. 3. The employer shall implement a monitoring program to identify employees exposed to the action level and ensure that they be included in the hearing conservation program. 4. Employees will be given the opportunity to select hearing protection from a variety of suitable hearing protectors provided. 5. An audiometric testing program shall be established and made available to all employees whose exposures equal or exceed the action level. 6. Within six months of an employee’s first exposure at or above the action level, the company shall establish a valid baseline audiogram against which future audiograms can be compared. Testing to establish this baseline shall be preceded by at least 14 hours without exposure to workplace noise. Hearing protection may be used by the employee to avoid high levels of noise. After obtaining the baseline audiogram, the employer shall obtain a new audiogram annually to determine if a shift has occurred. If a shift has occurred, the employee shall be notified of this fact in writing within 21 days. Use of hearing protection shall be reevaluated and/or refitted and, if necessary, a medical evaluation may be required. 7. This hearing program is provided to the employee at no cost. Hearing protection shall be replaced as necessary and employees shall be trained in its use, care and fitting. 8. This program shall address high level noise environments and shall evaluate the protection to be used accordingly. 9. Elliott-Lewis will maintain accurate record of all employee exposure measurements for the duration of employment with us or two years, whichever is longer. 10. Hearing protection must be worn in high noise areas and in designated areas, or during the following work operations: a. Chipping b. Large diameter grinder use REV2.1 February 13, 2018 Page 49 | 165 The Elliott-Lewis Safety Manual c. Tamping g. Heavy equipment operations in d. Sand blasting open cabs e. Hydro-Blasting h. Arc-gouging/air arcing/plasma arc f. Impact tool use 11. Different types of hearing protection are available: a. Foam ear plugs c. Wool ear plugs b. Plastic ear plugs d. Ear muffs 12. Generally, soft foam earplugs when properly worn reduce noise levels better than earmuffs. In high noise concentrations, use earplugs and earmuffs. 10.1.5 Respiratory Protection
In every case where respiratory protection may be needed, attempts must first be made to establish engineered controls to reduce the contaminant through product substitution or mechanical ventilation. If these methods are not possible or practical, then respiratory protection may be used.
There are several types of respiratory protection, including:
1. Half-face cartridge respirator 4. SCBA (Self-contained breathing apparatus) 2. Full-face cartridge respirator 5. Full-face PAPR (Powered air purifying 3. Air-supplied full-face respirator respirator)
Before respiratory protection needs can be evaluated, the following information is critical:
1. Knowledge of the contaminant(s) 4. Knowledge of the concentration of the 2. Available ventilation contaminant through air monitoring 3. Ambient air volume
10.1.6 Dust Masks
1. Disposable dust masks are available for the following: a. Light concentrations of nuisance dusts b. Welding fumes Light spray painting c. Non-asbestos insulation dusts d. Light concentration welding fumes 2. Disposable dust masks do not offer adequate protection for the following contaminants: a. Asbestos exposure b. Gases, including sulfur dioxide, carbon monoxide, hydrogen sulfide c. Solvent vapors, including degreasers, penetrant dyes d. High dust concentrations e. Silica dusts, such as sandblasting f. Heavy concentration weld fumes g. Low oxygen levels 3. Employees with cardiac or respiratory problems or employees who have difficulty breathing through a dust mask must not be permitted to use a dust mask without physician approval or work in an area that would require respiratory equipment. 4. Dust masks purchased by projects must have a NIOSH approval clearly printed on the box.
REV2.1 February 13, 2018 Page 50 | 165 The Elliott-Lewis Safety Manual 5. Respirators are required for certain operations. The requirements for respiratory protection are outlined in the Respiratory Protection Program, found in Section 16 of this Manual. Generally, the following operations will require respirators, unless sufficient exhaust ventilation can be installed: a. Sand-blasting g. Degreasing operations b. Solvent or other chemical use h. Asbestos exposure c. Acid etching i. Epoxy paint operations d. Sulfur gas j. Polyurethane applications e. Cadmium welds k. Coal tar pitch product use f. Heavy galvanized welding l. Chlorine and other acid gases
10.1.7 Hand Protection
1. Employees are required to use appropriate hand protection when the employee’s hands are exposed to hazards such as those from skin absorption of harmful substances, severe cuts or lacerations, punctures, or temperature extremes. 10.2 Fall Protection, Safety Harnesses, Lifelines Safety harnesses and lifelines may be used whenever other methods, such as guardrails, scaffolds, ladders or other means of providing fall protection cannot be used. All employees working above a height of six feet must use fall protection equipment.
9.2.1 Safety Belts and Harnesses
1. A Class III Safety Harness may be used as fall protection from a vertical plane, such as would occur while on a suspended scaffold, motorized 'spider' staging, or float. The harness should be used with a short lanyard attached to a mechanical rope or cable grab that is attached to a vertical lifeline. 10.2.2 Lifelines and Anchoring
1. Life lines (sometimes also called drop-lines) must be rigged independently of all other rigging and tied off to a structural member capable of supporting 5,400 pounds. Safety lines must have ¾ inch manila, 5/8- inch nylon rope or steel cable of equivalent breaking strength. a. Note: Employees who tie-off to a safety line must do so with a mechanical rope grab or cable grab designed for the rope or cable diameter in use. Special knots (such as snugger hitches) are not permitted. All attachments should be made with a manufactured snap-hook with a positive safety control to prevent accidental disconnection. 2. On suspended scaffolds with multiple employees, each employee must be tied to their own independent lifeline. 3. Where multiple employees must traverse a horizontal plane, such as an elevated runway, a Catenary Line (or Static Line) may be used. 4. A catenary line is a horizontal cable that is secured in such a manner to structural members to allow horizontal movement of one or more employees from one point to another. Employees secure their belts to the Catenary Line by use of the safety clip at the end of the lanyard. 10.2.3 Descent Control Devices
1. Descent control devices, safety nets, or any other similar high level rescue equipment may not be used on a project without permission from the Safety Department.
REV2.1 February 13, 2018 Page 51 | 165 The Elliott-Lewis Safety Manual 10.3 Gloves and Hand Protection 1. Gloves should be worn whenever the employees’ hands are exposed to cuts, chafes, burns, cold or irritations. The following are examples of gloves that are available: a. Rubber chemical gloves d. Cotton gloves b. Viton/Vitril rubber gloves for e. Rubber impregnated cotton gloves solvents f. Latex gloves c. Weld gloves Note: Rubber and Latex gloves do not offer protection for certain organic chemical solvents. Most degreasers will penetrate through standard rubber gloves. Special gloves may be required. Consult the product's MSDS for specific applications. 10.4 Rain gear and Boots 1. Boots must be available when the employee works in concrete, water or mud. 2. Rain gear must be available to employees who must work during the rain, or when handling or vibrating concrete.
11 Scaffolds and Ladders
11.1 Ladders Ladders should be inspected before issue or use. Examine the ladder for split side-rails, broken or split steps or rungs, uneven legs, broken extension brackets, and hardware deficiencies. Ladder rungs, cleat, and steps shall be parallel, level, and uniformly spaced when the ladder is positioned for use. Any ladder not in compliance shall be tagged and placed out of service. The Elliott-Lewis Ladder Inspection form will need to be completed on each ladder quarterly. Do not use ladders for braces, shoring or as a workbench.
1. Extension ladders and straight ladders must be tied off to prevent slipping. 2. Step ladders may be used as a straight ladder only if the ladder sections are tied together and the ladder is secured. 3. Proper use of a ladder includes: a. Use a hand line to hoist material, never carry material while climbing a ladder b. Face the ladder when climbing c. Use both hands while climbing the ladder d. Be sure shoes are clean of oil and grease e. Set up on a stable, level surface 4. Aluminum ladders are a hazard around energized electrical equipment and welding. 5. Job-made ladders must be built to conform to OSHA standards, which includes 2 inche x 4 inches’ handrails with 1 inche x 3 inche cleats spaced 12 inches apart from top edge to top edge. The cleats must be inset into the rails or filler blocks may be used. Job-made ladders must be inspected frequently for signs of wood-rot. (See Attachment A of this section for construction diagrams for job-made ladders). Ladders shall be used only for the purpose for which they were intended. 6. When a ladder is used for access to a floor, deck or staging platform, the top of the ladder must extend at least 36 inches above the floor or deck. The feet of an extension ladder shall be placed away from the vertical height, distance equal to ¼ (one-fourth) the ladder's vertical height. 7. The top two steps of a stepladder are not to be used. Jobsites may spray paint the top two steps orange or red as a reminder not to use the steps. REV2.1 February 13, 2018 Page 52 | 165 The Elliott-Lewis Safety Manual 8. All ladders purchased for the Company shall be Class I heavy duty, industrial grade ladders. Straight ladders and extension ladders should be purchased with safety feet installed, whenever possible. Ladders shall not be loaded beyond their maximum rated capacity. 9. Tools and materials used while on a ladder should be contained in a tool pouch or tool bucket. Do not leave tools on ladder steps. 10. Ladders that are damaged should be repaired or destroyed and discarded. 11.2 Scaffolds Scaffolds may be used to provide a safe elevated work platform. There are many different types of scaffold construction. In general, all scaffolds must be provided with fall protection, safe access and must be capable of structurally withstanding any intended load.
All employees assigned to work on scaffolds shall be trained by a “qualified” person. Training shall include recognizing hazards associated with the type of scaffold being used and to understand the procedures to minimize those hazards (electrical, fall, falling objects). In addition, the training shall include fall protection, use, and load capacity. When conditions change in any way, re-training is required.
For most applications, manufactured scaffold sections should be inspected before each use.
1. Each working deck of a scaffold, suspended deck, ramp or runaway over 6 feet high must be guarded with horizontal guardrails. The guardrails must be installed on all open sides at the deck perimeter, installed at the edge of the open side to prevent a gap between the deck and the guardrail. Openings between the deck and a guardrail larger than 9.5 inches are not permitted. 2. Whenever plant equipment, piping or a wall are immediately adjacent to a deck, the guardrail may be eliminated provided equivalent protection is provided by the wall or equipment and the distance between the deck and all does not exceed: a. 14 inches for standard scaffolds b. 18 inches for plastering and lathing operations or c. three inches for outrigged planked decks 3. The top guardrail should be installed at approximately 42 inches (waist height) and a mid-rail installed halfway between the deck and the top rail. Cross braces do not substitute for a horizontal top rail. Guardrails may be supplied to the project as part of the component system of the scaffold; otherwise, standard two inches’ x four inches lumber or pipe may be used as equivalent protection. a. Manila or nylon rope may be used as guardrails in special circumstances provided some means of maintaining the rope taught is installed, and the supporting uprights are installed at three-four- feet intervals. 4. Working decks over six feet high must have toe boards installed to prevent tools and material from falling. Toe boards should be made of one-inch x four inches’ lumber, or equivalent. 5. Where people pass underneath or alongside a scaffold, such as a walkway, chicken wire or equivalent wire mesh or plywood should be installed between the midrails and toe boards to prevent material from falling onto personnel below. 6. The working deck of a scaffold must be at least 18 inches wide (two planks). When planking is used for the scaffold deck, the planking must be cleated or wired to the scaffold frame to prevent displacement. Deck openings larger than 9.5 inches must be covered with ¾ inches plywood. 7. Where two scaffolds join, the overlap of the planks must be supported. Where a scaffold turns a corner, the planking must overlap by at least 18 inches and the bearing side planking shall rest under the adjacent planking.
REV2.1 February 13, 2018 Page 53 | 165 The Elliott-Lewis Safety Manual 8. Whenever possible, laminated planking is recommended, otherwise, scaffold plant used for a work deck must be high fiber (stress grade) full thickness two inches’ x 10 inches or two inches’ x eight inches’ lumber. Structural grade lumber must be free of large knots, checking and splits. a. Planking purchased locally for a project must be examined before use and questionable planks tested as necessary. 9. When testing is necessary; the following process shall be used: a. Place the plank onto two cinder blocks. b. A 16-foot plank should withstand the weight of one employee (175 pounds) and an eight-foot plank should withstand the weight of two employees (350 pounds) without breaking while standing at the centerline of the plank. c. The successfully tested planks should be identified using a spray painted stencil or iron as follows:
"TESTED – (Date Tested)"
d. Laminated planking does not require testing. Where laminated plank is used, employees should be instructed not to cut laminated planking into lengths smaller than eight feet, and each eight- foot length marked "DO NOT CUT." 10. Examine planking for any of the following defects: a. Splitting or cracking beyond 10 percent of the surface of the plank. b. Severe splitting or checking at the end of the plank beyond the weigh-bearing portion of the plank. c. Knots or pitch deposits that are deeper than 10 percent of the thickness of the plank. d. Saw cuts deeper than 10 percent of the thickness of the plank. 11. The maximum permissible unsupported span for heavy-duty use of a full thickness two-inch x 10-inch plank is 6 feet. 12. Safe access must be provided to the working deck(s) as follows: a. A hook-on ladder b. Climbing rungs integral with the scaffold frame. 13. The access route and the ladder footing should be free of obstructions. The ladder should be secured to the scaffold. a. Note: An access ladder may be eliminated when the scaffold frame used is a climbing frame with unobstructed rungs that have a rung-to-rung distance no greater than 16 inches, preferably on 12-inch centers. 14. Scaffolds over 20 feet high must be secured to a building or other structure every 25 feet, otherwise outriggers must be installed. Scaffold over 125 feet high must be designed by a professional engineer. 11.3 Mobile/Rolling Scaffolds 1. Platforms and planking on mobile scaffold must be tightly secured. 2. A horizontal diagonal must be installed between the uprights to prevent the frame from 'racking' (or paralleling). 3. The wheels of a rolling scaffold must be locked when employees are on the scaffold. 4. Employees may not "ride" a rolling scaffold. 11.4 Two-Point Suspended Scaffolds (Swing-lo's) 1. Winch motors must be inspected before each use. Winch motors shall be serviced each year, or as needed for repairs. The Winch motors on suspended scaffolds must have an inspection tag visible and the motor should not be used without an inspection tag visible and dated within one year.
REV2.1 February 13, 2018 Page 54 | 165 The Elliott-Lewis Safety Manual 2. No more than two men are permitted on a suspended scaffold with a motor working load of 500 pounds. No more than three men are permitted on a suspended scaffold with a motor working load of 750 pounds. 3. The scaffold deck must be guarded with a top rail and mid-rail. Toe boards must be installed. All deck and guardrail connecting bolts and connections should be checked prior to use. 4. The supporting steel cable must be insulated from any metal building components whenever welding is being performed and the building structure is being used for an electrical ground. 5. An employee lifeline must be installed independent of other rigging for each employee on the scaffold. The lifeline must be made of 3/4-inch manila or nylon rope and must be secured to a structural member capable of withstanding at least 5,400 pounds. 6. Employees working on suspended scaffolds must wear a Class III Safety Harness (See Personal Protective Equipment, Section 9.1) and must be tied-off to the independent lifeline at all times by use of a mechanical rope. Special knots, such as a hand-tied “snugger-hitch,” are not permitted. 11.5 Tagging 1. On designated projects, each scaffold built by or built for Company employees shall be inspected by a superintendent or the competent person prior to use and periodically through the project. 2. On designated multi-employer projects, a scaffold tagging system shall be utilized according to the following guidelines: a. RED CONSTRUCTION TAG - shall be hung on the first frame or structural member of the scaffold when the scaffold is being built or when the scaffold is being dismantled. Employees may not use the scaffold when it is incomplete. b. GREEN TAG - shall be hung on the access ladder of the scaffold following an inspection by the crew superintendent or safety monitor. Employees may work on green-tagged scaffolds without fall protection. c. YELLOW TAG - shall be hung on a scaffold or work platform whenever guardrails or other fall protection cannot be installed. Employees must wear safety belts and tie-off when working on yellow-tagged scaffolds. d. RED DANGER-CONDEMNED TAG – shall be hung by the competent person on any incomplete scaffold. A red danger condemned tag may be removed by the superintendent or competent person following repairs or corrections. Employees may not work on red danger-condemned scaffolds. 3. On projects where a scaffold tagging system is used, employees shall be trained to recognize the tags and understand the meaning of each tag. Such training shall be included in the new-hire orientation program and periodic safety bulletins. 4. Tags will be made available by the Safety Department to designated projects.
12 Fall Protection 12.1 General It is the responsibility of the company to identify all fall hazards, to prevent employees from falling off or through working levels, and to protect employees from falling objects. These OSHA Fall Protection requirements apply to all construction and service sites including residential service where any employees are at risk from falling onto or through any walking or working surface four feet or higher from the lower level.
REV2.1 February 13, 2018 Page 55 | 165 The Elliott-Lewis Safety Manual Elliott-Lewis Corporation shall provide training for each employee who might be exposed to fall hazards. The training shall enable the employee to recognize the hazards of falling and shall train each employee in the procedures to follow to minimize these hazards. Written records shall show who was trained, the date, and the signature of the person providing the training. Retraining shall be provided whenever there are deficiencies in training, work place changes, or when fall protection systems or equipment changes that render previous training obsolete.
All fall protection strategies shall be prepared by the Safety Director in a coordinated effort with the Project Manager of the jobsite. Plans shall be site-specific. Under no circumstance will any employee or sub-contractor work without a form of fall protection in place prior to start of work. A “fall protection plan” as an alternative approach to “fall protection” as recognized by OSHA under 29CFR 1926.502(k) is not an acceptable means of protection under the guide and direction of the Elliott-Lewis Corporation Safety Department and direct Supervision.
12.1.1 Objectives
The means to achieve this objective is three-fold: Identify the hazard, prepare a written Fall Protection Program, and employee training.
A competent person will be assigned to recognize fall hazards, warn employees who are unaware of a hazard or acting in an unsafe manner, be posted on the same working level and in visual sight, stay close enough for verbal communication, and act as a monitor with no other assignments or distractions. This employee would be the Project Manager or the Foreman in his stead.
All incidents, accidents, or near misses must be reported immediately to the Safety Department so that an investigation can begin and changes can be implemented to the fall protection program, if necessary.
All fall protection equipment shall meet the requirements of applicable ANSI, ASTM, and OSHA guidelines. All equipment utilized shall be company issue to ensure compliance
12.1.2 Hazard Identification
The following guidelines shall be adhered to in order to ensure an employee cannot fall four feet or more:
1. If walking/working surfaces have the strength and structural integrity to support the workers. 2. Employees on a walking/working edge which has unprotected sides and edges which is four feet or more above a lower level must be protected by the use of a guardrail, safety nets or personal fall arrest systems (PFAS). 3. At hoist areas, workers must be protected from falling. 4. Workers must be protected from falling more than four feet through holes. 5. Employees working on the face of framework and reinforcing steel at four feet or higher above a lower level must be protected by guardrail, nets or PFAS. 6. When employees are working on ramps, runways, or other walkways, they must be protected from falling by guardrail systems. 7. Workers on the edge of excavations more than four feet deep must be protected from falling by guardrails, fences, or barricades. 8. Workers less than four feet above dangerous equipment must be protected from falling onto or into the equipment by guardrail, nets of PFAS. 9. Workers involved in overhead brickwork must be protected by guardrail with toe boards, nets, PFAS, or must be in a controlled access zone.
REV2.1 February 13, 2018 Page 56 | 165 The Elliott-Lewis Safety Manual 10. Workers conducting rooftop work on low slope roofs must be protected by guardrail systems with toe boards, nets, PFAS, or a combination system that includes a warning line system and a safety monitoring system. 11. Workers involved in the construction of pre-cast concrete erection must be protected through conventional methods unless the employer can prove that it is unfeasible. 12. Workers conducting residential construction must be protected through conventional methods unless the employer can prove that it is unfeasible. 13. Near all wall openings six feet or higher above a lower level and less than 39 inches above the walking/working surfaces, workers must be protected from falling by guardrail, nets or PFAS. 14. Fall protection is not required when utilizing movable ladders such as a step or extension ladder. The employee must show common sense in the safe use of this equipment. 15. All accidents and near misses must be investigated. Implementation of changes to the fall protection plan must be done where needed. 12.1.3 The Elements of Fall Protection
Taken in total, the following three components provide the maximum in fall protection:
1. Body Wear: personal protective equipment (PPE) consists of full body harness and restraint belt. 2. Connecting Devices: Components that attach to the worker's PPE such as lanyards, restraint ropes, retractable lifelines, and rope grabs. 3. Anchoring Devices: Commonly known as a tie-off point, this is the area that supports the entire weight of the employee and fall protection system. 12.1.4 Fall Protection Systems
12.1.4.1 Fall Arrest
The primary function of a PFAS is to minimize the consequences caused by a fall. The use of a PFAS is to prevent the fall and to limit injuries caused by falling. Personal fall arrest systems must be rigged so that the workers can neither fall more than four feet nor contact any lower level.
1. Utilize a full body harness with D-ring located in center of the back; the use of safety belts is not permitted in a fall arrest system. a. All equipment used will be inspected prior to use by the person preparing to use the equipment. b. User will look for signs of wear, damage, deterioration, and defective components. c. Any equipment found to contain any of the above listed issues will be removed from service and tagged “danger, do not use.” 2. Connecting devices shall be a shock-absorbing lanyard; the length of the lanyard will be determined on the jobsite. The softstop end of the lanyard should always be attached to the D-ring. The lanyard shall be double snap lock ends and be capable of sustaining a shock load of 5,000 pounds. The lanyard will limit maximum arresting forces on the employees to 1,800 pounds when used with a harness. 3. The anchorage point can be an eyebolt or a steel eye-beam. The use of a cross-arm nylon strap can facilitate the attachment.
12.1.4.2 Fall Positioning
The purpose of positioning devices is to allow the worker to hold himself in position, permitting their hands to be free to accomplish a task. Whenever a worker leans back, the system is activated, making this an "active" system.
REV2.1 February 13, 2018 Page 57 | 165 The Elliott-Lewis Safety Manual Positioning devices shall be rigged so that an employee cannot free fall more than two feet. An effective system includes the following:
1. Personal Protective Equipment (PPE) a. A full body harness with side "D" rings. 2. A Connecting Device a. Lanyards with snap rings 3. Positioning Anchorage Point a. The anchoring point shall be capable of supporting twice the potential impact load of the employee or 3,000 pounds.
12.1.5.3 Retrieval System
The third category of fall protection is mostly used in confined spaces. This is utilized when the worker is required to enter a manhole, a tank, etc., and may require retrieval if an emergency occurs.
1. Personal Protective Equipment (PPE) a. Bosin chair or a full body harness with "D" ring mounted in the center of the back. 2. Connecting Device a. A retractable lifeline/rescue unit 3. Anchor Point a. Tripod Eyebolt 12.1.6.4 Suspension System
This fourth category is used widely in window washing and painting industries and is designed to lower and support a worker while allowing a hands-free work environment.
1. Personal Protection Equipment (PPE) a. A Bosin chair and full body harness 2. Connecting Device a. A work line 3. Anchor Point a. Anchor bolt or carabineer
Note: Because the components of a suspension system are not designed to arrest a free fall, a back-up fall arrest system should be utilized in conjunction with the personal suspension system. 12.1.6.5 Rescue Plan
Whenever a fall arrest system is utilized because of the presence of a fall hazard of four feet or greater, a rescue plan must be in place. This plan must facilitate a rescue of the employee in fall arrest within 15 minutes or shall ensure the employee is able to self-rescue.
12.1.7.6 Fall Restraint
Fall Restraint is a system that should be utilized as much as possible and in lieu of fall arrest. A fall restraint system maintains a safe distance short of the fall hazard yet allows the employee to do their work in a safe and efficient manner. The system allows the employee to be within inches of an unprotected edge and as long as the employee cannot reach any unprotected edge, it is a compliant fall restraint system. A rope lanyard should be used in tandem with a body/ladder belt or harness. The rope lanyard is connected to an anchor point that should have the capacity to withstand at least twice the maximum expected force that is needed to restrain the REV2.1 February 13, 2018 Page 58 | 165 The Elliott-Lewis Safety Manual employee from exposure to the fall hazard. In determining this force, consideration should be given to site- specific factors such as the force generated by a person walking, leaning, or pulling on the anchor point. This system is highly recommended because it eliminates the need for a 5000 lb. anchor point and a rescue plan because the hazard has been eliminated. Fall restraint can be utilized only on a flat roof, not on a sloped roof. 12.2 Alternate Fall Prevention Systems 12.2.1 Guardrail Systems
1. Guardrails must be capable of withstanding a force of at least 200 pounds. 2. Guardrail height shall be 42 inches (plus or minus three inches) and have a mid-rail at least 21 inches high. 3. Guardrail systems shall be surfaced to prevent injuries from punctures and lacerations. 4. If wire rope is utilized as a top rail, it must be flagged every six feet.
12.2.2 Safety Nets
1. Must be installed as close as possible to the working area but not more than 300 feet below the working/walking surface. 2. Safety nets must be inspected weekly. 12.2.3 Warning Line Systems
1. Warning lines must be erected for rooftop work where the roof area is more than 50 square feet. The line must be placed at least three feet in from the parapet, at a height of 40 inches and capable to withstand a force of 310 pounds.
12.2.4 Covers
1. Covers shall be placed over any hole that has a gap of 2 inches or more in its least dimension, in a floor, roof, or other walking/working surface. Covers must be capable of supporting twice the weight of employees or any equipment placed on top of the cover. 2. The lid must be secure and marked with the word "cover" or "hole."
12.2.5 Controlled Access Zone
1. An area where work being done without conventional systems and where access is limited to approved persons and is defined by a control line. Control lines shall be erected not less than 6 feet nor more than 25 feet from the unprotected edges. Lines shall consist of ropes, wires, danger/caution tape or equivalent 2. materials and shall be flagged every 6 feet for high visibility. Each line shall be rigged so that it will not sag to less than 39 inches from the walking/working surface and its highest point is not more than 45 inches.
12.2.6 Skylights
1. OSHA Standard 1910.23(a) (4) requires that all skylights on rooftops shall be guarded by a standard skylight screen or fixed standard guardrail on all exposed sides. If the jobsite does not provide any permanent guarding, the employee shall create a controlled access zone protecting any affected employees from the hazard. See section 9.7.5 for controlled access zone guidelines. 12.3 Open-Sided Floors, Floor-Openings and Hoist ways, Barricades and Hole Covers
12.3.1 Open Sided Floors-Perimeter Protection
REV2.1 February 13, 2018 Page 59 | 165 The Elliott-Lewis Safety Manual 1. Open sided floor perimeters over six feet high must be guarded with a handrail and mid rail of 2 inches’ x 4 inches’ lumber, pipe, or steel cable. Steel cable must be installed and tightened to prevent sagging and displacement. Uprights should be installed at such distances to provide stability and secured to withstand 500 pounds of lateral force. 2. Where employees must work near the perimeter of an open sided floor, toe boards must be installed where there is a danger of material falling onto the employees below. 3. On multi-tiered floors, plastic barrier screen erected with a steel cable top rail provides good fall and debris protection. 4. Where employees must remove perimeter guarding to hoist equipment or material, the employee working at the opening must be secured with a safety belt and a lifeline secured to a building structural member. 12.3.2 Floor and Roof Openings
1. Floor and roof openings larger than 12 inches must be covered or guarded with standard guardrails wherever there is a danger of an employee falling or stepping into the opening. Toe boards must be installed if tools or materials are used near the floor opening. 2. Where employees must work near the edge of an open sided floor, roof or floor opening, standard guardrails and toe boards must be installed. 3. Where employees must remove the perimeter guarding of an open sided floor or roof to hoist material, the employee must be protected from a fall by wearing a safety belt with a lifeline attached to part of the building structure.
12.3.3 Warning Lines
1. An open-sided floor, floor opening, or roof opening may be protected with a warning line, instead of a guardrail or other barricade. 2. A warning line made of rope, flagging or barrier ribbon may be erected instead of a guardrail, and provided it is erected as a “warning line” at least six feet from the edge of the fall exposure. Employees should be instructed not to work within a barricaded area where there is a fall exposure without use of a safety belt secured to a building structural member. A warning may never substitute for primary fall protection. 12.3.4 Hole Covers
1. A hole cover must be installed on floor openings larger than 12 inches or wherever there is danger of tripping. 2. Holes larger than 12 inches must be covered with 3/4-inch plywood, or equivalent, and must be cleated or secured from displacement and should be labeled: a. "DO NOT REMOVE - FLOOR COVERING/STORE NO MATERIAL." 12.4 Protection from Falling Objects When a worker is exposed to falling objects, the employer must require each worker to wear a hard hat and must erect toe boards, screens, or guardrails to prevent objects from falling; or erect a canopy structure and keep objects away from the edge of the higher level; or barricade the area to which objects could fall.
1. Toe boards shall be a minimum of 3-1/2 inches high and shall have no more than 1/4" of clearance above the working/walking surface. 2. Canopies, when used as falling object protection, shall be constructed strong enough to prevent any objects from penetrating through it. REV2.1 February 13, 2018 Page 60 | 165 The Elliott-Lewis Safety Manual 12.5 Fall Protection during Rigging of a large air conditioning unit 1. When an employee is required to rig a large air conditioning unit for hoisting by a crane, the employee should perform a Job Hazard Analysis with the crane operator to plan the safest and easiest way to rig each unit for lifting. 2. It is the policy of the company that the rigging is done from the ground or the bed of a trailer. Under NO circumstances will an employee be permitted to stand on the top of the unit during this process. 3. When the rigging points are at the base of the unit, all rigging will be performed from the ground or from the bed of the trailer. When the rigging is set, the crane operator is to be instructed to lower the hook to the rigging. The operator shall have long enough slings and move the hook to each side of the unit to set the slings into the hook. If possible, the slings may be attached to the hook first and then lowered into position so all the rigging points can be reached and attached from the ground. This procedure should not require the use of any ladders at any time. 4. When the unit to be hoisted has the rigging points at the top of the unit and there is a risk of a fall of four feet or greater, the employee will set up a ladder extending three feet above the top of the unit and comply with all the rules of ladder safety. All the rigging will be done from the ladder. 12.6 Revisions Revised Date: Revised By:
13 Welding and Burning Safety
13.1 General 1. Welders and cutters, and their supervisors must be instructed in the proper operations of their equipment and the handling of cylinders and weld equipment, as well as fire prevention requirements and the use of fire extinguishing equipment. The foreman, or competent person, shall inspect the welding/cutting site and authorize the job and complete a hot work permit showing the hazards and precautions taken. 2. Welders are responsible for surveying their work area and areas below for any potential fire hazards. Combustible material must be removed or protected. If the object to be welded or cut cannot be moved and if all the fire hazards cannot be removed, then guards shall be used to confine the heat sparks and slag and to protect the immovable fire hazards. If it is determined that the job cannot be done safely, the welding or cutting shall not be performed. 3. A fire watch should be utilized when the following conditions exist: a. Locations where other than a minor fire might develop b. Combustible materials closer than 35 ft. to point of operation c. Combustibles that are 35 ft. or more away but are easily ignited d. Wall or floor openings within 35 ft. radius expose combustible materials e. Combustible materials are adjacent to the opposite side of metal partitions, ceilings, or roof REV2.1 February 13, 2018 Page 61 | 165 The Elliott-Lewis Safety Manual f. Fire watchers shall have fire extinguishers readily available. g. A fire watch shall be maintained at least a half an hour after the welding or cutting operation is completed. 4. Welders are to have a fire extinguisher available within the immediate area. Welders are responsible for reporting any fire or extinguisher discharge to their foreman. 5. When welding inside an existing building, metal catch pans, fire blankets and rod-stub buckets must be used to contain spark and hot rod-stubs. Exhaust ventilation may be necessary inside existing buildings. Any welding, cutting, or burning of lead based metals, zinc, cadmium, mercury, beryllium, or exotic metals or paints not listed shall have proper ventilation or respiratory protection. 6. Welders are responsible for their own cylinder care. All hoses, weld leads and air hoses must be kept out of walkways and protected or elevated to prevent damage. 7. Confined spaces pose additional hazards when welding and cutting. Welders shall be trained and shall address these additional issues prior to entering the space. These issues include ventilation, lifelines, electrode removal, gas cylinder shutoff, and warning signs. See section 15.9 for confined space procedures. 8. A first aid kit shall be readily available at all times during the operations. 9. All welders in charge of oxygen or fuel-gas equipment must be instructed and judged competent for such work. 10. All compressed gas cylinders shall be stored upright and secured from falling over. Additionally, oxygen cylinders must be stored a minimum of 20 feet from any flammable gases or petroleum products. 11. Arc welders shall be properly instructed and qualified to operate such equipment. 12. All operators of welding/cutting equipment should report any equipment defect or safety hazards and discontinue use of equipment until its safety has been assured. Repairs shall be made by a qualified individual. 13. All employees assigned to operate welding/cutting equipment shall be familiar with OSHA regulations 1910.254 and 1910. 252(a)(b)(c) which are the general requirements and procedures outlined above. 14. Gases for oxy-fuel welding and cutting will be restricted to a single type of fuel gas on a project, unless adequate precautions have been made to ensure that non-compatible torches and gauges are not used. 15. Gauges, torches, hoses and weld leads should be in good repair before being issued to an employee. Oils, solvents and paints may not be used for repair or identification of any gas gauges, hoses, fitting or torches. 16. Welding and burning permits may be required on some projects. Contact the property owner concerning his own fire regulations before beginning work. 17. Welders must be instructed in the proper handling of cylinders and weld equipment, as well as fire prevention requirements. 18. Welders are responsible for surveying their work area and areas below for any potential fire hazards. Combustible material must be removed or protected. A fire watch should be utilized when combustible material cannot be removed or covered with fire retardant blankets. 19. Welders are to have a properly rated fire extinguisher (ABC) available within the immediate area. Welders are responsible for reporting any fire or extinguisher discharge to their foreman. 20. When welding inside an existing building, metal catch pans, fire blankets and rod-stub buckets must be used to contain spark and hot rod-stubs. Exhaust ventilation may be necessary inside existing buildings. 21. Welders are responsible for their own cylinder care. All hoses, weld leads and air hoses must be kept out of walkways and protected or elevated to prevent damage. 22. Welding from metal or aluminum ladders is prohibited.
REV2.1 February 13, 2018 Page 62 | 165 The Elliott-Lewis Safety Manual 14 Hand and Power Tools
Tools and equipment issued to a project shall be inspected prior to use. Tools and equipment purchased for a project should be inspected prior to use on a project. Tools that are damaged or in poor repair should be removed from service and repaired or replaced. 14.1 Tools, Guards and Precautions Tools - General
1. Electric Tools must be double insulated or grounded through a third-wire ground. The ground lug on the plug of the tool must not be cut. 2. The power cord to an electric tool must be free of chafes and cuts and the protective outer insulation must be intact and secured to the tool and plug. 3. Core Drilling Equipment must be protected with a variable ground-fault device to protect the operator in case of accidental contact with imbedded electrical lines. 4. All tools that come equipped with safety features and guards from the manufacture will be used at all times. At no point in time will a tool be operated without manufacture guards and inoperable safety features. 5. Guards shall be in place and operable at all times while the tool is in use. The guard may not be manipulated in such way that will compromise its integrity or compromise the protection in which it is intended. 6. Before purchasing a new style or brand of hand/power tool, background research needs to be completed to ensure that all guards meet or exceed ANSI B15.1. 7. Any tool found to be defective during a pre-use is required to be tagged “danger” “tool out of service” and returned to the shop for replacement or disposal. 14.2 Grinders 1. Grinder guards must not be removed from the tool. Employees may not remove guards. Cut-off wheels of 2" diameter or less do not require a guard. 2. Guards on seven-inch grinders must never be removed. 3. Bench grinders must be properly adjusted per the following: a. Upper flange within 1/8 inch of the wheel b. Tool rest within ½ inch of the wheel c. The wheel should be "dressed" as necessary d. Note: Bench grinders may not be used without a tool rest. 4. Air power grinders must be equipped with a Schraeder quick-disconnect fitting or an air shut-off must be within each of the operator. 5. Air power grinders must have momentary, "dead-man" controls with a safety clip to prevent accidental operation. 6. Grinding wheels and cut-off wheels must meet or exceed the RPM's of the grinder. The wheels must be attached to the grinder with flanges and fittings supplied by the manufacturer of the grinder. Incompatible bolts, flanges or washers shall not be used. 7. The operator must wear safety glasses or goggles and a face shield. 14.3 Drills 1. ½ inch power drills must be used with the side handle installed
REV2.1 February 13, 2018 Page 63 | 165 The Elliott-Lewis Safety Manual 2. Always unplug the tool before changing bite 3. Use only GFCI electrical protection when drilling in wet areas, or whenever drilling into concrete 14.4 Impact Tools 1. The air supply lines to impact tools must be securely fastened to the tool. Whip lines to the tool should be fastened with a Schraeder fitting or other type quick disconnect, or a threaded fitting may be used with a manual shut off on the whip line. 2. All fitting, shafts, extenders and sockets must be secured using a manufactured standard pin, as provided with tool. Wire, nails or other incompatible securing devices shall not be used. 3. Impact nailers and staplers may not be operated with a working pressure of more than 100 psi. A safety device must be operable at the muzzle of the tool to prevent accidental discharge. These tools, when purchased, must meet applicable ANSI standards. 14.5 Chisels 1. Chisels should be kept sharp. The shaft of the chisel should be inspected for bends and cracks. Chisels with "mushroomed" heads must not be used. 2. Chisels used on pneumatic tools must be secured to the tool using a standard retaining pin to prevent accidental ejection. Do not use tie-wire or nails as retaining pins. 3. The employee must wear safety glasses or goggles while operating impact tools. 14.6 Woodworking Tools 1. Portable power saws must have a momentary switch that will release and shut off the tool when the operator releases the switch. 2. Portable power saws must have a retractable blade-guard maintained in working order. 3. Table saws and crosscut saws (radial-arm saws) must be equipped with retractable blade guards and anti- kickback guards. 4. Radial arm cutting heads must return to the rear position when released by the operator, either by gravity or return spring. 5. The power cut-off for table saws and crosscut saws must be within reach of the operator. 6. The operator must wear safety glasses or goggles. 14.7 Power Tampers 1. Employees should be familiar with the hazard the tool poses to the operator's feet. 2. Employees using a power tamper should wear steel toe shoes or wear strap-on metal toe guards. 3. Refuel the machine when not running and only after cooling sufficiently to prevent spontaneous combustion. 4. Power tampers should be operated on an incline with caution. 5. Power tampers should be lifted by two employees. 14.8 Hand Tool PPE 1. Personal protective equipment, also known as PPE, must be available for employee use 2. whenever it is required for their work as outlined in this Manual. On occasion, an employee may request basic protection, regardless of the work requirements. Requested equipment should be made available if the request is reasonable. 3. The employer shall assess all areas of the workplace to determine if hazards are present or likely to be present. Eye protection is required at all times. If specific additional PPE is needed for a job site, the Project Manager, in conjunction with the Safety Director, shall provide a signed site specific safety plan that will outline the PPE requirements for that site. REV2.1 February 13, 2018 Page 64 | 165 The Elliott-Lewis Safety Manual 4. The employer is responsible for ensuring that all PPE is available at no cost to the employee and that employees are trained in how to properly don, doff, adjust and wear the equipment. The employee shall be trained in the limitations of the PPE, the proper care, maintenance, useful life and disposal of PPE. Retraining of the employee is required when the workplace changes, making the earlier training obsolete, when the type of PPE changes, or when the employee demonstrates a lack of use, improper use, or insufficient skill or understanding. All Training shall be documented and must include the employee name, dates of training, and the certification subject. 5. The employer shall ensure that all PPE will be maintained in a sanitary and reliable condition to protect body parts from contamination through inhalation, absorption, or physical contact. 6. All PPE is provided by Elliott-Lewis Corporation, including a program providing those employees with prescription glasses to purchase prescription safety glasses. All PPE will be purchased and maintained by the employer. 7. Defective or damaged PPE shall not be used at any time.
15 Housekeeping and Waste Management
15.1 General Estimation of the waste that may be generated on any jobsite prior to the start of the project shall be done so that the need for containers and removal of the waste containers can be accomplished in a timely and controlled fashion. In the work we perform, we generally will generate similar, if not the same waste, based on the size of the project. Employees must be instructed on the proper disposal methods for all wastes. If wastes generated are classified as hazardous, employees must have training to ensure proper disposal.
1. Good housekeeping on a project has several useful benefits. First, good housekeeping reduces injuries by eliminating tripping hazards and obstruction. 2. Secondly, good housekeeping improves production efficiency because the elimination of obstruction and cluttered work areas provide for better material movement and storage. 3. Third, good housekeeping is the key to fire prevention on a project. Most project fires are caused by the careless ignition of scrap material, lumber, sawdust, and rubbish/paper goods. 4. Lastly, the general appearance of a project is an indication of the "professional" manner in which a company operates. 15.2 General Rules 1. Trash containers shall be located throughout a project. Enough laborer support should be considered to provide for a daily cleanup of rubbish and scrap. On multi-level buildings, skip-pans (scale-pans) should be provided for hoisting scrap material out of the building. 2. Rags, paper, scrap wood, and sawdust should be cleaned up each day. 3. Remove nails and sharp objects from scrap material before it is discarded. 4. Slippery floor condition should be cleaned up immediately to prevent injuries. 5. Employee change areas, washrooms, drinking fountains and water cans must be cleaned daily. 6. Keep stored material out of walkways and work areas. Do not store material within six feet of a hoist-way or floor opening or open-sided floor. 7. Keep pipe, conduit and re-bar chocked or secured to prevent rolling. 8. Keep outdoor ramp-ways and stairs dry and free of mud or other slippery conditions 9. Do not block fire or rescue equipment locations with stored material. REV2.1 February 13, 2018 Page 65 | 165 The Elliott-Lewis Safety Manual 10. Do not store excess material on a scaffold. Store only what is needed for that day. 11. Keep walkways clear. Determine what areas employees frequently travel and inspect these areas frequently for tripping hazards or slippery conditions. 12. Waste materials should be properly stored and handled to minimize the potential for spills and any impact to the environment. Oily rags and combustible waste must be discarded in safety containers with self-closing lids. Remove waste oil and solvents from the building on a regular basis. During outdoor storage, receptacles must be covered to prevent dispersion of waste materials and to control the potential for runoff. 13. On projects with dumpsters, employees must be instructed not to lift rubbish cans overhead to empty into a dumpster. If the dumpster does not have an open end, then a ramp or steps must be built so that an employee can dump a can from a waist high position. Serious back injuries occur from lifting material overhead. 14. Ensure proper segregation of waste materials for proper disposal and to ensure opportunities for reuse or recycling.
16 Excavating and Trenching
16.1 Responsibilities The Project Manager is responsible for ensuring that the project complies with the Trenching and Excavating requirements of OSHA 1926.651. The standard interpretation follows: 16. 2 Competent Person A competent person will be designated by the Project Manager and trained by the Safety Department for each project where any form of trenching or excavating is planned. The competent person must be knowledgeable of the OSHA standards, including sloping and benching design and shoring/bracing specifications. The competent person should be familiar with excavation processes and general construction techniques. The competent person will:
1. Pre-plan trenching and excavation work. 2. Perform a daily inspection of each trench and excavation for changes in soil conditions, adequate egress, personal protective equipment (where applicable), rescue equipment (where applicable) and general compliance with sloping and protection requirements. 3. Perform an inspection of all trench excavations following heavy rains or a freeze-thaw cycle where the integrity of protective systems could be jeopardized. 4. Maintain a daily log of inspections. 5. Maintain a file of manufacturer’s data or PE certifications for all trench boxes and shielding systems. 16.3 Pre-Plan Operations 1. Surface Encumbrances that are located where they may pose a hazard to employees below should be removed, moved or supported. 2. Utilities location shall be determined prior to starting any excavating. Local utility companies or a locating service must be contacted prior to starting an excavation within 24 hours (or longer, depending on local ordinances wherever utilities are suspected). PA One Call: 1-800-242-1776; Account No. 2261166. 3. Egress shall be provided into a sloped excavation or trench by means of a ramp. Ramps must be built with cleats and must be capable of withstanding any intended load.
REV2.1 February 13, 2018 Page 66 | 165 The Elliott-Lewis Safety Manual 4. Where ramps are not utilized, steps or ladders must be installed in any trench excavation deeper than 48 inches. A means of egress (ladder, steps or ramps) must be provided for every 25 feet of trench excavation. 5. Employee Exposures a. Employees exposed to vehicular traffic must wear high visibility traffic safety vests. b. Employees are not permitted to work beneath suspended loads. Enough room must be afforded to allow employees to drift sections of pipe or rebar into a trench without standing directly beneath a suspended load. Tag lines are advisable. c. Where equipment is operated near a trench excavation and where the operator does not have a clear view behind the equipment, back-up warning alarms must be installed. d. Equipment operating at/near the edge of an excavation should be prohibited from operating closer than two feet from the edge of an excavation by use of a guide or barricades. 6. Atmospheric Monitoring must be performed by the competent person or a designee who is familiar with such testing for any trench excavation where the competent person could reasonably suspect that there might be an accumulation of combustible gases, toxic gases or an oxygen deficiency. A triple gas monitor will be used to perform such testing. The following are areas that should be suspect: a. Adjacent to or over any sewer line, d. Chemical storage tanks or process active or inactive piping b. Any large diameter water canal e. Fuel lines c. In the vicinity of any natural gas line f. Landfill areas
7. All testing should be recorded on the daily excavations inspection log. a. Entry should be prohibited and an employee should be posted at the excavation to warn others if the atmosphere is not acceptable. The Safety Department will provide training in the operation of the monitor. 8. Where a hazardous atmosphere may develop during the excavation process, all employees are to be evacuated from the excavation till the source of the hazardous atmosphere is located. 9. Rescue precautions must be implemented prior and during the shift: a. A body harness and lifeline b. Stand-by employee 10. Water Hazards must be controlled. Employees are not permitted to work in excavations where water may accumulate and pose a threat due to undermining of the trench walls or protective system. 11. The competent person should visually inspect for such water accumulation during the daily inspection. a. Constant monitoring should be conducted to ensure all entrants are aware of the changing conditions. 12. Adjacent structures should be examined to ensure their stability. Shoring, bracing or underpinning may be necessary. 13. Sidewalks, roadways, pavements and appurtenant structures will not be undermined without the consultation of an engineer. 14. A shoring, bracing or underpinning system may be eliminated only after inspection and approval of a Registered Professional Engineer. 15. Loose soil and spoil from the excavation process must be kept back at least two feet from the edge of the excavation or otherwise barricaded. 16. Crossovers and ramps must be built by a competent person and guarded with standard guardrails and mid-rails to prevent employee falls into open trench excavations.
REV2.1 February 13, 2018 Page 67 | 165 The Elliott-Lewis Safety Manual 16.4 Protection from Cave-In 1. Every trench excavation deeper than five feet, or any excavation which the competent person deems to be unstable, must be protected. Every trench excavation deeper than 20 feet must be protected by one of the listed protective systems and approved by a Registered Professional Engineer. 2. several methods of protection, as listed below: a. Sloping the trench excavation walls to an allowable angle of repose based on the type of soil b. Benching (or stepping) the excavation walls to an allowable depth and angular slope based on the type of soil c. Sloping and/or benching in accordance with tabulated data or a design approved by a Registered Professional Engineer d. Installation of a manufactured Trench Box used in accordance with the manufacturer’s instructions e. Installation of timber shoring, manufactured aluminum hydraulic shoring f. A fabricated shield system designed and approved by a Registered Professional Engineer g. Note: Tables are provided, as attachments to this section, which outline the allowable slopes and configurations for each different soil type. 3. Soil testing must be done by the competent person. Instructions are included as attachments to this section for testing soil types. 4. Whenever a Registered Professional Engineer designs a protective system or allows a deviation from the allowable configurations, such approval must be kept on file at the project. 5. A Registered Professional Engineer used to certify protective systems or certify deviation from any of these standards must be registered in the state in which the excavation is being performed. 6. The Safety Department must be notified of any of the following situations: a. Any trench excavation planned deeper than 15 feet b. Any planned deviation from the manufacturers recommended use of a manufactured shield system c. A cave-in or severe sloughing when employers are in a trench excavation d. Any trench-related accident or near miss e. Discovery of atmospheric contaminants 16.5 Definitions and Soil Classification The definitions and examples given below are based on, in whole or in part, the following American Society for Testing Materials (ASTM) Standards D653-85 and D2488; The United Soils Classification System, The U.S. Department of Agriculture (USDA) Textural Classification Scheme and The National Bureau of Standards Report BSS-121.
Cemented Soil: A soil in which the particles are held together by a chemical agent, such as calcium carbonate, such that a hand-size sample cannot be crushed into powder or individual soil particles by finger pressure.
Cohesive Soil: Clay (fine grained soil) or soil with a high clay content, which has cohesive strength. Cohesive soil does not crumble, can be excavated with vertical side-slopes, and is plastic when moist. Cohesive soil is hard to break up when dry, and exhibits significant cohesion when submerged. Cohesive soils include clayey silt, sandy clay, silty clay, clay and organic clay.
Dry soil: Soil that does not exhibit visible signs of moisture content.
Fissured: Soil material that has a tendency to break along definite planes of fracture with little resistance, or a material that exhibits open cracks, such as tension cracks, in an exposed surface. REV2.1 February 13, 2018 Page 68 | 165 The Elliott-Lewis Safety Manual Granular soil: Gravel, sand or silt, (coarse grained soil) with little or no clay content. Granular soil has no cohesive strength. Some moist granular soils exhibit apparent cohesion. Granular soil cannot be molded when moist and crumbles easily when dry.
Layered system: Two or more distinctly different soil or rock types arranged in layers. Micaceous seams or weakened planes in rock or shale are considered layered.
Moist soil: A condition in which a soil looks and feels damp. Moist cohesive soil can easily be shaped into a ball and rolled into small diameter threads before crumbling. Moist granular soil that contains some cohesive material will exhibit signs of cohesion between particles.
Plastic: A property of a soil that allows the soil to be deformed or molded without cracking, or appreciable volume change.
Saturated soil: A soil in which the voids are filled with water. Saturation does not require flow. Saturation, or near saturation, is necessary for the proper use of instruments such as a pocket penetrometer of sheer vane.
Soil classification system: For the purpose of this subpart, this is a method of categorizing soil and rock deposits in a hierarchy of Stable Rock. Type A, Type B and Type C, in decreasing order of stability. The categories are determined based on an analysis of the properties and performance characteristics of the deposits and the environmental conditions of exposure.
Stable rock: Natural solid mineral matter that can be excavated with vertical sides and remain intact while exposed.
Submerged soil: Soil that is underwater or is free seeping.
Type A soils: Cohesive soils with an unconfined compressive strength of 1.5 ton per square foot or greater. Examples of cohesive soils are clay, silty clay, sandy clay, clay loam and, in some cases, silty clay loam and sandy clay loam. Cemented soils such as caliche and hardpan are also considered Type A. However, no soil is Type A if:
1. The soil is fissured 2. The soil is subject to vibration from heavy traffic, pile driving, or similar effects 3. The soil has been previously disturbed 4. The soil is part of a sloped, layered system where the layer’s dip into the excavation on a slope of four horizontals to one vertical or greater 5. The material is subject to other factors that would require it to be classified as a less stable material
Type B:
1. Cohesive soil with an unconfined comprehensive strength greater than 0.5 tsf (48kPa) but less than 1.5 tsf (144 kPa) 2. Granular cohesion-less soils including angular gravel (similar to crushed rock), silt, silt loam, sandy loam and, in some cases, silty clay loam and sandy clay loam 3. Previously disturbed soils except those which would otherwise be classed as Type C soil 4. Soil that meets the unconfined compressive strength or cementation requirements for Type A, but is fissured or subject to vibration 5. Dry rock that is not stable 6. Material that is part of a sloped, layered system where the layer’s dip into the excavation on a slope less steep than four horizontals to one vertical (4H:1V), but only if the material would otherwise be classified as Type B REV2.1 February 13, 2018 Page 69 | 165 The Elliott-Lewis Safety Manual Type C:
1. Cohesive soil with an unconfined compressive strength of 0.5 taf (48 kPa) or less 2. Granular soils including gravel, sand, and loamy sand 3. Submerged soil or soil from which water is freely seeping 4. Submerged rock that is not stable 5. Material in a sloped, layered system where the layer’s dip into the excavation or a slope of four horizontals to one vertical (4H:1V) or steeper
Unconfined compressive strength: The load per unit area at which a soil will fail in compression. It can be determined by laboratory testing, or estimated in the field using a pocket penetrometer, by thumb penetration tests, and other methods.
Wet Soil: Soil that contains significantly more moisture than moist soil, but in such a range of values that cohesive material will slump or begin to flow when vibrated. Granular material that would exhibit cohesive properties when moist will lose those cohesive properties when wet. 16.6 Testing Requirements 1. Classification of soil and rock deposits. Each soil and rock deposit shall be classified by a competent person as Stable Rock, Type A, Type B, or Type C in accordance with the definitions set forth in the Definitions. 2. Basis of classification. The classification of the deposits shall be made based on the results of at least one visual and at least one manual analysis. Such analyses shall be conducted by a competent person using tests described in paragraph "D" below, or in other recognized methods of soil classification and testing such as those adopted by the America Society for Testing Materials, or the U.S. Department of Agriculture textural classification system. 3. Visual and manual analysis. The visual and manual analysis, such as those noted as being acceptable in paragraph "d" of this appendix, shall be designed and conducted to provide sufficient quantitative and qualitative information as may be necessary to identify properly the properties, factors, and conditions affecting the classification of the deposits. 4. Layered systems. The system shall be classified in accordance with its weaker layer. However, each layer may be classified individually where a more stable layer less under a lean stable layer. 5. Reclassification. If, after classifying a deposit, the properties, factors, or conditions affecting in classification change in any way, the changes shall be evaluated by a competent person. The deposit shall be reclassified as necessary to reflect the changed circumstances.
Visual tests.
1. Visual analysis is conducted to determine qualitative information regarding the excavation site in general, the soil adjacent to the excavation, the soil forming the sides of the open excavation, and the soil taken as samples from excavated material. 2. Observe samples of soil that are excavated and soil in the sides of the excavation. Estimate the range of particle sizes and the relative amounts of the particle sizes. Soil that is primarily composed of fine-grained material is cohesive material. Soil composed primarily of coarse-grained sand or gravel is granular material. 3. Observe soil as it is excavated. Soil that remains in clumps when excavated is cohesive. Soil that breaks up easily and does not stay in clumps is granular. 4. Observe the side of the opened excavation and the surface area adjacent to the excavation. Crack-like openings such as tension cracks could indicate fissured material. If chunks of soil spall off a vertical side, REV2.1 February 13, 2018 Page 70 | 165 The Elliott-Lewis Safety Manual the soil could be fissured. Small spalls are evidence of moving ground and are indications of potentially hazardous situations. 5. Observe the area adjacent to the excavation and the excavation itself for evidence of existing utility and other underground structures, and to identify previously disturbed soil. 6. Observe the opened side of the excavation to identify layered systems. Examine layered systems to identify if the layers slope toward the excavation. Estimate the degree of slope of the layers. 7. Observe the area adjacent to the excavation and the sides of the opened excavation for evidence of surface water, water seeping from the side of the excavation, or the location of the level of the water table. 8. Observe the area adjacent to the excavation and the area within the excavation for sources of vibration that may affect the stability of the excavation face.
Manual tests.
1. Manual analysis of soil samples is conducted to determine quantitative as well as qualitative properties of soil and to provide more information in order to classify soil properly. 2. Plasticity. Mold a moist or wet sample of soil into a ball and attempt to roll it into threads as this as 1/2 inch in diameter. Cohesive material can be successfully rolled into threads without crumbling. For example, if at least a two-inch (50 mm) length 1/8-inch thread can be held on one end without tearing, the soil is cohesive. 3. Dry Strength. If the soil is dry and crumbles on its own or with moderate pressure into the individual grains or fine powder, it is granular (any combination of gravel, sand or silt). If the soil is dry and falls into clumps that break up into smaller clumps but the smaller clumps can only be broken up with difficulty, it may be clay in any combination with gravel, sand or silt. If the dry soil breaks into clumps which do not break up into small clumps and which can only be broken with difficulty, and there is no visual indication the soil is fissured, the soil may be considered un-fissured. 4. Thumb penetration. The thumb penetration test can be used to estimate the unconfined compressive strength of cohesive soils. (This test is based on the thumb penetration test described in American Society for Testing and Materials (ASTm) Standard designation D2488 - "Standard Recommended Practice for Description of Soils (Visual-Manual Procedure)” Type A soils with an unconfined compressive strength of 1.5 tsf can be readily indented by the thumb; however, they can be penetrated by the thumb only with very great effort. Type C soils with an unconfined compressive strength of 0.5 taf can be easily penetrated several inches by the thumb, and can be molded by light finger pressure. This test should be conducted on an undisturbed soil sample, such as a large clump of soil, as soon practicable after excavation to keep to a minimum the effects of exposure to drying influences. If the excavation is later exposed to wetting influences (rain, flooding), the classification of the soil must be changed accordingly. 5. Other strength tests. Estimates of unconfined compressive strength of soils can also be obtained by use of a pocket penetrometer or by using a hand-operated shear vane. 6. Drying test. The basic purpose of the drying test is to differentiate between cohesive material with fissures, un-fissured cohesive material, and granular material. The procedure for the drying test involves drying a sample of soil that is approximately one-inch-thick (2.54 cm) and six inches (15.24 cm) in diameter until it is thoroughly dry: a. If the sample develops cracks as it dries, significant fissures are indicated. b. Samples that dry without cracking are to be broken by hand. If considerable force is necessary to break a sample, the soil has significant cohesive material content. The soil can be classified as an un-fissured cohesive material and the unconfined compressive strength should be determined.
REV2.1 February 13, 2018 Page 71 | 165 The Elliott-Lewis Safety Manual c. If a sample breaks easily by hand, it is either a fissured cohesive material or a granular material. To distinguish between the two, pulverize the dried clumps of the sample by hand or by stepping on them. If the clumps do not pulverize easily, the material is cohesive with fissures. If they pulverize easily into very small fragments, the material is granular. 7. The use of any allowable protective system is dependent on a determination of the soil classification.
17 Electrical Requirements
17.1 General 1. Employees shall be trained in safety related work practices that pertain to their respective job assignments. Employees who face a risk of electric shock but who are not qualified persons shall be trained and made familiar with electrically related safe practices. Training shall include clearance distances. 2. Electrical equipment on a project includes temporary feeds, extension cords, droplights, secondary distribution panels, droplights and receptacles for employee use. Electrical equipment and any temporary distribution equipment must be grounded. 3. A project, with the Safety Director and Project manager having responsibility for compliance, should implement one of two programs to ensure employee protection through grounding adequacy: a. Installation of Ground-Fault Circuit Interrupters (GFCI's) at the receptacles or breakers. b. Assured Grounding Continuity Program through periodic inspection of all temporary wiring to ensure the continuity of the third-wire ground. The inspection should be documented and performed by a competent person. 4. Temporary wiring should be installed only by a licensed electrician. Employees may use extension cords, tools, droplights, etc. that are energized by plugging into a standard receptacle up to 220 volts (except where labor agreements prohibit.). 5. Employees may not handle any temporary feed over 220 volts, or tamper with or attempt to repair any electrical distribution panels or hardwired feeds. 6. All equipment to be worked on must be de-energized and locked out and tagged out at the feed source. For rules on LO/TO, see section 11.5. 7. Conductors and parts of electrical equipment that have been de-energized but have not been locked or tagged out shall be treated as live parts. 8. Only qualified employees may work on electric circuit parts and equipment that have not been de- energized. These employees shall be capable of working safely on energized circuits and shall be familiar with the proper use of special precautionary techniques, PPE, insulation and shielding materials and insulated tools. 9. If work is to be performed near overhead lines, the lines shall be de-energized and grounded or other protective measures shall be provided before work is begun. A qualified employee shall adhere to the approach distance of one foot for less than 6oo volts. An unqualified worker shall remain a minimum of 10 feet from the line. Vehicles or mechanical equipment working near overhead lines shall maintain a clearance distance of 10 feet for all lines of 50kV or less. Insulating barriers are recommended to prevent contact of any kind. 10. Employees may not enter spaces containing exposed energized parts unless illumination is provided that enables the employees to work safely.
REV2.1 February 13, 2018 Page 72 | 165 The Elliott-Lewis Safety Manual 11. When an employee works in a confined or enclosed space that contains exposed energized parts, the company shall provide, and the employee shall use, protective shields, protective barriers or insulating materials as necessary to avoid inadvertent contact. 12. When employees are subject to handle long dimensional objects (ducts or pipes), they must be handled in a manner to prevent them from contacting exposed energized conductors or circuit parts. Use of insulation, guarding, and material handling techniques are required to minimize the hazard. 13. All ladders used on jobsites and service calls shall be non-conductive fiberglass. 14. Conductive articles of clothing and jewelry may not be worn if they might contact exposed energized parts. However, they may be worn if they are rendered nonconductive by covering, wrapping or insulating. 17.2 Ground Fault Circuit Interrupters (GFCI's; GFI's) 1. The company shall establish an assured grounding conductor program/ground fault circuit interrupter program on all sites covering all cord sets and receptacles which are not part of the building or structure and equipment connected by cord and plug which are available for use or used by employees. A site specific safety plan, including procedures, shall be made readily available. 2. On projects that choose to implement a GFCI protected system, all 15-20 ampere receptacles used by employees should have approved GFCI circuit protection, or temporary in-line GFCI receptacle boxes may be used in lieu of circuit protection from the distribution panel. 3. Portable power generators of more that 5-kw-capacity must have an inline GFCI installed. 4. Installation of GFCI circuit protection from the distribution panel should be done by a licensed electrician, however, portable/temporary in-line GFCI receptacle boxes can be installed by any employee. 5. GFCI circuits are designed to detect minimal electrical loss, measured as a constant potential between the two "legs" in the feed. GFCI's may continuously "trip" in damp locations, and for this reason may not be suitable for some operations. 17.3 Assured Grounding Continuity Program 1. As an alternative to GFCI protection, the following program may be implemented for a particular operation: 2. All extension cords used on the project must be inspected daily to assure that the third-wire ground is intact, and marked with a color code to indicate the current inspection period. 3. Permanent plant receptacles and receptacles on temporary panels should be checked initially for ground continuity. The receptacle does not have to be marked or re-inspected except where damage is suspected or repairs were performed. 4. Power tools that are not marked as double insulated should be checked each month for ground continuity between the ground lug and the tool body. 5. Only competent employees should be permitted to perform electrical continuity checks by use of a manufactured tester. (Competency is determined by training and familiarity with grounding test equipment, or occupation as an electrician). 6. Extension cords that are damaged or do not have a continuous third-wire ground should be repaired or discarded. 7. The following universal color-coding should be used for all projects:
January -White May -Green/Yellow September -Red & Blue February -White/Yellow June -Green/Blue October -Orange March -White & Blue July -Red November -Orange & Yellow April -Green August- Red/Yellow December -Orange & Blue
REV2.1 February 13, 2018 Page 73 | 165 The Elliott-Lewis Safety Manual 8. Employees on the project must be informed during their orientation, and periodically thereafter, that an electrical continuity check is performed monthly and that a new color code should appear on the cables each month. The color code for each new month should be posted in the employee change/lunch area following completion of the tests. Employees should be instructed not to use extension cords that have not been currently checked. 17.4 Electrical - General Requirements 1. In wet or damp locations, low voltage lighting or GFCI circuit protection should be sued. Where the installation or low voltage lights or GFCI is impractical, battery powered hand lamps may be used. 2. In hazardous locations where there is a danger of fire, explosion or accumulation of combustible gases, explosion proof Class I lighting must be used. a. The company Safety Director should be notified of any planned work in explosive, flammable or combustible atmospheres. 3. Portable electrical extension cords must have a third wire ground and must have a heavy-duty outer jacket that is capable of resisting chafes and cuts. Heavy-duty cable is defined as types SJ, ST, SJT, SO, SJO, or STO. 4. Stranded two wire light stringers are not permitted. Light stringer cords must be made of heavy duty cable, as described in No. 3 above, except where light stringers are suspended overhead and will be disturbed or repeatedly relocated, in which cases, spliced Romex wire lights pigtailed from the Romex may be used. 5. Employees may not plug extension cords or electrical tools into a light stringer by use of an adaptor. 6. Open lamp sockets on light stringers are not permitted. Each lamp must have a guard. 7. All temporary wiring should be elevated out of walkways and protected from chafes and cuts by use of cable-trees, cable-ramps or heavy mats to cover the cable. a. On roadways, cables must be protected by use of a cover, ramp or channel. 8. Power tools that are not double insulated must have a third wire ground and ground lug intact on the plug. 9. Quartz lights should not be used in close proximity to employees where the employee may come in contact with the light fixture. 17.5 Lockout / Tagout - Control of Hazardous Energy 1. Authorized employees shall be trained in the rules of lockout/tagout and includes recognition of hazardous energy source, type, magnitude of energy available, and methods and means necessary for energy isolation and control. The sources of potential energy include but are not limited to electrical, mechanical, steam, hydraulic, pneumatic, chemical, tension, and gravity. a. Training will address when lockout/tagout systems are used including the limitations of tags (tags are warning devices and do not provide physical restraint). b. Training should also include that a lock and tag are never removed without proper authorization. The process is never ignored or defeated in any way. c. Retraining is required when there is a change in job assignments, in machines, a change in the energy control procedures, new hazards are introduced, or a deficiency by an employee in following company policies is discovered. d. All training is documented, signed, and certified. e. Periodic inspections by the project manager and safety director shall be performed to ensure compliance of lockout/tagout. These inspections should be documented annually with the site, date, equipment, and the employees involved.
REV2.1 February 13, 2018 Page 74 | 165 The Elliott-Lewis Safety Manual i. When maintenance and repair of machinery and equipment is performed on a routine basis, this lockout/tag-out program will be implemented and strictly enforced. During this process posse, a large risk for deviation from stand practice, and must be closely monitored for correct implementation. 2. All affected employees, and any other employee whose work operations may be in an area where energy control procedures may be utilized, shall be notified of the process. 3. Installed and energized equipment on construction projects must be tagged at the feed source to prevent accidental energization. a. If an energy isolating device is not capable of being locked out, the Tagout energy control procedure shall utilized. i. Refer to sub-section with procedure to M (1) and N for Tagout utilization. b. If an energy isolating device is capable of being locked out, a lockout device shall be utilized to lockout the equipment. 4. Proper Job Hazard Analysis by the technician or project manager will determine the energy source and the procedure for protecting workers. Electrical and mechanical subcontractors must be informed of this procedure prior to equipment installation. a. Locks, tags, chains, wedges, key blocks, adapter pins, self-locking fasteners, or other equipment specific isolation devices will be determined from a pre-job walk through. All energy isolation devices will be provided to employee(s) at no cost. 5. Where employees could be injured while working in or around energized equipment, the equipment shall be tagged and locked out. 6. When several employees are working concurrently on the same equipment, each employee, including subcontractors, shall apply their own lock and/or tag to the group’s device while they are working and then remove it when finished. The authorized employee should ascertain the exposure status of individual group members. During shift changes, there should be specific procedures to ensure the continuity of lockout or tagout procedures. Documentation should be specific for the site. 7. Employees may not remove another employee's lock or tag under penalty of immediate dismissal. 8. The project manager, or other assigned employee of the general contractor, shall maintain a log of tagged equipment. a. Tag-out devices provided by the Safety Department. b. Locks (key or combination) keyed differently. c. Circuit breaker lockouts for single, double and triple pole breakers. d. Multiple lockout hasps. e. Valve lockouts for piping systems are available in many sizes. f. Lockout tags standardized in size and color with a warning of hazardous energy (Do Not Start, Do Not Open, do not Close, Do Not Energize, or Do Not Operate). i. If the Safety Department does not have the proper device to fit the job, the assignment will be delayed until the proper lockout device is located and purchased from a local supplier. g. Lockout tags must always identify the employee applying the device. 9. Before an authorized employee turns off a machine or piece of equipment. Affected employees shall be notified by the employer or authorized employee of the application and removal of lockout devices or tagout devices. Notification shall be given before the controls are applied, and after they are removed from the machine or equipment. 10. The authorized employee shall have knowledge of the type and magnitude of the energy, the hazards of the energy to be controlled, and the means to control it. The unit shall be shut down using the
REV2.1 February 13, 2018 Page 75 | 165 The Elliott-Lewis Safety Manual procedures established by the manufacturer prior to servicing. An orderly shutdown must be utilized to avoid any additional or increased hazards to employees as a result of the stoppage. 11. Process steps for implementation. a. Notify all affected employees i. Prior to equipment shut down, a verbal conversation will be held with client site management informing of the day and time the energy isolation and lockout process will be initiated. (Client and manufacturer procedures will be followed for shutting down to ensure proper de- energization). ii. Once the service has been completed, client site management will be notified of the pending equipment lockout removal and re-start of equipment date and time b. Identify the energy source c. Isolate the unit by de-energizing the circuit breaker or main disconnect Attach the lock and tag d. Control any stored energy (electrical capacitance). If there is a possibility of re-accumulation of stored energy, verification of isolation shall be continued until, the servicing is completed or the possibility of such accumulation no longer exists. e. Verify that energy state is zero 12. An authorized employee shall affix lockout or tagout devices to each energy-isolating device. The devices shall be affixed in such a manner as will clearly indicate that the operation or movement of energy isolating devices from the safe or off position. a. If equipment being serviced is incapable of accepting a lockout device and a lock. A Tagout system shall be used in its place if all research shows no way of attaching a physical lock. The utilization of a tagout system must be reviewed by the Safety Department and an engineer with knowledge of the system to ensure the unit is properly de-energized. 13. Tagout tags shall be fastened at the same point at which a lock would have been attached. Where a tag cannot be affixed directly to the energy isolating device, the tag shall be located as close as safely possible to the device in a position that will be immediately obvious to anyone attempting to operate the device. a. If equipment is capable of receiving a physical lockout device; a physical device shall always be utilized. 14. If a lockout device must be temporarily removed for additional testing of the unit, the technician or project manager shall ensure that all tools are cleared, all employees are removed from the area, the LOTO device should be removed, then energize and proceed with the testing. When completed, de- energize, and reapply all control measures as before. 15. Prior to equipment start-up, a work area walk through must be conducted by the authorized employee. The authorized employee will ensure all tools and materials used for the service are accounted for. The work area shall be inspected to ensure that nonessential items have been removed and to ensure that machine or equipment components are operationally intact. The authorized employee will ensure the work area shall be checked. They will ensure that all employees have been safely positioned, remove un- necessary employees, and located/stage necessary employees in a safe location prior to start-up. 16. After lockout or tagout devices have been removed and before a machine or equipment is started, affected employees shall be notified that the lockout or tagout device(s) have been removed. 17. Once the service has been completed, client site management will be notified of the pending equipment lockout removal and re-start of equipment date and time 18. Suggestions/Evaluation Employees are encouraged to make positive suggestions for the purpose of upgrading control of hazardous energy that may be peculiar to our industry. 19. Exhaust fan de-energize and lockout process:
REV2.1 February 13, 2018 Page 76 | 165 The Elliott-Lewis Safety Manual a. Locate the electrical disconnect and or breaker in the breaker panel for the exhaust fan that will be worked on. i. If the only apparent switch is located with-in the equipment itself, the job task is to stop at this point. This must be discussed with the site contact for further information on how and where to de-energize and lockout the unit. 1. If customer cannot provide the information needed to safely de-energize the unit, contact your immediate supervisor and wait for further instructions on how to proceed. b. Disconnect power to the exhaust fan unit. c. Apply isolation devices to energy source. d. Verify the equipment is at a “zero” energy state and cannot be turned on. e. Remove cap guard and proceed with task. 20. Field Inspections - Lock-out/Tag-out - Procedure a. Inspections will be made by the Safety Department along with the site project manager. These periodic inspections will be made randomly and without prior notice. b. Findings of these inspections will be documented and submitted to the corresponding managers for compliance evaluation. c. The inspection report will include any deviation from or inadequacies of our lock-out/tag-out policy. 21. Boiler and Chiller Servicing a. During boiler service and shut downs, boiler technicians are required to lockout multiple energy supply lines within a boiler system. They also could be involved with multiple locations at the same time. This program is intended to address lockout practices for boiler maintenance situations only. Boiler employees will be issued two lock boxes each with twelve black lockout locks keyed alike within that kit but different from all other kits. The lock boxes and locks will be numbered the same to ensure those locks are utilized for all the lockouts required on that job only and stay with that kit. One lock box, one set of locks, and one key per job. The key from the locked out energy supply lines and any extra locks from that kit will be placed in the lock box. An inventory lockout tag will then be placed on the lockout box, indicating the locations of every lockout device and lock that has been utilized. If a technician who didn’t perform the lockout procedure initially is now assigned to the task, they are required to use the inventory lockout tag to locate, inspect, and ensure that no lockout devices have been compromised prior to resuming work. When the inspection is completed and all lockouts are located and inspected per the inventory list, all employees working on that job will then place their personal red lockout on the lock box for true lockout compliance to ensure their personal safety against re-energization. When work is completed for each shift, if a relieving crew is not present, a company #2402 lock is placed on the lock box as maintenance protection for the boiler and all red personal lockout locks are removed. When the next shift arrives, they will also locate and inspect all lockout devices per the inventory list and place their red locks on the lock box for their personal protection until the task is completed. By utilizing the #2402 company lock on the lockbox when unattended, this will ensure that only an Elliott-Lewis employee will be able to access the key when the task is completed and re-energization can occur. Two kits will be distributed to each technician at random to begin with but may become interchanged between technicians as jobs are completed. The boiler technicians are responsible to return any additional kits they accumulate to the originally assigned technician or return extras to the service manager for proper re-distribution. It is important to remember that the #2402 company lock is only for maintenance lockout as
REV2.1 February 13, 2018 Page 77 | 165 The Elliott-Lewis Safety Manual protection for the unit being worked on. When a technician is preparing to work on a locked out boiler system, their personal red lockout lock and tag must be placed on the lock box, without exception. This will ensure lockout compliance and safety of all our technicians. 17.6 ARC Flash Protection Program / NFPA 70E-2015 Purpose: This NFPA 70E-2015 Arc Flash Protection Program provides updated safety guidelines to ensure the proper installation, maintenance, inspection, and testing of electrical circuits and equipment. These guidelines are designed to avoid injuries due to electrical fault incidents.
1. Training a. Training shall be provided to employees exposed to an electrical hazard when the risk associated with that hazard is not reduced to a safe level by the applicable electrical installation requirements. Employees shall be trained to understand the specific hazards associated with electrical energy and be trained in safety-related work practices and procedural requirements as necessary to provide protection from the electrical hazard associated with the job assignment. Employees shall be trained to identify and understand the relationship between the electrical hazards and possible injury, the creation of approach boundaries and understanding the Arc Flash PPE Categories. Training can be in a classroom, on the job, or a combination of the two. Employees must be trained in LO/TO procedures as outlined in section 16.5 of this manual. The level of training must be adequate for the tasks involved. b. Employees exposed to shock hazards must be trained in methods of release of victims from contact with exposed energized electrical conductors or circuit parts. Employees shall be regularly instructed in methods of first aid and emergency procedures, such as approved methods of resuscitation, if their duties warrant such training. Training of employees in approved methods of CPR shall be certified every two years. c. A qualified person shall be one who has demonstrated skills and knowledge related to the construction and operation of electrical equipment and installations and has received safety training to identify and avoid the electrical hazards that might be present with respect to that equipment or work method. In addition, the employee shall be trained in distinguishing energized parts from other parts, to determine nominal voltage of circuit parts and decision making regarding degree and extent of the hazards. They will be able to do the necessary planning in the selection and use of the proper PPE. Unqualified persons shall not be permitted inside the limited approach boundary at any time once that boundary has been determined and the hazards are exposed. A qualified employee shall be trained to select an appropriate voltage detector and shall demonstrate how to use the device to verify the absence of voltage, including interpreting indications provided by the device. The training shall include information that enables the employee to understand all limitations of the test instruments, equipment, and accessories that may be used and to ensure they are rated for the equipment to which they will be connected. The voltage detector shall be verified to be in good working order both before and after a test for the absence of voltage is performed d. NFPA 70E-2015 provides that re-training in safety-related practices shall be performed at intervals not to exceed three years. Retraining is also required when a task is performed less than once a year, if an employee is not complying with the designated practices, or for new technologies, equipment, or work practices. All training must be documented and maintained for the duration of employment and must include names and dates of the training. 2. Responsibility
REV2.1 February 13, 2018 Page 78 | 165 The Elliott-Lewis Safety Manual a. The employer is responsible for supplying the safety-related work practices contained in NFPA 70E and shall train the employee in those practices. b. The employee shall be responsible for implementing the safety-related practices. c. The host employer shall be responsible for informing the company and/or our employees of known hazards that are covered by this standard that are related to our work on their site and any documentation of that hazard. This includes hazards that might not be recognized by our company and/or employee and any information about the installation of the system that would assist us in making necessary arc flash assessments. Also, the host employer shall report to the company any violations of this standard while our employee is on their site. Our employee also has a responsibility to advise the host employer of unique hazards in their workplace presented by our work, any unanticipated hazards, and the measures taken to correct all hazards reported to them or found by them. 3. Risk Assessment Procedure a. A Risk Assessment procedure is an overall process that identifies hazards, estimates the likelihood and the potential severity of injury or damage to health, and determines if protective measures are required and what they may be. The two types of Risk Assessments used by the standard are arc flash risk assessment and shock risk assessment b. The risk assessment (job hazard analysis) procedure shall be used before work is started within the Limited Approach Boundary of energized electrical conductors and circuit parts operating at 50 volts or more or where an electrical hazard exists. This evaluation procedure is designed to determine the tasks involved, eliminate risk, reduce the frequency of exposure, reduce the magnitude or severity of exposure, enable the LO/TO process (See Corporate Safety Manual Section 16.5), and overall enhance the safety-related work practices. The goal is to establish an electrically safe work condition. An electrically safe work condition shall be achieved when performed in accordance with the lockout/tagout policy and verified by the following: i. Determine all possible sources of electrical supply to the equipment ii. After properly interrupting the load current, open the disconnecting device(s) for each source iii. Wherever possible, visually verify that all blades of the disconnecting devices are fully open or that circuit breakers are withdrawn to the fully disconnected position iv. Apply lockout/tagout devices in accordance with ELCO policies v. All test instruments, equipment, and their accessories shall be rated for circuits and equipment to which they will be connected. An adequately rated voltage detector shall be utilized to test each phase conductor or circuit part to verify they are de-energized. Test each phase conductor or circuit part both phase-to-phase and phase-to-ground. Before and after each test, determine the voltage detector is operating satisfactorily vi. Where the possibility of induced voltages or stored electrical energy (capacitors) exists, ground the phase conductors or circuit parts before touching them. c. If multiple employees are working on the circuit, a job briefing will be performed before the start- up of work and if any changes occur in the scope of the job. The job briefing shall cover the hazards associated with the job, the work procedures involved, any special precautions an employee would need to be made aware of, the energy source controls, and all PPE requirements d. Every electrical conductor or circuit part must be considered energized until proven otherwise e. No bare-hand contact is to be made with exposed energized electrical conductors or circuit parts above 50 volts
REV2.1 February 13, 2018 Page 79 | 165 The Elliott-Lewis Safety Manual f. De-energizing an electric conductor or circuit part and making it safe to work on is, in itself, a potentially hazardous task g. The Risk Assessment shall include elements that consider the condition of the electrical equipment and the maintenance provided in the past h. The hierarchy of risk control methods specified in the standards shall be: i. Elimination ii. Substitution iii. Engineering controls iv. Awareness v. Administrative controls vi. Personal protective equipment 4. Electric Shock Hazard a. Electric shock was the original purpose of NFPA 70E-2004. To eliminate this hazard, we need to know the source of the hazard, how the exposure could occur, how the human body would react, and what action is necessary. The first course of action is to mitigate the hazard by de-energizing. If de-energizing is impossible or impractical, the employee must determine what action would minimize the hazard, and what PPE would minimize the exposure. A shock hazard analysis shall be performed to determine the voltage to which the employee will be exposed, boundary requirements, and the PPE necessary in order to minimize the possibility of electric shock. Determine approach boundaries utilizing table 130.4(D)(a) of NFPA70E-2015 5. Arc Flash Hazard a. An arc flash is a dangerous condition associated with the possible release of energy caused by an electric arc. An arc flash hazard may exist when energized electrical conductors or circuit parts are exposed or when they are within equipment in a guarded or enclosed condition, provided a person is interacting with the equipment in such a manner that could cause an electric arc. Under normal operating conditions, enclosed energized equipment that has been properly installed and maintained is not likely to pose an arc flash hazard. b. An Arc Flash risk Assessment will be conducted prior to work on any equipment. This assessment will determine if an arc flash hazard exists. If an Arc Flash hazard is potential, the corrective measures will be determined from the information gathered in the assessment. With the information gathered, the employee will be able to determine the: i. Appropriate safe work practices ii. Establish the arc flash boundary iii. The PPE required for work with-in the arc flash boundary The level of PPE required and arc flash boundary will be determined by using the information of the system to be worked on, and the information in table NFPA 70e table130.4(D)(a). All information and calculations will be documented and submitted to the Safety Department. 6. An arc flash hazard analysis shall be performed to determine the flash protection boundary and the level of necessary PPE needed within the boundary shall use. The arc flash analysis shall consider the short circuit energy available and the clearing time of the OCPD (over current protective device). The design of the OCPD and its opening time along with its maintenance condition must be taken into consideration. The clearing time depends upon arcing current and arcing current depends upon the short circuit current available. This will be further discussed in section “H”. The arc flash boundary shall be permitted to be determined by table 130.7(C)(15) (A)(b) or 130.7(C)(15)(B). Because of the nature of our service business, detailed arc flash hazard analysis calculations are not usually available and a standard arc flash boundary of at least five feet can be utilized.
REV2.1 February 13, 2018 Page 80 | 165 The Elliott-Lewis Safety Manual 7. An energized electrical work permit is required when working on energized electrical conductors or circuit parts that are not placed in an electrically safe work condition. The electrical work permit shall include the description of the circuit and equipment to be worked on. This shall include: justification for why the work must be performed in an energized state, a description of the safe work practices to be employed, results of the hazard risk evaluation, determination of the approach boundaries, the necessary PPE, means employed to restrict the access of unqualified individuals from the work area, evidence of completion of a job briefing, and approving signatures from the authorizing or responsible management or safety officer. Work performed within the limited approach boundary of energized electrical conductors or circuit parts by a qualified employee related to testing, troubleshooting, voltage measuring, thermograph y and visual inspection (provided the restricted boundary is not crossed) is exempted from the work permit requirement provided appropriate safe work practices and PPE are used. a. Arc Blast Hazard i. NFPA 70E does not address arc blast as there is no known means at this time to offer viable protection b. Approach Boundaries i. There are two approach boundaries: 1. Limited Approach Boundary = no unqualified persons shall be permitted to approach nearer than this to energized conductors and circuit parts 2. Restricted Approach Boundary = the closest boundary that is reserved for qualified persons only and shock and arc protection are required ii. The approach boundaries are determined utilizing shock and arc flash hazard analyses or the default table 130.4(D)(a) of NFPA70E-2015. In most cases, for our purposes the table will be the determining factor. The standard determines where detailed analysis calculations are not performed for systems between 50 volts and 600 volts, the limited approach distance will be 3 feet 6 inches. This is based on the product of clearing time of 2 cycles (0.033 secs.) and the available short circuit energy of 50kA. A standard of four feet is used as an arc flash boundary. 1. Red Danger tape and signage will be hung around the work area notifying employees outside of the work of the hazards within. c. Arc Flash PPE Categories i. Where it has been determined that work will be performed within the arc flash boundary, the incident energy exposure level for the employee needs to be calculated. Table 130.7(C)(15)(A)(b) or table 130(C)(15(B) can be used instead of the calculations for arc flash PPE categories. In most cases, it has been determined that the bulk of our work is an arc flash PPE category 2, which includes circuits greater than 240volts and up to 600 volts. In a few isolated cases and locations in the HVAC service department and building services department, the arc flash PPE category is 4, where work on a chiller with a 4160- volt circuit or racking a 13,200-volt breaker may be required. d. Personal Protective Equipment i. NFPA 70E 130.7(A) and table 130.7(C)(14) mandates that employees working in areas where electrical hazards are present shall be provided with, and shall use protective equipment that is designed and constructed for the specific part of the body to be protected and for the work to be performed. Elliott-Lewis has provided its employees who could be exposed to an Arc Flash PPE Category 2 with Indura full length coats, protective leggings, Class E hard hats with attached arc shields, a balaclava (sock hood),
REV2.1 February 13, 2018 Page 81 | 165 The Elliott-Lewis Safety Manual and Class 0 rubber electrical gloves with leather liners. In most cases, this equipment exceeds the requirements of category 2 of the standard. ii. Those sites where an employee could be exposed to an Arc Flash PPE Category 4, shall be supplied with Indura full length coats and leggings rated to 40 calories, arc flash hoods rated to 40 calories, and Class 2 rubber electrical gloves with leather liners rated to 17,000 volts. 1. An arc flash rating is a value attributed to materials that describes their performance to exposure to an electric arc discharge. The arc rating is expressed in calories per centimeter squared and is derived from the determined value of the arc thermal performance value (ATPV) or energy of the “breakopen” threshold. “Breakopen” is a material response evidenced by the formation of one or more holes in the innermost layer of flame-resistant material that would allow flame to pass through the material. iii. All equipment shall be maintained in a safe and reliable condition. The PPE shall be inspected before each use. Protective equipment shall be stored in a manner to prevent damage from physically damaging conditions and from moisture, dust, or other deteriorating conditions. In the event of an incident, the protection shall be immediately inspected thoroughly to ensure the protection has not been compromised in any way. iv. When they become dirty, all Indura coats and leggings will be returned to the Safety Department for laundering and replacement. If any item becomes damaged or torn, the employee shall tag the item prior to turning it in. Tags are provided from the Safety department. If possible, the provider will repair it. Elliott-Lewis provides laundering and long term care for the garments. The only requirements are that they be laundered alone in a basic laundry detergent with no fabric softener or bleach. When they become worn, return them to the Safety Department for replacement 1. The employee will launder balaclavas. v. Personal clothing worn when performing electrical work with or without fire retardant clothing shall be made of natural fibers such as cotton, including underwear. vi. Insulated hand tools are required whenever you are working with energized circuits. Insulated tools offering high resistance to the passage of current.. vii. All jewelry shall be removed prior to working on or near energized parts. viii. Because of the dark shade of the arc shield, always ensure that proper lighting is provided to enable proper vision at all times. 8. All employees trained in Arc Flash Protection will receive a card recognizing they have been trained, a copy of the tables from NFPA70E, and this Arc Flash Corporate Safety Program. OSHA requires that these guidelines be enforced and in the event of non-compliance, the employee will be disciplined based on Section 5 of this manual. These guidelines have been created for the protection of the employees and their health and safety while on the job. Job site audits will be conducted on each employee yearly. This is to ensure effectiveness of this program in conjunction with a written program audit. This program will be updated for correct regulations as the NFPA 70e standards are updated. 17.7 Revision Revision Date: Revised By:
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18 Right to Know/ Hazard Communication/Globally Harmonized System
18.1 General 1. OSHA regulations require that an employer: a. The Elliott-Lewis will develop a hazard communication program. b. The program will cover all required standards from 29 CFR 1910 and 29 CFR 1926. The program will cover areas such as labels of materials and chemicals, warning signs, SDS usage and locations, employee rights and duties, training requirements, and so on. i. Provide training annually to employees in the recognition of classifications of hazardous material. c. Each facility and temporary project site will have a copy of Right to Know/ Hazard Communication/Globally Harmonized System program from the Elliott-Lewis Safety Manual available for review on hand. d. Maintain a file or book of Safety Data Sheets (SDS) at each facility and temporary project site, and an inventory of chemical products at each location. The employer shall have an SDS for each chemical used with the exception of consumer products. SDSs shall be maintained and readily accessible in all work areas. SDS’s can be maintained at a primary site. However, they should be available in case of an emergency or upon request. i. All SDS’s are available through the SDS Binderworks application. This application will house all SDS files from every chemical using and available to use at any of our locations. e. Properly label all hazardous material indicating the hazard to a user and protection requirements while using the product. f. Inform an employee that they may have access to information about a hazardous material and may refuse to work with that material (or ask for an alternative assignment) without fear of retribution should the employer not comply with the employee's request or provide adequate protection. The information must be produced within five working days. 2. The project manager shall arrange for hazard communication training of new employees upon hire, as part of the new hire orientation. 3. The project manager shall ensure that all project supervision is aware of the requirements of this program through supervisors training, and that in the course of their work they shall ensure that employees do not handle hazardous material without proper training and protective equipment. 4. The employee/new-hire training program shall include: a. A review of the applicable right to d. How to use the SDS Binderworks know legislation and their right as an Application. employee to request information e. How to read an SDS regarding hazardous materials with f. How to recognize and understand which they are working or to which hazard labels they may be exposed. g. How to recognize the need for b. The location of the SDS book. proper protective equipment c. The chemical product inventory.
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(A complete training outline is included in this section of the manual.)
18.2 Requesting Information 1. An employee may request information about any hazardous substance they are working with or exposed to during their employment. This information is provided to the employees by allowing them the opportunity to review the SDS for the product. The employee may have a copy of the SDS if requested in writing. 2. An employee may request information verbally, but a copy will not be provided unless the request is written by the employee or a recognized designee. 3. It shall be the policy of this company to respond to verbal requests promptly to avoid regulatory interference and work refusals. The employee should be asked, however, to submit his request in writing by using the request form found in the project's SDS book, and as Attachment A of this section. 4. Upon receiving a written or verbal request for information, the project superintendent shall assure that every attempt is made to obtain the SDS. If the SDS is not on file at the project, check with the Philadelphia office or contact the manufacturer or supplier. a. An SDS is best obtained by calling the manufacturer or the supplier of the product. The SDS may be sent to the project promptly by fax or overnight mail. 5. After the employee has been given the opportunity to review the SDS, the employee must complete and sign the request/review form (See Attachment A of this section). Keep the original completed request form in the SDS book. 6. An employee may refuse to work with or refuse to continue to be exposed to any unidentified substance, chemical or material if the company has not: a. Disclosed the identity and contents of the product by providing the SDS within five working days, or b. Provide proof to the employee, in writing, that a diligent effort has been made to obtain the SDS. 7. In the event an employee is required to perform a non-routine task, the Project Manager in conjunction with the Safety Department will perform a job hazard analysis to determine the hazards of the task. When the analysis is complete, any SDS necessary will be provided to the employee, job controls put into place to minimize any hazards involved, and PPE that will be required. 8. Labels shall be legible, in English. However, for non-English speaking employees, information may be presented in their language as well.
The Safety Department shall be notified immediately if there is any delay in responding to an employee request for an SDS. 18.3 Non-Discrimination 1. Once the employee is provided with the SDS, the employee may be required to return to work with the product, provided proper protective equipment has been issued. 2. An employee may request information only for the products that they are using, or for which they may be exposed, without fear of reprisal or discrimination for their request.
REV2.1 February 13, 2018 Page 84 | 165 The Elliott-Lewis Safety Manual 18.4 Compliance Methods 1. The project superintendent shall assure that the appointed project safety monitor on each project inventories the chemical products and hazardous materials on a regular basis, but in no case less than monthly. a. The inventory shall be compared to the SDS Book and the Hazardous Material Purchase Log and the manufacturer or supplier shall be contacted to supply any missing SDS. 2. A copy of the inventory shall be posted in a conspicuous location for employees to review and a copy shall be kept with the Hazardous Material Purchase Log. 3. The project superintendent shall assure that the project safety monitor assigned to the project inspects the project at least weekly for unlabeled containers. The project safety monitor shall be given the authority to properly label containers or return unlabeled containers to a storage area for labeling. 4. The company Safety Director shall be responsible for assuring that each project complies with the requirements of this section. Compliance shall be monitored at least quarterly using the company Project Safety Audit form. 18.5 Multi-Employer Jobsites 1. Overall site safety issues are the responsibility of the Controlling Contractor. Our employees should ensure attendance at safety orientations and meetings to familiarize themselves to any site-specific issues. When sub-contractors are using chemicals on our job sites, precautionary measures are to be taken and methods of providing information on labeling systems shall be made available to all contractor employees. In addition, our company Hazcom program shall be made available to the Controlling Contractor and, if requested, our sub-contractors. 18.6 Hazardous Material Control Environmental Protection 18.6.1 Definition
Hazardous material is best defined as any substance, solid or liquid, a vapor, fume or gas, which is potentially toxic, incompatible with other substances, corrosive, explosive, flammable (or combustible), or poses any unusual physical hazards.
To the user, a hazardous material can be a skin, mucous membrane or respiratory irritant, a toxin to a specific target organ, or it may cause a severe and acute systemic reaction when inhaled, absorbed or accidentally ingested. It can have latent affects, where a long term or acute exposure may cause cancer, organ damage or muta-genetic affects.
Environmentally hazardous materials are listed by each state with Chemical Abstract System (CAS) numbers.
A list of hazardous materials and chemicals found in the common products used in the construction industry can be found as Attachment A following this section. A copy of the OSHA Hazardous chemical list can be found as Attachment B. Use these lists as a reference guide.
18.6.2 General
This section is intended to comply with the federal and state regulatory agencies that govern the purchase, storage, use, disposal and exposure to hazardous materials. The procedures outlined in each sub-section are written to comply with the standards of the EPA, OSHA, DER, NFPA and state laws. All project locations are required to comply with these basic procedures. Assistance with any additional requirements imposed by individual states will be provided by the company Safety Department.
REV2.1 February 13, 2018 Page 85 | 165 The Elliott-Lewis Safety Manual By complying with these procedures, project personnel and the environment will be protected from negligent exposures, and the company will be protected from regulatory citations and penalties associated with the use, disposal and exposure of hazardous materials.
1. Before purchasing any liquid or dry chemical product, such as paints, epoxies, insulation materials, acids, thinners, degreasers, oils, lubricants, or any product containing metals, such as galvanizing agents, weld rod, or any other product containing nickel, chromium or cadmium, check the list of hazardous materials for the applicable state and the list included at the end of this section. a. If the product or a component appears on this list, or if there is any question regarding the toxicity or hazard associated with a product, call the corporate safety department for assistance before purchasing the product. 2. If the hazards of a product far outweigh the benefits of using a product, then product substitution will be recommended. 18.7 Purchasing 1. The project superintendent and the individual responsible for purchasing materials at each project location are responsible for complying with this section of the procedure. 2. The purchaser shall maintain a log of hazardous materials purchased. Any product listed in this section shall be considered a hazardous material and logged upon purchase. 3. The purchaser shall notify the company safety manager before purchase of any flammable or combustible product purchased in a single quantity of more than 55 gallons’ liquid, or 550 pounds’ dry weight. Special storage requirements may be imposed. 4. The purchaser shall request, at the time the order is placed with the supplier, a Material Safety Data Sheet (MSDS) to be delivered with the product. If a purchase order form is used to order the product, then the form should be marked or stamped in bold letters “SDS REQUIRED UPON DELIVERY." 5. Upon delivery, the purchaser or receiver shall: a. Note the delivery date of the product to the Hazardous Material Purchase Log. b. Give a copy of the SDS to the project superintendent or safety monitor for filing in the Project SDS book. Stamp the SDS with the date received and the project name and send a copy of the SDS to the home office Safety Department. c. Check the shipping container for proper labeling. If the container is not properly labeled, note this in the Hazardous Material Purchase Log and label the container as required. (For labeling requirements, see the labeling requirements section of this procedure.) 6. If a product is delivered without an SDS, the purchaser shall immediately contact the supplier/distributor by telephone and request an SDS (preferably by fax). a. If the product Hazardous Warning Label (DOT or equivalent label) on the shipping container indicates a health hazard no greater than 1, then the product may be issued to the field for use while awaiting the SDS. b. If the health hazard rating is greater than “1,” then the product may not be issued to the field without permission from the company safety director for notification of non-compliance to the Commission of Labor. 7. In cases where the client/customer supplies specified chemical(s) or other hazardous material to the project, the project superintendent shall assure that the following actions are taken: a. Inventory all chemical products supplied to the company by the client. List these products in the Hazardous Material Purchase Log. Write “Client Supplied” in the Date Received column. b. Request an SDS for those products from the client. If an SDS is not received within five business days following the request, notify the company safety director. Document all requests. REV2.1 February 13, 2018 Page 86 | 165 The Elliott-Lewis Safety Manual c. Any product supplied by a client that is listed on the company hazardous material list or the OSHA list as a carcinogen or neurotoxin may not be issued for field use without permission from the company safety director or until an SDS is received and precautions are taken. d. All field use secondary containers must be labeled as explained in the labeling requirements section of this procedure. A secondary container is defined as the final container used to dispense the product in the work area, such as a safety can, bucket, etc. 8. If there is any question regarding the purchase or proper labeling of a hazardous material, contact the company safety director. 18.8 Labeling Requirements 1. The purchaser or receiver shall be responsible for assuring that the shipping container of any hazardous material is properly labeled. The project superintendent shall be responsible for assuring that any secondary field use containers are properly labeled by the employee. a. A field use container label contains all of the above, except the CAS number and the name of the manufacturer or supplier. 2. A proper bulk container label contains all of the following: a. Labels in English d. Signal Word b. Product and supplier identification e. Hazard Statement c. Pictogram(s) f. Precautionary Statement
3. If a shipping container is received without a proper label, the purchaser or receiver shall be responsible for labeling the container before it is issued to the field, or used for dispensing. When receiving new container of materials, all labels shall remain intact as they came from the manufacture. Labels shall not be removed or written on in any fashion to prohibit the ability to read the information. a. All labels shall be kept in a legible form for easy in identify the chemicals/materials within the container. b. the labels shall all be written in English. i. If an employee does not read English, that employee’s language must be used on the label along with the English version so that all employees are aware of the hazards in the container. 4. Secondary containers used to dispense from a bulk container for field use must be labeled. The project superintendent shall be responsible for assuring that employees label or tag field use containers. 5. The company purchasing manager or warehouse manager shall assure that any hazardous materials shipped from the company warehouse are properly labeled. Further, they shall assure that the vehicles used to transport such materials are properly marked with a DOT shipping sign. 18.9 Storage and Handling 1. The storage of any toxic, caustic, corrosive, combustible or flammable liquid must comply with the storage requirements outlined in the SDS, the MFPA, the EPA, or other applicable agency, or as directed by the company safety director. 2. The purchase and subsequent storage of any chemical liquid or any flammable liquid in a single quantity greater than 55 gallons must be approved by the company safety director. 3. The following are basic storage requirements: a. Flammable or Combustible Liquids: i. Dispensing drums and the secondary containers must be grounded while dispensing. ii. The storage area must be posted 'NO SMOKING' and a fire extinguisher must be located within 25 feet of the container.
REV2.1 February 13, 2018 Page 87 | 165 The Elliott-Lewis Safety Manual iii. Where quantities greater than 25 gallons are stored, a diked area, using sandbags or dirt, must be built. iv. Flammable liquid may not be stored inside a building in quantities larger than 10 gallons. v. Flammable and combustible liquids may only be dispensed in the field from improved metal safety cans with a self-closing spout and splash screen. b. Toxic, Caustic and Corrosive Chemicals: i. Consult the SDS for storage incompatibilities. ii. Storage areas must be diked with sandbags, dirt or concrete. iii. An emergency eye wash station must be in the immediate vicinity and unobstructed. iv. Storage inside closed areas may require forced ventilation. v. Dispensing any quantity may require special containers for field use and personal protective equipment. vi. The dispensing/storage area must be protected from rainwater, or the drum openings must remain closed. 18.10 Subcontractor Requirements 1. Subcontractors on multi-employer work sites are required to submit an SDS to the project superintendent of the company for each chemical product and hazardous materials prior to delivering such product onto the project. 2. Subcontractors are responsible for their own waste disposal, except under special arrangements with the project manager. 3. The subcontractor contract shall include the requirements of this section and permit cease and desist action in cases where a subcontractor fails to comply. The company may, at the project manager’s discretion, remove any hazardous material brought on site by a subcontractor if the subcontractor fails to comply with the requirements of this section. 18.11 Hazardous Waste Disposal Area 1. Each project shall establish a hazardous waste disposal area, except on those projects where the property owner/client agrees to allow the company to use their waste disposal area. The waste disposal area shall be set up using the following guidelines: a. At least one empty 55-gallon drum shall be available for each of the following hazardous waste categories used on the project as listed below. Each SDS for products in use on the project should be checked for incompatibilities before mixing waste. i. waste solvents iii. waste oils, lubricants ii. thinners and de-greasers iv. waste detergents, soaps and cleaners
b. The waste disposal area should be located in an outside area that is immediately available to the work areas, but is accessible for the waste hauler. The area should be at least 25 feet from any permanent building. c. A drum storage area shall be established for waste disposal. Empty drums are available from local waste haulers. The drums shall have lids and shall be labeled as "WASTE" with the category of the waste on the label and a start date for tracking waste storage time limits. d. A sheet of 20-gauge plastic poly shall be placed on the ground under the drums and a containment dike made of sandbags, a sand mound or dirt shall encompass the drums, or a commercial brand containment pallet shall be used.
REV2.1 February 13, 2018 Page 88 | 165 The Elliott-Lewis Safety Manual e. Where flammable or combustible waste is stored, a 15-20 pound of dry chemical fire extinguisher shall be located within 25 feet of the drum(s) and the area posted "NO SMOKING." f. The waste disposal area shall be inspected for leaks and damage during the safety monitor/rep daily project. 18.12 Employee Training Employees shall receive instruction during their new hire orientation that waste oils, solvents and other liquids must be segregated for proper disposal by using the established waste disposal area. They shall be instructed not to dump waste into drains, storm sewers or onto the ground. Attendance must always be taken, and the instructor must sign the attendance sheet.
1. Right to Know Legislation a. Requires an employer to have an SDS on file for the following products: i. Any Chemical Products that contain hazardous ingredients ii. Products that contain normally non-hazardous ingredients that may become hazardous if used/applied other than as intended by the manufacturer. b. Allows employees to request a review and/or copy of any SDS for a product with which they are working or to which they may be exposed. The company has five days in which to: i. Produce the SDS, or ii. Provide evidence to the employee of a diligent effort to get the SDS. c. Requests from the employee to the employer must be in writing to document employer compliance. A request form is available from the project office. 2. The Safety Data Sheets. In the Globally Harmonized System (GHS), all Safety Data Sheets have up to 16 sections of which 12 are mandatory. They must be organized in the following specific order: a. Product Identification i. GHS Product Identifier or other means of identification ii. Recommended use of the chemical and restrictions iii. Supplier’s name, address, phone number & emergency numbers b. Hazard Identification i. GHS hazard classification of the substance ii. Pictograms, signal word, and hazard statement iii. Precautionary statements iv. Description of any hazards not otherwise classified c. Composition/Information on Ingredients i. Chemical identity ii. Common name and synonyms iii. CAS numbers and other identifiers iv. Impurities and stabilizing additives which are themselves classified and which contribute to the classification of a substance v. Mixtures require the same information including the concentration ranges of all ingredients d. First Aid Measures i. Necessary first-aid instructions ii. Most important symptoms/effects, acute and delayed iii. Indication of immediate medical attention and special treatment e. Fire-fighting Measures REV2.1 February 13, 2018 Page 89 | 165 The Elliott-Lewis Safety Manual i. Suitable extinguishing media ii. Specific hazards arising from the chemical iii. Special protective equipment and precautions for fire fighters f. Accidental Release Measures i. Personal precautions, protective equipment, and emergency procedures ii. Environmental precautions iii. Methods and materials for containment and cleanup g. Handling and storage i. Precautions for safe handling ii. Conditions for safe storage, including any incompatibilities h. Exposure Controls/Personal Protection i. Occupational exposure limit values ii. Personal protective equipment to minimize worker exposure iii. Engineering controls to minimize worker exposure i. Physical and Chemical Properties of the Substance or Mixture i. Minimum information requires consists of appearance, odor, odor threshold, vapor pressure, pH, relative density, melting/freezing point, solubility, initial boiling point and boiling range, flash point, evaporation rate, flammability, upper/lower flammability/explosive limits, auto-ignition temperature, decomposition temperature, and viscosity j. Stability and Reactivity i. Reactivity ii. Chemical stability iii. Possibility of hazardous reactions iv. Conditions to avoid (e.g. static discharge, shock or vibration) v. Incompatible materials k. Anticipated hazardous decomposition products that could be produced toxicological information i. Routes of exposure ii. Description of the symptoms iii. Description of the delayed, immediate, or chronic effects iv. Numerical measures of toxicity l. Ecological Information (Non-mandatory) i. Toxicity data performed on aquatic/terrestrial animals ii. Persistence and degradability iii. Bioaccumulation potential iv. Mobility in the soil v. Other adverse effects m. Disposal Consideration (Non-mandatory) i. Recommendations of appropriate disposal methods ii. Appropriate disposal containers to use iii. Special precautions for landfill or incineration disposal n. Transport Information i. UN number and proper shipping name ii. Transport hazard class(es) iii. Packing group number (if applicable) iv. Environmental hazards
REV2.1 February 13, 2018 Page 90 | 165 The Elliott-Lewis Safety Manual v. Guidance on transport in bulk vi. Special precautions in connection with the transport within or outside premises o. Regulatory Information i. Identifies the safety, health, and environmental regulations specific for the product in question p. Other Information i. When the SDS was prepared or date of last revision 3. Labeling Requirements a. All containers must be labeled as follows: i. Product Name iv. Signal Word ii. Manufacturer or Supplier v. Hazard Statement iii. Pictogram(s) vi. Precautionary statement
b. Employees dispensing chemicals from a bulk drum are responsible for ensuring that the field use container is labeled. 4. Emergency Procedures a. Notify a company supervisor immediately. b. When possible, remove affected personnel from any exposure area. c. Never enter a confined space to attempt a rescue without rescue equipment, including lifeline and self-contained breathing apparatus. 18.13 Waste Removal 1. All waste removal shall be performed by a licensed hauler using a *** manifest system. The project manager shall be responsible for arranging for local waste disposal. 2. No more than 55 gallons of waste per waste category shall be permitted to accumulate on any project for more than 90 days. At the completion of a project, the project manager shall be responsible for arranging for the final removal of hazardous waste. Waste shall not be left on customer property. 3. A copy of each waste manifest shall be forwarded to the company safety director. 18.14 Spills, Leaks and Accidental Contamination 1. Any major spill or damage to a waste disposal area shall be reported to the company safety department immediately. In case of a spill, efforts shall be made to contain the spill using sand or dirt. Where quantities of more than 500 gallons of chemical products are stored in one location, a hazardous waste spill team shall be trained and deployed to control contamination. 2. In case of a spill or any other environmental contamination to any owner/client property shall be immediately reported to the owner/client representative and the company safety department. 3. Projects requiring the storage of any liquid chemical product or liquid waste in any single container greater than 50 gallons will be required to have the following emergency spill equipment immediately available:
6-8 Sandbags Shovel 25-50 feet of absorbent 'Ppgs' Rake 50 lbs. Oil-dry absorbent Plastic sheeting Over-pack drum Plastic waste bags Respirator with HEPA & Tyvek suits organic vapor cartridges Rubber boots Rubber and latex gloves Drum leak plug Barrier/warning flagging No smoking signs REV2.1 February 13, 2018 Page 91 | 165 The Elliott-Lewis Safety Manual 18.15 Safety Data Sheets 1. The following Safety Data Sheets pertain to all the chemicals that are typically carried in our service vehicles. 2. If you encounter any additional chemicals, please contact the Safety Director for SDS Request Forms. They will then be entered in our Safety Manual. 3. These SDS Sheets are available at the Elliott-Lewis home office and SDS Binderworks.
19 Fire Prevention and Fire Protection
19.1 General Fire prevention procedures are designed to prevent the occurrence of fire due to accidental causes. All employees will be trained in fire prevention at hire and annually thereafter.
1. The project Superintendent is responsible for ensuring that fire prevention procedures are followed by employees and that fire extinguishing equipment is available and in good working order prior to mobilizing. All portable fire extinguishers shall be checked monthly and be maintenance checked and retagged annually. 2. On projects that require hot work permits/weld permits, welders must receive an indoctrination of the permit system and site fire prevention procedures when they are hired. On projects not requiring hot work permits, the company Safety Director or the Project Superintendent may designate certain areas of the project as hot work controlled areas. Examples of such areas include; combustible material storage areas, rubber lined tanks and pipes, potentially explosive atmospheres, cable spreading rooms or control equipment rooms, etc. 3. Fires on a project, no matter how small, must be documented using the Incident Report Form. A client representative must also be notified immediately and should be given a copy of the fire incident report. Any property damage or injuries caused by a fire on a project must be reported to the Safety Director immediately. 19.2 Fire Prevention Plan 1. A list of all major workplace fire hazards, including hazardous chemicals, their proper handling, storage procedures and the type of firefighting equipment required. 2. Names of employees responsible for maintenance of fire prevention and control systems. 3. Names of employees responsible for purchasing and control of fuel source hazards. 4. The employer shall control accumulations of flammable and combustible waste materials so that they will not contribute to a fire emergency. 5. The employer shall train the employees to recognize fire hazards. 6. The training shall be documented. 19.3 Flammable Liquids and Solvents 1. The company Safety Director must be notified of any intended bulk purchase of a solvent, de-greaser, acid or caustic liquid. 2. The following major hazards should be considered prior to solvent use: a. Toxicity - solvents and de-greasers as a group are toxic to varying degrees. Exposure can occur through inhalation, absorption and ingestion. Major systemic changes in the human body can occur from short exposure to certain solvents as well as severe allergic reactions. REV2.1 February 13, 2018 Page 92 | 165 The Elliott-Lewis Safety Manual b. Flammability/Combustibility - Virtually all solvents are classified as combustible or flammable. Vapors released from these solvents can be explosive. Special storage, fire prevention and fire protection requirements are necessary for solvent use. c. Hazardous Waste and Environmental Concerns - Disposal of waste solvents and chemicals is strictly regulated in virtually all states. Violation of these regulations can jeopardize the company and our client. (See Section 12.0 of this manual). 3. Never use flammable liquids that are not intended by the manufacturer for cleaning purposes as a solvent or a cleaner. 4. Always provide adequate ventilation when using a solvent. Solvents generally have good "warning properties," in that they have an odor. When the odor becomes strong or overpowering, then ventilation is not adequate. An LEL monitor may need to be required to monitor the concentration on the material in the atmosphere. 5. Smoking, open flames, temporary heaters and spark producing devices are not permitted in areas where solvents are used. 6. Areas where solvents are used and stores must be flagged-off/barricaded and "NO SMOKING, OPEN FLAME" signs must be posted. 7. An ABC fire extinguisher must be within 10 feet of an area where solvents are used or stored. 8. Flammable liquids, such as gasoline, may not be stored inside of a building in quantities greater than 25 gallons. 9. Bulk storage of flammable or combustible liquids in quantities greater than 250 gallons must be located at least 20 feet from any building or trailer. 10. Flammable liquids, including gasoline, must be dispensed from approved safety cans with self-closing caps and spark screens. Gasoline and other flammable liquids or fuels may not be stored or dispensed in quantities greater than 20 gallons without permission from the company Safety Department and must meet the OSHA requirements for flammable liquid storage in accordance with 29 CFR 1926.152, and local ordinances. Flammable liquids may not be used from open containers; such as paint cans or buckets. 11. Flammable and combustible liquid containers may not be stored in office trailers or in unventilated gang- boxes. 12. All storage containers, safety cans and drums containing solvents/chemicals must be properly labeled, including: a. Product Name b. DOT Approved Hazard Warning (Caustic, Flammable, Combustible, etc.) 13. Fire protection procedures ensure that adequate firefighting equipment is available and emergency procedures are established to minimize fire loss. 14. The emergency telephone number for the local fire department must be posted by the project telephone. 15. Fire protection includes fire extinguishers, fire hoses, buckets, water hoses, hydrants, etc. 16. The project safety monitor must inspect all fire extinguishers monthly. a. A third party inspector must re certify fire extinguishers annually. b. A local vendor shall refill discharged extinguishers as soon as practical. 17. On projects where fire protection in company work areas is provided by the client, discharged fire extinguishers found during inspections should be returned to the client or brought to the client's attention immediately. 18. The Project Superintendent, in conjunction with the Safety Department, will be responsible for determining the fire protection needs before a project begins to ensure that adequate protection will be immediately available. 19. Fire Extinguishers, minimum project requirements:
REV2.1 February 13, 2018 Page 93 | 165 The Elliott-Lewis Safety Manual Area Quantity and Type of Extinguisher
Trailers One 10-pound ABC Dry Chemical or one five gallon pressurized water (heated trailers only) extinguisher for each trailer
Weld fab areas and field One 25-pound ABC Dry Chemical Extinguisher or five gallon pressurized weld areas water extinguisher (heater areas only).
General construction One 25-pound ABC Dry Chemical Extinguisher for every 3,000 square feet areas and/or renovation of floor area. One five-gallon pressurized water extinguisher for every areas 3,000 square feet of floor area in heated buildings. Travel distance to any extinguisher should not exceed 100 feet.
Concrete form work Where there are large areas of wooden formwork, a ½-inch garden hose with a standard nozzle should be available on each floor. The hose shall be stored in a box or rack and labeled "For Fire Use Only."
Flammable/combustible One 25-pound ABC Dry Chemical Fire Extinguisher within 50 feet (more liquid storage areas than five gallons.)
Fuel gas & propane One 25-pound ABC Dry Chemical Extinguisher within 50 feet of cylinder cylinder storage location.
Electrical switchgear, One 25-pound CO2 (Carbon Dioxide) or Halon Extinguisher within 25 feet transformers, heat stress of electrical equipment. operations
Note: On projects where a pressurized fire hydrant(s) is available within the construction area, standard fire hose should be available with sufficient length to reach the furthest point of the protected area. A firebox should be built to store and protect the hose, nozzle(s) and hydrant wrench(s). 19.4 On Site Building Maintenance Services The Building Services Division of Elliott-Lewis Corporation provides, in many cases, around the clock maintenance services to buildings occupied by our customers. Based on the location, our mechanics may be asked to comply with designated fire procedures. These procedures must be outlined in a site-specific safety plan and agreed to by management of both the customer and Elliott-Lewis Corporation. In most circumstances, fire response will be limited to a basic identify, notify, secure, and evacuate process. Again, this will be determined by the Site-Specific Safety Plan agreed upon by both parties. Sections A through D contain some basic and very general guidelines which shall be followed until a site-specific plan is developed.
1. If an employee locates a fire, or sees flame or smoke, he/she should immediately notify the authorities. This authority will either be a building command center or the outside fire department (911). It is advantageous to notify an inside command center because they would know exactly what street or entrance that is needed to access the building depending on the size of the complex and the location of the fire. 2. Prior to leaving the building, if possible, contain the fire and smoke by closing all windows and doors to rooms, stairwells, and corridors to prevent the spread of fire and smoke. If accessible, turn off all sources of ignitions that could fuel a fire. 3. Assist in the evacuation of all inhabitants of the building to the nearest mustering area which is designated by the site-specific safety plan provided by building management. Do not use elevators within
REV2.1 February 13, 2018 Page 94 | 165 The Elliott-Lewis Safety Manual a building as a means of egress during fire alarm activation or an actual fire. Based on the size and location of the fire, evacuation may be adequate to a lower floor. When in doubt, evacuate the building totally. The Site-Specific Safety Plan should identify the mustering area for all inhabitants of the building. When relocated to this designated area, someone in a supervisory capacity shall take a roll call to ensure that all employees and visitors are accounted for in their respective departments as outlined in the safety plan. If anyone is missing, do not re-enter the building. Notify a representative of the fire department, police, or rescue personnel that someone may still be in the building. 4. Our employees are trained in very basic fire prevention and fire extinguisher use. If the fire is small enough (trash can fire, small motor, etc.), and an employee judges that it can be contained by a fire extinguisher, an initial attempt can be made. Heat and smoke from a fire can be more dangerous than the flames. Inhaling the super-hot air can sear a person’s lungs. Fire can produce poisonous gases that can cause death. If it cannot be contained on the first attempt, evacuate the building.
20 Jobsite Contaminants
20.1 Training All field employees who could be affected by the presence of a jobsite contaminant will attend initial awareness training during safety orientation, before initial assignment at a jobsite containing a contaminant, and annual refresher training. This training will inform of the specific nature of the operations which could result in exposure to lead above the action level, the purpose, proper selection, fitting, use, and limitation of respirators, engineering controls, purpose, and a description of the medical surveillance program and the medical removal program. 20.2 Asbestos Safety 1. Employees of the company are not permitted to handle, disturb, remove or clean up any insulation that is suspected of containing asbestos. 2. Employees are not permitted to enter into any enclosed or barricaded area where asbestos insulation removal is being performed without permission from the company Safety Department. Certain training and protective requirements must be met. 3. Supervisors must plan ahead whenever company employees may be disturbing old insulation. Contact the company Safety Department to have a sample of the insulation safely retrieved and analyzed for asbestos content. Simple examination of a sample, even by an experienced insulator, is not sufficient to determine the presence or absence of asbestos. 4. The company Safety Department must be notified of any planned activities or projects where asbestos removal may be performed in company work areas. Monitoring results from the removal company may be necessary to determine if the ambient asbestos level is within permissible limits before the company’s employees enter the area. 20.3 Lead Safety 1. All field employees who could be affected by the presence of lead on a jobsite will attend initial awareness training during safety orientation, before initial assignment at that jobsite, and annual refresher training. All training shall be properly documented. The employees shall be informed of the specific nature of the operations which could result in exposure to lead above the action level. Included in the training are the purpose, proper selection, fitting, use, and limitations of respirators, engineering controls, purpose and a description of the medical surveillance program and the medical removal
REV2.1 February 13, 2018 Page 95 | 165 The Elliott-Lewis Safety Manual program. Instructions shall include that if lead is found, employees are not to proceed and not disturb the lead in any way. 2. Lead is a heavy metal that can threaten the health of our employees and their families. Lead can be inhaled, swallowed, and carried on our clothing. Once inside the body, it tends to remain in tissues and organs. Eventually, after repeated exposures, lead build-up becomes toxic. Exposure can cause damage to the nervous system, kidneys, immune system, reproductive system, and possibly cause cancer. 3. Generally, our exposure to lead is due to drilling holes for piping through multiple coated painted surfaces. If any lead is present in the workplace, immediately notify the Safety Department to ensure the proper controls are put into place as provided by this program. Our employees have the right to know what operations and processes in the workplace could cause lead exposure. The Safety Department and the Project Manager will determine the control measures and monitoring system to be utilized throughout the length of the project. A site-specific compliance program shall be developed addressing the means of engineering and work practice controls, air monitoring, and a description of each operation in which lead is emitted. If work is being done on a multi-contractor jobsite, all means shall be employed to protect our employees and others from exposure. The program must be revised and updated annually. 4. Air samples are required to determine if the amount of lead exceeds the limits set by OSHA. The company must ensure that no employees are exposed to lead at concentrations greater than fifty micrograms per cubic meter of air averaged over an 8-hour period. If the initial air monitoring reveals employee exposure to be at or above the action level but below the permissible exposure limit, the employer shall repeat air monitoring at least every six months. The employer shall continue air monitoring at the required frequency until at least two consecutive measurements, taken at least seven days apart, are below the action level at which time the employer may discontinue monitoring for that employee. 5. The employer must, within fifteen working days after the receipt of the results of any monitoring, notify each affected employee of the results either individually in writing or by posting the results in an appropriate location that is accessible to affected employees. Whenever the results indicate that the representative employee exposure, without regard to respirators, exceeds the permissible exposure limit, the employer shall include in the written notice a statement that the permissible exposure limit was exceeded and a description of the corrective action taken or to be taken to reduce exposure to or below the permissible exposure limit. 6. When levels exceed the action level of thirty micrograms per cubic meter, controls shall be put into place to protect the employee. a. Blood tests will be administered to determine a base-line to enable proper monitoring of exposure levels. Additional blood testing shall be done every six months until two consecutive blood samples and analysis are acceptable. If on any blood test the employee exceeds fifty micrograms per 100 grams of blood, they should be temporarily removed from that jobsite. Employees should be in writing within five days when lead levels are not acceptable. Temporary removal requires Medical Removal Protection benefits. b. Medical examinations, evaluations and procedures shall be performed by or under the supervision of a licensed physician. The medical surveillance is provided at no cost to the employee. c. Respiratory protection shall be worn at all times while in the contaminated area. Respiratory protection must be issued in accordance with OSHA guideline 29CFR1910.134. Always use the correct filter for the contaminant. Put on and remove the respirator outside the lead work area. d. All personal protective equipment shall be provided by the company. Protective work clothing such as Tyvek suits and shoe covers shall be worn at all times. All Tyvek clothing that is to be
REV2.1 February 13, 2018 Page 96 | 165 The Elliott-Lewis Safety Manual disposed of after use shall be removed in a clean room which will prevent the dispersion of lead outside the area. It will then be disposed of properly. Never wear contaminated clothing home. If a half face respirator is used, face shields, goggles, or any other appropriate protective equipment shall be utilized for maximum protection for the eyes and face. Gloves shall be worn whenever exposure exists. Always wash the hands and face thoroughly if lead is present e. The employees shall be provided a change room and wash facility when the lead exposure level is above the permissible limit. f. Warning signs should be posted in the work area where the PEL is exceeded. 20.4 Silica Exposure 1. This program is to provide the hazards associated with silica dust and outline the steps to ensure employees who may work with, or around silica containing material are not exposed to silica dust. This program provides procedures for common silica related work duties to minimize exposure in accordance with the OSHA Air Contaminants standard, specifically (29 CFR 1910.1053). All materials containing silica can result in the presence of respirable silica particles when chipping, cutting, drilling or grinding takes place. Silica exposure occurs through inhalation of silica containing particles and occurs through many construction and general industry work activities. Work activities that may expose an employee to silica are rotary hammering, concrete mixing, concrete core drilling or working in the vicinity of a rock quarry. Exposure to excessive silica dust over long periods of time can result in silicosis. This program applies to any employees who may be expected to be exposed to silica dust through the methods outlined above. 2. Crystalline silica is an important industrial material found abundantly in the earth’s crust. Quartz, the most common form of silica, is a component of sand, stone, rock, concrete, brick, block, and mortar. Silica dust is hazardous when very small (respirable) particles are inhaled. These respirable dust particles can penetrate deep into the lungs and cause disabling and sometimes fatal lung diseases, including silicosis and lung cancer, as well as kidney disease. To a lesser extent, there is cause for concern that silica exposures may be associated with auto-immune disorders and cardiovascular disease. Occupational exposure to respirable crystalline silica occurs when cutting, sawing, drilling, crushing of concrete, brick, ceramic tiles, rock, and stone products. 3. Our exposure to Silica is created from core drilling holes for piping to pass through and installing anchors (floor and ceiling mounted). Prior to installation, if knowledge of performing work activities where silica dust may be created; notification to the Safety Department is required to ensure all proper controls are put into place as provided by this program. Our employees have the right to know what operations and processes in the workplace could cause silica exposure. The Safety Department and the Project Manager will determine the control measures and monitoring system to be utilized throughout the length of the project. The program shall address the means of air monitoring, engineering controls, work practice controls, and or in the addition of specialized equipment for capturing the respirable dust. If work is being done on a multi-contractor jobsite, all means shall be employed to protect our employees and others from exposure. 4. For each employee engaged in a task identified under 29 CFR 1926.1153 Table1 (appendix 47.1), project management with the assistance of the safety dept. will implement the engineering controls, work practices, and respiratory protection specified for the task on Table 1, unless the employer assesses and limits the exposure of the employee to respirable crystalline silica in accordance with paragraph (d) of this section 5. Air samples are required to determine if the amount of respirable silica exceeds or meets the action level set by 29 CFR 1910.1053 general industry and 29 CFR 1926.1153 construction (25g/m3 of an 8-hour TWA). Supervision and project management must ensure that no employee(s) are exposed to respirable
REV2.1 February 13, 2018 Page 97 | 165 The Elliott-Lewis Safety Manual silica at concentrations greater than fifty micrograms per cubic meter (OSHA permissible exposure limit (PEL) 50mg/m3 of an 8-hour TWA). If the initial air monitoring results show employee exposure to meet or exceed the action level but below the permissible exposure limit, the employer: a. The employer shall assess the exposure of each employee who is or may reasonably be expected to be exposed to respirable crystalline silica at or above the action level in accordance with either the performance option in sub-section (I) or the scheduled monitoring option in sub-section (ii). i. The employer shall assess the 8-hour TWA exposure for each employee on the basis of any combination of air monitoring data or objective data sufficient to accurately characterize employee exposures to respirable silica. ii. The employer shall perform initial monitoring to assess the 8-hour TWA exposure for each employee on the basis of one or more personal breathing zone air samples that reflect the exposures of employees on each shift, for each job classification, in each work area. Where several employees perform the same tasks on the same shift and in the same work area, the employer may sample a representative fraction of these employees in order to meet this requirement. In representative sampling, the employer shall sample the employee(s) who are expected to have the highest exposure to respirable crystalline silica. 1. If initial monitoring indicates that employee exposures are below the action level, the employer may discontinue monitoring for those employees whose exposures are represented by such monitoring. 2. Where the most recent exposure monitoring indicates that employee exposures are at or above the action level but at or below the PEL, the employer shall repeat such monitoring within six months of the most recent monitoring. 3. Where the most recent exposure monitoring indicates that employee exposures are above the PEL, the employer shall repeat such monitoring within three months of the most recent monitoring. 4. Where the most recent (non-initial) exposure monitoring indicates that employee exposures are below the action level, the employer shall repeat such monitoring within six months of the most recent monitoring until two consecutive measurements, taken seven or more days apart, are below the action level, at which time the employer may discontinue monitoring for those employees whose exposures are represented by such monitoring, except as otherwise provided in paragraph (d)(2)(iv) of this section. iii. The employer shall reassess exposures whenever a change in the production, process, control equipment, personnel, or work practices may reasonably be expected to result in new or additional exposures at or above the action level, or 17 when the employer has any reason to believe that new or additional exposures at or above the action level have occurred 6. Exposure Determination- Specific tasks that Elliott-Lewis employees perform that could involve potential to crystalline silica include the following: a. Core drilling 1” to 4” holes through concrete for piping to pass through is a common task that occurs. Employees including installers and HVAC techs may perform this task when required for 5 to 30 minutes per day on a periodic basis during the workweek. Not all workdays involve core drilling.
REV2.1 February 13, 2018 Page 98 | 165 The Elliott-Lewis Safety Manual b. Installing floor and ceiling mounted anchors in concrete is a common task. Employees including installers perform this task for 5 to 30 minutes per day on a periodic basis during the workweek. Not all workdays involve installing anchors. 7. The ACGIH Construction Committee compiled and evaluated silica exposure on construction sites. This study included 97 samples for the task of drilling concrete and the geometric mean exposure was 200 ug/mg3. 8. Another study entitled Silica Exposure during Construction Activities: Statistical Modeling of Task-Based Measurements from Literature”2 included 45 samples taken while drilling concrete with a geometric mean of 58 ug/mg3. 9. Based on these studies Elliott-Lewis estimates that potential uncontrolled exposure to silica during core drilling and installing floor and ceiling mounted anchors to be as follows: a. 5-Minute Daily Exposure Task = 0.60 ug/m3 to 2.08 ug/m3 b. 30-Minute Daily Exposure Task = 3.6 ug/m3 to 12.5 ug/m3
Based on this exposure assessment Elliott-Lewis has determined that the maximum potential exposure is below the Action Level of 25 ug/m3 and thus OSHA's Respirable Crystalline Silica standard for construction does not apply to the tasks our employees perform.
10. Engineering Controls Used-Elliott-Lewis has implemented the following engineering controls to further reduce employee potential for crystalline silica exposure: a. Use of Dustless Dust Vacuum equipment when installing floor and ceiling wall anchors. b. Use of water to keep the drill bit cool and control dust when using larger bits to cut plugs out of masonry and concrete walls and floors. 11. Training- Employees performing works tasks that have potential silica exposure will be trained so that they understand the following: a. Health hazards associated with respirable crystalline silica exposure. For respirable crystalline silica, the health hazards include cancer, lung effects, immune system effects, and kidney effects. b. Specific workplace tasks that could expose employees to respirable crystalline silica. c. The Elliott-Lewis exposure assessment that demonstrates daily tasks are not expected to exceed the OSHA Action Level. d. Specific measures Elliott-Lewis uses to reduce the potential for respirable crystalline silica exposure, including engineering controls, work practices, and housekeeping. e. The OSHA Fact Sheet entitled “Control of Silica Dust in Construction: Hand Held and Stand Mounted Drills” has been provided to all employees who are performing the tasks of drilling into concrete, and this topic has been covered in safety training. 12. References a. Journal of Occupational and Environmental Hygiene: “Silica Exposure on Construction Sites: Results of an Exposure Monitoring Data Compilation Project”, March, 2006 b. The Annals of Occupational Hygiene: “Silica Exposure During Construction Activities: Statistical Modeling of Task-Based Measurements from the Literature”, May, 2013
20.5 Revision Revision Date: Revised By:
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20.6 Ozone Depleting Refrigerant It is Elliott-Lewis Corporation's policy to conduct its business in a manner that protects employees, customers and the public from unacceptable risks due to Ozone Depleting Chemicals that are used or encountered in customers’ plants. The company is committed to continuous efforts to identify and manage risks associated with such substances and to provide an appropriate margin of safety for people and the environment.
To implement this policy, the company will:
1. Comply with all applicable laws and regulations, and apply responsible standards of its own whenever laws or regulations do not exist. 2. Maintain ozone depleting effects as a priority consideration in planning and developing mechanical systems, and in the repair and maintenance of it. 3. Specify precautions for handling, transporting, using and disposing of products that it uses. Communicate those precautions to employees, customers and others who may be affected to assure precautions are followed. 4. Refuse to use or sell materials where it is not possible to control adequately the risks from ozone depleting chemicals through proper equipment design, procedures and practices. 5. Respond quickly and effectively to incidents or emergency releases of ozone depleting chemicals experienced by customers. 6. Support research to extend knowledge about the ozone depleting effects of materials used or sold by the company; promptly applying significant findings and sharing them with employees and customers. 7. Undertake appropriate reviews and evaluations of all company operations to measure progress and to ensure compliance with this policy. 8. To create and maintain a paper trail to track the purchase of an ozone-depleting chemical, it's use in the field, to the issuance of a "Death Certificate." 9. To hire technicians and utilize recovery equipment which have been approved by the Refrigeration Service Engineers Society or similarly approved agency.
21 Confined Space Entry Program: Permit-Required and Non-Permit Required
21.1 General The purpose of this program is to protect the employees of Elliott-Lewis who must enter into, work in and exit from confined spaces from the risk of exposure to serious hazards such as entrapment, engulfment and hazardous atmospheric condition. This permit-required confined space program is available for inspection by employees of Elliott-Lewis or their designated representatives. For the purpose of this program, "confined space" is divided into two categories as follows:
1. Non-permit confined space: This type of confined space usually does not contain or have the potential to contain or, with respect to atmospheric hazards, have the potential to contain any hazards that are capable of causing death or serious physical harm. a. Is large enough and so configured that an employee can bodily enter and perform assigned work
REV2.1 February 13, 2018 Page 100 | 165 The Elliott-Lewis Safety Manual b. Has limited or restricted means for entry or exit such as tanks, vessels, silos, storage bins, hoppers, vaults and pits c. Is not designed for continuous employee occupancy 2. Permit-required confined space: This type of confined space has all the characteristics of a non-permit required confined space and one or more of the following other characteristics: a. Contains or has a potential to contain a hazardous atmosphere b. Contains material that has the potential for engulfing an entrant c. Has an internal configuration that would cause an entrant to be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross section. d. Contains any other recognized serious safety and health hazard 21.2 Procedure for Identifying Confined Spaces 1. The Elliott-Lewis Corporation shall designate a representative in writing, to evaluate each workplace to determine the existence and type of confined space in the area where employees of Elliott-Lewis will be working. 2. Before employees of Elliott-Lewis are allowed to begin work, the designated representative of Elliott- Lewis shall coordinate with the authorized representative of the owner or the general contractor to evaluate the jobsite and to determine the type of confined space(s) that exist in the work area. 3. If permit required spaces are found to exist, the Elliott-Lewis Corporation designated representative will make a note of the exact location of this space and post or have posted danger signs, or identify the manner in which this space is already posted. A typical sign stating: "DANGER - PERMIT REQUIRED CONFINED SPACE, DO NOT ENTER" or using other similar language would satisfy the requirements for a sign. 4. If employees of Elliott-Lewis will not be required to enter confined spaces in the course of their work, they will be required to sign a statement that they have been briefed on the location of permit-required confined space(s) in their work area. 5. If the employees of Elliott-Lewis will enter permit-space(s), they will do so by following the procedures outlined in this, Elliott-Lewis Corporation's, permit-required confined space program. 21.3 Coordination with Host Employer When employees of Elliott-Lewis are to work in facilities containing confined space(s) that are controlled by the host employer, the authorized representative of Elliott-Lewis shall coordinate all confined space entry requirements with a properly authorized representative of the host employer. As a minimum, the following information shall be exchanged/determined:
1. The host employer shall appraise the Elliott-Lewis representative of all elements to include the hazards identified in the confined space, the experiences that the host employer has had with the space; the reason(s) why a space is classified as a permit required confined space. 2. Any precautions or procedures that have been implemented by the host employer for the protection of their employees in or near the confined space area where employees of Elliott-Lewis will be working. 3. Coordinate all entry operations to protect both the host employer employees and employees of Elliott- Lewis or employees of another contractor who are working near the confined space to be entered. If host employer employees, employees of another contractor and employees of Elliott-Lewis are to work in the confined space simultaneously, entry procedures shall be developed and implemented to ensure the safety of all authorized entrants, and to ensure that employees of one employer do not endanger the employees of another employer.
REV2.1 February 13, 2018 Page 101 | 165 The Elliott-Lewis Safety Manual 4. The authorized representative of Elliott-Lewis shall obtain from the host employer any available information regarding the permit space hazards and any entry operations mandated by the host employer. Further, the authorized representative of Elliott-Lewis shall provide a copy of the Elliott-Lewis confined space program to the host employer for their review and approval before any entry operation is performed by any employee of Elliott-Lewis. Approval to use the Elliott-Lewis confined entry program as is, or as modified by special requirements of the host employer, shall be in writing and shall be signed by an authorized representative of the host employer. 5. The authorized representative of Elliott-Lewis shall debrief the host employer at the conclusion of the entry operation regarding the permit space program followed, and of any hazards encountered or created in the permit spaces during entry operations and actions taken to protect the safety of the assigned entry personnel. 21.4 Preparations for Entry into Permit Space 1. Before entry into a permit space is authorized, the authorized representative of Elliott-Lewis shall: a. Implement all measures necessary to prevent unauthorized entry. b. Identify and evaluate the hazards that may be encountered in the permit space. c. Specify acceptable entry conditions. d. Conduct preliminary purging, inserting, flushing or ventilating of the permit space as appropriate to eliminate or control atmospheric hazards. Continuous ventilation shall be applied throughout the entry process. e. Provide barriers to control pedestrian and vehicle traffic to protect the entrants from external hazards. f. Periodically test the air content in the occupied space. 2. The authorized representative of Elliott-Lewis shall ensure that necessary equipment is available on location, that the equipment is in proper operating conditions and that personnel operating/using the equipment have been properly trained. The following items of equipment shall be provided: a. Testing and Monitoring Equipment: Various types of instruments are available for determining the presence of dangerous gases. The instruments should not be taken into the confined space that may contain hazardous gases; rather, sampling lines (probes) should be used. Some of the more familiar test instruments are as follows: b. Oxygen deficiency indicator - This instrument measures oxygen content to determine if it is sufficient to support life. c. Combustible gas indicator - This instrument registers the explosiveness of the mixture of gas and air. d. Carbon monoxide detector - This instrument gives a reading of the carbon monoxide present in the confined space. e. Hydrogen sulfide detector - This instrument consists of a detecting ampoule that is lowered into the confined space. A color chart is used to compare the color of the ampoule to determine if hydrogen sulfide gas is present.
Employees of Elliott-Lewis who are designated to use testing or monitoring equipment shall be properly trained to know the type of gas that may be encountered in typical confined spaces and how to properly use the gas detection equipment. NOTE: All testing equipment must be calibrated according to manufacturer's specifications before use.
3. Communication Equipment: Appropriate communications equipment shall be used to maintain contact between authorized entrants and the attendant, to monitor the status of the entrant(s) and to alert them
REV2.1 February 13, 2018 Page 102 | 165 The Elliott-Lewis Safety Manual if the need arises for them to evacuate the space. The type of communications shall be based on the conditions in the permit space and may include one of the following: a. Visual (observation) b. Voice c. Telephone d. Two-way radio e. Other means as appropriate 4. Ventilating Equipment: Ventilating by a blower or fan may be necessary to remove harmful gases and vapors from a confined space. The method used and the equipment selected is dependent on: a. The size of the confined space openings b. The gases to be exhausted c. The source of the makeup air
A common method of ventilating a space is to use a large hose with one end attached to a fan and the other end lowered into the confined space. The ventilating hose end shall be located at the bottom of the confined space to blow out all harmful gases and vapors. The air intake shall be placed in an area that will draw in fresh air only. Ventilation shall be continuous to keep hazardous atmospheres from reforming.
5. Personal Protective Equipment: To protect personnel of Elliott-Lewis from becoming injured while entering, performing the required work and safely exiting the confined space, necessary personal protective equipment shall be maintained and provided by Elliott-Lewis to personnel involved in confined space work at no cost to the employee. There is certain basic protective equipment that should be worm at all times to include: a. Head protection b. Eye and face protection c. Hand and foot protection
In certain conditions, there may be a need for protective clothing, hearing protection, respiratory protection and body harness.
Before an employee of Elliott-Lewis enters any confined space, the interior of the space shall be evaluated for the type hazards that may be present in the space and appropriate personal protective equipment shall be issued.
6. Lighting Equipment: Appropriate lighting shall be provided within and outside the confined space to allow employees of Elliott-Lewis to enter safely, perform the required work and exit the confined space. Some of the precautions that shall be taken when selecting lighting are as follows: a. If the atmosphere inside the confined space is classified as flammable/explosive, the electrical equipment used shall conform to Article 500, National Electric Code. b. All personnel entering the confined space shall be provided with explosion-proof flashlights, if other means of lighting is not available. c. Extension cords in damp or wet areas could cause electric shock hazards. Only approved low- voltage (6 or 12 volt) lights and extension cords with ground fault circuit interrupters should be used in confined spaces. 7. Barrier and Shields a. Appropriate barriers and shields shall be used to isolate the confined space from personnel who are not directly involved in the entry operations. High visibility warning tape may be used to keep unauthorized personnel at a safe distance. If the confined space is located in an area accessible to
REV2.1 February 13, 2018 Page 103 | 165 The Elliott-Lewis Safety Manual public, barriers that keep pedestrian and vehicular traffic away from the entry operation shall be erected. b. Before the entrance cover to the confined space is removed, the area around the entrance shall be inspected and all unsafe conditions eliminated. c. Immediately after removal of the entrance cover, a railing, temporary cover or other type of barrier as appropriate that will prevent an accidental fall through the opening and to protect employee working in the space from objects that may fall into the space shall guard the opening. 8. Entry and Exit Equipment: Ladders and other types of equipment that provide safe entry and exit to the authorized entrants from the confined space shall be available at the entry location. Necessary precautions shall be taken to ensure that this equipment does not interfere with the ventilating equipment. 9. Rescue and Emergency Equipment: Work/rescue equipment, including lifelines, belts, stretchers, mobile cranes, hoists or other suitable equipment needed to rescue an individual from the confined space shall be available at all times. Since the conditions and space characteristics vary from one situation to another, the necessary equipment shall be selected based on the potential hazards and possible contingencies expected to occur during the entry operations. A properly trained attendant shall be positioned outside the permit space to observe the status of the entrants. The attendance shall be equipped with a two-way radio or have immediate access to a telephone so he/she can summon rescue and emergency services. 21.5 Pre-Entry Testing of Confined Space 1. Pre-Entry Testing: Before any type of confined space (permit or non-permit) is entered into by employees of Elliott-Lewis, the space shall be tested with a calibrated, direct reading instrument to determine if acceptable entry conditions exist. Entrants or their representatives shall be given the opportunity to participate in and review calibrated air monitoring data before entry. If a permit space is large or is part of a continuous system (i.e., a sewer), pre-entry testing shall be performed to the extent feasible, and if entry is authorized, entry conditions shall be continuously monitored in the areas where authorized entry personnel are working. 2. When testing for atmospheric hazards, it shall be done in the order shown (i.e., oxygen concentration, combustible gases and vapors, and toxic gases and vapors). a. Atmospheric oxygen concentration CRITERIA: Not below 19.5 percent or in excess of 23.5 percent. b. Flammable gas vapor or mist CRITERIA: Not to exceed 10 percent or its lower flammable limit (LFL) c. Airborne combustible dust that meets or exceeds its lower flammable limit (LFL) This concentration may be approximated as a condition in which the dust obscures vision at a distance of five feet or less. d. Atmospheric concentration of any substance for which a dose or permissible exposure limit is published and which could result in employee exposure in excess of the dose or permissible exposure limit. CRITERIA: Refer to Subpart G, Occupational Health and Environmental Control, and Subpart Z, Toxic and Hazardous Substances in OSHA Safety and Health Standards (29 CFR 1910) for exposure limits. e. Isolating Energy Sources: Before employees of Elliott-Lewis enter any confined space, the space shall be removed from service and shall be completely protected against the release of energy and/or material(s) into the space. This means that all energy sources leading to the confined space or located within the confined space which are potentially hazardous to the workers shall
REV2.1 February 13, 2018 Page 104 | 165 The Elliott-Lewis Safety Manual be locked out, tagged, relieved, disconnected, and/or restrained. The objective for isolating all energy sources is to prevent unexpected or accidental energization, start-up or release of stored energy that could cause injury to workers within the confined space. Energy sources include: i. Electrical ii. Mechanical iii. Hydraulic iv. Thermal Radioactive Sources v. Gravity f. Fire Protection: To preclude the possibility of fires occurring in the confined space that could become a hazard to the workers inside, the following precautions shall be taken as a minimum: i. Access and egress to and from the confined space shall be maintained clear of any obstructions at all times. If welding or cutting is to be performed in the confined space, combustible materials shall be covered with flame-retardant materials. ii. Flammable liquids (i.e., acetone, alcohol, etc.) shall be stored in UL or FM approved containers. The amount of flammable liquid(s) brought into the confined space shall not exceed the amount needed to perform the work each day. iii. Properly rated fire extinguishers shall be immediately available. iv. Cylinders containing oxygen, acetylene or other fuel gases shall not be taken inside the confined space. v. All rags, brushes, wipes, gloves, etc., shall be stored in metal containers with lids. vi. A person shall be posted during all welding, burning and heating operations to monitor for fires, and ensure that after the work has ceased or at the end of a work shift there are no fire conditions present. vii. All flammable gas equipment, hoses, torches, etc., shall be free of defects and inspected by the user prior to such operations or are adequately protected to prevent ignition. viii. To eliminate the possibility of fire in enclosed spaces as a result of gas escaping through leaking or improperly closed torch valves, the gas supply to the torch shall be positively shut whenever the torch is left unattended for long periods of time, such as during lunch breaks. At the end of a work shift, the torch and hose shall be removed from the confined or enclosed space. Open-end fuel gas and oxygen hoses shall be immediately removed from enclosed spaces when they are disconnected from the torch or other gas-consuming device. g. Evacuating a Permit Space: Should a situation occur where a hazardous condition develops, the authorized entrant(s) shall immediately notify the attendant that the space is being abandoned. The attendant shall notify the rescue services and assist the authorized entrants in any way possible. It is important that the attendant not enter the permit space. h. Closing Permit Space and Canceling of Permit: The permit space entry supervisor shall consult with the authorized entrants to determine the cause of the hazardous situation and identify any actions taken by the entrants that could have caused the situation to develop. Before further entry is attempted, a new permit shall be prepared which corrects any deficiencies found in the original permit. The original permit shall be cancelled by having the entry supervisor sign and date in the cancellation space on the permit.
REV2.1 February 13, 2018 Page 105 | 165 The Elliott-Lewis Safety Manual 21.6 Preparing the Entry Permit 1. An entry permit shall be prepared to authorize entry into any permit-required space by employees of Elliott-Lewis. Elliott-Lewis shall designate an entry supervisor for each specific confined space entry operation. The entry supervisor shall be the only person that can sign the entry permit to authorize entry. 2. The entry permit used by Elliott-Lewis shall include the following information: a. Description of the confined space to be entered b. The purpose of the entry and known space hazards c. The date and the authorized duration of the entry d. The names of all authorized entrants, eligible attendant(s) of the individual(s) designated as entry supervisor(s). If the individual serving as entry supervisor is someone other than the entry supervisor or originally authorized entry, space for the names of both entry supervisors and their signatures shall be provided e. The measures to be taken to isolate the permit space and to eliminate or control permit space hazards (i.e. locking out or tagging of equipment and procedures for purging, making inert, ventilating, flushing, etc.). f. Statement as to what constitutes acceptable entry conditions. g. The results of initial and periodic tests performed, together with the names or initials of the individuals doing the test and the time when the test was conducted. h. The rescue and emergency services that are to be summoned, the means (i.e., telephone, etc.) and the number(s) to be called to summon these services. i. The communication procedures to be used by the authorized entrants and the attendant to maintain contact during entry. j. Personal protective equipment used by entrants, testing and monitoring equipment used, alarm system and rescue equipment that will be available on site. k. Additional permits, i.e. hot work, etc., that have been issued for work inside the space. l. Any other information pertinent to a specific confined space to ensure employee safety. 3. The completed permit shall be made available at the time of entry to all authorized entrants. This shall be accomplished by posting the permit or by reviewing the permit with all entrants so that they are made aware that all pre-entry preparations have taken place. 4. The duration of the entry permit must not exceed the time required to complete the assigned task or job identified on the permit. 5. If hazardous conditions are detected during entry, employees of Elliott-Lewis must immediately leave the space and the space must be evaluated to determine the cause of the hazardous condition. 6. The entry supervisor shall terminate entry and cancel the entry permit when: a. The entry operations covered by the permit have been completed. b. A condition arises which is not covered under the permit. The circumstances of the situation must be noted on the canceled permit and should be used in revising the permit space program. 21.7 Training and Education 1. Elliott-Lewis will provide proper training to all its employees before their initial work assignment in a permit space. Upon completion of this training, Elliott-Lewis will assure all individuals who participated in the training understand and have the necessary knowledge and skills for the safe performance of their duties. Additional training will be given when: a. The job duties change b. There is a change in the permit space program or the permit space presents a new hazard c. When the job performance of any employee shows deficiency
REV2.1 February 13, 2018 Page 106 | 165 The Elliott-Lewis Safety Manual 2. Instructors conducting the training shall be competent in permit-required confined space entry through either education or experience. They shall further have thorough knowledge of confined spaces, hazards associated with toxic atmospheres, monitoring equipment, personal protective equipment and emergency rescue planning. Instructors shall also be knowledgeable in blinding and purging operations, lockout/tag-out procedures, ventilation and toxicological effects. 3. Appendix II *** provides the training syllabus to be followed in the training of Elliott-Lewis employees. Considering the fact that there are a large variety of confined spaces with their own unique requirements, the employees of Elliott-Lewis shall receive additional instructions that cover the specifics of a particular permit space prior to entry into the space. 21.8 Rescue and Emergency Services 1. Elliott-Lewis shall have one individual available at the job-site where permit space entry is to take place to provide rescue services. This individual may be the job supervisor or foreman in charge of the entry operation. 2. The individual designated to provide rescue services shall be provided with personal protective equipment and other rescue equipment necessary to make rescues from permit space. This individual shall be trained in the use of the personal protective equipment. 3. For job-sites in a host employer facility, the Elliott-Lewis rescue service person shall coordinate with the host employer and identify the rescue equipment that needs to be available at the permit space and establish procedures that are to be followed in case rescue becomes necessary. If there is reliance on the client host rescue services for use, they must be given an opportunity to examine the entry site, practice a rescue, and decline as appropriate. a. When an outside rescue service is used, they must be given an opportunity to examine the entry site, practice a rescue, and decline as appropriate. 4. In cases where the Elliott-Lewis rescue service person is required to enter the permit space to perform rescue, he/she shall be equipped with a chest or full body harness with a retrieval line attached at the center of the back rear shoulder level or above the head. The other end of the retrieval line shall be attached to a mechanical device or fixed point outside the permit space in a manner that will allow rescue to begin immediately. A mechanical device shall be available to retrieve personnel from vertical type permit spaces more than five feet deep. 5. The Elliott-Lewis rescue service person shall receive the same training as the entry personnel. The rescue service person shall also practice making a simulated rescue from typical permit space(s) where Elliott- Lewis personnel may have to work. 6. Where an entrant is exposed to a substance in the permit space that will require treatment at a medical facility, a copy of the SDS for that substance will be provided to the treatment facility. 7. For any IDLH (Immediately Dangerous to Life or Health) conditions during an entry, trained rescue is required on site while work is being performed.
REV2.1 February 13, 2018 Page 107 | 165 The Elliott-Lewis Safety Manual 22 Respiratory Protection Program
22.1 General 1. Dust masks do not offer adequate protection for gases or solvent vapors. When engineering control measures are not feasible, respirators are provided which are applicable and suitable for the purpose intended. 2. Dust masks for protection from nuisance dusts, spray paint, mists and weld fumes may be purchased by a project from a local safety equipment supplier. (See approved Safety Equipment Purchase List in Section 17.0). 3. Respirators may not be purchased for any use without approval from the Safety Department. The type of respirator, type of cartridge, physical capabilities, and the ventilation and air monitoring requirements must be considered before respiratory protection can be issued. 4. In those circumstances approved by the Safety Department where a respirator is required, the respirator wearer must be examined by a physician to determine if he is physically capable of withstanding the additional strain that a respirator demands on the respiratory system. The Safety Department will provide training before initial issuance and annually thereafter to ensure the employee has knowledge of respirator fit, use, limitations, fit checks, maintenance, signs and symptoms of effective use, and general requirements of the OSHA standard. If misuse is discovered or new application for the job occurs, re- training will be applicable. 5. Additionally, employees who have a history of sensitivity or disease from exposure to certain contaminants must not be allowed to work in contaminated areas. 6. For information regarding respiratory protection for any of the following operations, contact the company Safety Department:
Solvent use in confined areas Asbestos containing dusts Sandblasting Entry into asbestos removal areas Sulfur gases Epoxy paint applications Cadmium welds, galvanized welding Use of any liquid polyurethane products Degreasing large areas Use of coal tar pitch products 7. The following respiratory equipment is available with permission from the company safety department based on the hazards encountered: a. Half Face Air Purifying Respirators (NIOSH certified) b. Full Face Air Purifying Respirators (NIOSH certified) c. Air Supplied Full Face Respirators 8. A specific project respiratory program will be developed for each project as needed. 9. All medical evaluations and fit tests will remain confidential information. Medical evaluations, the equipment, and training will be done during normal working hours at no cost to the employee. The employee will be afforded the opportunity to discuss the results with the physician. 10. Fit tests will be performed annually by Qualitative Fit Test or Quantitative Fit Test methods, per OSHA standards. 11. Facial hair will compromise the seal of a respirator and is not permitted. 12. In highly sensitive areas and situations, employees are to leave the area to wash, change cartridges, or if their seal is compromised. 13. No employee should enter an area that is considered IDLH (Immediately Dangerous to Life and Health). 14. Respirators need to be kept clean and sanitary and stored properly. Antiseptic wipes are provided as needed. Always protect respirators from damage and contamination. Inspect them before each use. REV2.1 February 13, 2018 Page 108 | 165 The Elliott-Lewis Safety Manual 15. SCBA’a (Self Contained Breathing Apparatus) are not needed nor supplied by the company. Supplied Air Respirators are available to the employees as required. The air supplied must be Grade D or better. The compressor needs to be placed in a clean atmosphere with in-line purification and tagged to indicate date or change-out. A carbon monoxide monitor should be in place and set to alarm at 10ppm. 16. Employees are asked to provide evaluations as to their respirator was selected, fitted, used and maintained. 17. All medical evaluations result and fit tests are retained in the Safety Department by the Safety Director and are made available in accordance with 29 CFR 1910.1020.
23 Corporate Field Technician Vehicle Policy
23.1Purpose The purpose of the Corporate Field Technician Vehicle Policy is to provide safe, economical vehicles to fit the field application and efficiently service the client. A clear, concise policy minimizes and reduces the risk of loss due to un-qualified drivers, driver misconduct, or mechanically un-fit vehicles. The corporate safety goal is to protect the employees, the environment, and the general public. 23.2 Scope This policy addresses the use and care of company vehicles, and the qualifications necessary to gain and maintain the privilege of driving a company vehicle. This policy does not address the qualifications or skills necessary to operate cranes or heavy construction equipment. 23.3 Administration The responsibility for implementing and enforcing this policy rests with the Fleet Manager and the Corporate Safety Director, in conjunction with the Company President. Questions associated with this policy are to be forwarded to the Corporate Fleet Manager at the main office. 23.4 Driver Qualification A field technician or any other authorized driver of company vehicles must have a valid driver’s license for the state in which he/she resides. A photocopy must be kept on file with the Human Resource Department. If an employee moves to another state, he/she must submit a copy of their new license. An “MVR Survey” which is a copy the operator’s driving record for the past three years, will be conducted prior to hire. A copy of that report is available for the technician to review. If the survey produces a record that is inconsistent with the corporate safety goals, that employee shall not be hired. If at any point during an employee’s employment, his/her operator’s license is suspended or revoked, the company will immediately retrieve the vehicle at the employee’s location.
1. At no time shall an unauthorized employee be permitted to drive a company vehicle or a motor vehicle of any kind for company business. 23.5 Personal Vehicle Use The personal use of service vehicles is prohibited by this Corporate Policy. It is endorsed by the Agreement between the Steamfitter’s Local Union # 420 and the Servicing Contractors Association of Greater Delaware Valley, Inc.
This Agreement states: REV2.1 February 13, 2018 Page 109 | 165 The Elliott-Lewis Safety Manual “The use of the service truck for any travel not directly connected with the employee’s assigned duties or without the Employer’s express consent is prohibited. Violation of this rule is cause for dismissal without notice.” 23.6 Vehicle Operation 1. Employees operating company vehicles must maintain a defensive driving attitude, with consideration for the unpredictable nature that other drivers may operate their vehicles. Anticipation of other driver’s actions and the actions of pedestrians can minimize accidents. The national average cost for physical damage to a vehicle is $ 2,500. Our insurance deductible is $ 2,500. This deductible applies when an accident is our driver’s fault or if an un-insured motorist causes an accident. In the Philadelphia area, it is a fact that 50 percent of the vehicles on the road are uninsured. 2. Employees should be physically fit to operate a company vehicle and be aware of and understand all the applicable state motor vehicle laws. Operators shall at all times be considerate of the rights and privileges of other drivers and pedestrians. 3. State law mandates that seat belts be worn at all times by both drivers and passengers. 4. At no time should a driver operate a motor vehicle while under the influence of alcohol, illegal drugs, or prescription or over-the-counter medications that could impair their driving skills. 5. It is against company policy to use a cellular phone while operating a company vehicle. This includes the use of a hands-free unit. Phone concentration and conversation is a major distraction leading to vehicle accidents. It is always prudent to pull to the side of the road to place or receive a call. 6. Adhering to the speed limit and maintaining a safe following distance are required at all times. 7. It is prohibited to tow a boat trailer or any trailer for any personal nature. 8. Passengers are not permitted in service vans other than another service technician or authorized employee of the company. 9. All loads shall be secured and shall not exceed the specifications and legal limits of the manufacturer. 10. All vehicles shall be used for the purpose for which they were designed and intended. 23.7 Vehicle Maintenance 1. Company vehicles shall be maintained in accordance with the maintenance schedule provided by the fleet administrator and performed at the corporate fleet facility. It is the operator’s responsibility to ensure that the vehicle is in safe working order and to report any inoperable vehicle equipment to the fleet technician for repair or replacement. A pool of spare vehicles is available for use while the company vehicle is being serviced. 2. Your supervisor must approve out-of-town mechanical repairs costing over $100. Minor repairs costing less than $100 do not require prior authorization, provided they are necessary for the safe and efficient operation of the vehicle. An original invoice or original paid invoice must be submitted for re- imbursement. All warranty repairs shall be performed at an authorized dealer. 3. The operator is responsible for maintaining the vehicle in a clean and presentable condition. Vehicle appearance reflects the company’s attitude and goals towards servicing the client. The cost of vehicle washing and waxing is reimbursable for up to two washes per month and two waxes per year. 4. The service and repair of personally owned vehicles at the corporate fleet facility are not permitted. 23.8 Accident Reporting Pertinent Information
1. All information as to the time, place, other driver and vehicle and vehicle owner are necessary to submit a report to our carrier. It is not sufficient to tell the other party to “call our office”.
REV2.1 February 13, 2018 Page 110 | 165 The Elliott-Lewis Safety Manual 2. A report with the pertinent information shall be submitted to the Safety Department at the home office for all accidents, acts of vandalism or other damages sustained to the company vehicle. At times, an incident report may be completed and kept on file as a record of an accident that did not result in any damage to any parties. 3. Requests for towing of damaged vehicles are to be addressed to Bob Weston, Chief Mechanic, or directly to Jack Logan Towing (215.632.8900). This is our only authorized towing company for the Philadelphia area. 23.9 Vehicle Violations 1. Parking Violations a. Parking violations are to be submitted to the Ticket Administrator, in the company-provided self- addressed envelopes. Prompt violation submittal eliminates penalty fees. A City of Philadelphia parking placard may be authorized by your supervisor for continued service work in the city limits. The parking placard costs $62.50 for a six-month period that allows over time meter parking and four-hour parking in a loading zone. It is not valid for areas marked “No Parking,” “Handicapped Parking,” “No Parking on the Sidewalk,” or “Tow-away Zone.” The placard must be prominently displayed to be valid. 2. Moving Violations a. Moving violations are the responsibility of the driver. 3. The privilege of driving a company owned vehicle will not be granted or may be revoked by the Safety department for any one of the following offenses: a. Suspension or revocation of an employee’s driver’s license i. Suspension: Automatic and immediate ii. Reinstatement: Reinstatement may be granted when the employee’s license is reinstated and following a review of the employee’s prior driving record by the Safety department and his supervisor. b. Failure to report an accident to the authorities or to the company, or leaving the scene of an accident, or failure to report a citation or moving violation i. Suspension: Automatic and immediate ii. Reinstatement: Reinstatement pending a review of the employee’s prior driving record by the Fleet Manager, the Safety Committee and his supervisor c. Citation or conviction of driving under the influence of alcohol or drugs i. Suspension: Immediate upon receipt of suspension ii. Reinstatement: Immediate reinstatement upon dismissal of charges or other determination of innocence by the court or authorities or reinstatement by reinstatement of driver’s license and review of employee’s prior driving record by the Fleet Manager, the Safety Committee and his supervisor d. Failure to wear a seat belt i. Suspension: Immediate upon notice of conviction ii. Restatement: Reinstatement following a review of the employee’s prior driving record by the Fleet Manager, the Safety Committee and his supervisor e. Careless or reckless endangerment or any other moving violation or action deemed dangerous by the authorities or by both the Fleet Manager and the Safety Director. i. Suspension: To be determined jointly by the Fleet Manager, the Safety Committee and employee’s supervisor
REV2.1 February 13, 2018 Page 111 | 165 The Elliott-Lewis Safety Manual ii. Reinstatement: To be determined jointly by the Fleet Manager, the Safety Committee and employee’s supervisor f. Violation of any part of this Company Vehicle Policy i. Suspension: To be determined jointly by the Fleet Manager, the Safety Committee and employee’s supervisor ii. Reinstatement: To be determined jointly by the Fleet Manager, the Safety Committee and employee’s supervisor 4. Where, as a condition of employment, an employee is dependent on a valid driver’s license and a driving record free of any of the violations listed in this policy, the employee may be terminated for “inability to maintain job qualifications”, provided no other work is available that he/she is qualified to perform. 5. Where an employment applicant or referral has applied for work that is dependent on a valid driver’s license and a driving record clear of any violations listed above, he/she shall not be hired, provided no other work is available that he/she is qualified to perform. 6. While an employee’s driver’s license is suspended or revoked, or the employee is laid off, the company vehicle shall be returned to the corporate office. 23.10 Appeals Any appeal to these guidelines by an employee shall be directed to a committee of the Fleet Manager, the Safety Committee and his supervisor.
24 Sub-Contractor Safety Program
24.1 General 1. All subcontractors will be pre-qualified by reviewing their safety programs, safety training programs, and safety statistics based on completion of the Elliott-Lewis Subcontractor Prequalification Form. Acceptable criteria for working for this company will be a recordable injury rate of 4.0 and an EMR of 1.0 or less. Anything less than the acceptable criteria will require explanation by the subcontractor in writing and a ruling thereafter by the Safety Department. Sub-contractors to this company must comply with applicable rules and regulations, including the minimum standards established in the Corporate Safety Manual. Sub-contractors will receive a contract addendum explaining the basic safety rules of the projects. 2. Subcontractors shall be included in all pre-job orientations, Job Safety Analyses, site inspections, job meetings, and toolbox safety talks. 3. The company Safety Director must be notified immediately of any situation of repeated sub-contractor non-compliance that is creating a hazard to project employees. 4. Project superintendents should document sub-contractor activity in their daily log. 5. Specific sub-contractor safety problems should be addressed to the company Safety Director. 6. The company Safety Department or the project Safety Monitor may issue a formal notice of non- compliance to a sub-contractor as included as "Attachment A"*** to this section. Upon completion of the job, a review of the performance of the subcontractor shall be completed by the Project Manager or Safety Department. In the event a subcontractor is considered non-compliant at any point in the project, that contractor shall be deemed unacceptable for future jobs.
REV2.1 February 13, 2018 Page 112 | 165 The Elliott-Lewis Safety Manual 25 Crane Safety Program
25.1 Purpose The objective of the Company Mobile Crane Safety Program is to reduce the possibility of an injury or property loss due to a preventable cause. It is the Company's responsibility to its employees, other workers at the site, and the general public to conduct its operations in a safe and efficient manner.
A complete listing of this OSHA Regulation CFR 1926.1400 and ANSI B30.5 that pertains to all crane operations at a construction site is available in the Crane Operation and Safety Program Division. It includes a crane daily inspection checklist, the inspection of wire rope and the correct application and placement of rigging equipment.
Methods of Obtaining Objectives: This Safety Program can only be effective through the concerns, participation, and co-operation of company management and operators. 25.2 Operators 1. Operator Qualifications-Current and new hires will demonstrate their expertise by hands-on operation of the assigned equipment prior to leaving the yard. Additional items to be checked: a. Medical ID Card b. Check of driver's license classification c. Operator's ability to read a load chart d. Knowledge of hand signals e. Creation of Employee Folder 2. Operator Awareness a. Familiarization with OSHA electric lines working clearances. b. Completion and signing of Rental Release Form prior to raising the boom c. ANSI Standards governing boom operation over people or occupied offices d. Daily use of the Hydraulic Crane Safety Inspection Checklist (walk-around) e. Performing Pre-Task Tailboard Briefing with all involved prior to the lift f. On-site inspection of slings and shackles g. Review customer's safety requirements (i.e. PGW requires hard hats, safety glasses, long sleeves, clean-shaven) h. Check crane capabilities and load chart for each job i. Ensure each crane has at least a 5 lb. CO2 or dry chemical fire extinguisher that is full and has been inspected yearly j. PREVENTIVE MAINTENANCE PROGRAM-Equipment condition is foremost in a Safety Program. All equipment is to be maintained in top operating condition by using the following methods: i. Annual Safety Inspections ii. Use of the Daily Inspection Checklist iii. Follow-up and correction of items in disrepair iv. Full service after 200 hours of operation v. All maintenance will be performed based on manufacturer’s guidelines vi. During maintenance, ensure keys are pulled and crane is tagged “Out of Service” 3. Operator Requirements a. Review crane manufacturer's operating manual b. Review the crane's "Pick and carry" capabilities and speed restrictions before proceeding
REV2.1 February 13, 2018 Page 113 | 165 The Elliott-Lewis Safety Manual c. Work within the load chart, making deductions for lifting beams, spreader bars, slings, shackles, wire rope, jib, ball or block d. Inspect the wire rope bucket and "tattle-tail" daily e. When deemed necessary, a pilot vehicle shall follow the oversize/overload crane; when the crane negotiates a sharp turn, the pilot vehicle shall temporarily lead the crane to warn and direct traffic f. Level crane on outriggers prior to lifting with boom in cradle (a three-degree side-tilt reduces capacity by 50 percent) g. Keep fire extinguishers re-charged h. Keep cab area free of trash and tools i. Locate crane a safe distance from trenching j. Use matting under outriggers as necessary k. prior to hoisting, the head of the boom shall be centered over the load l. A minimum of two full wraps must remain on the drum when lowering the boom or load m. During hoisting, avoid sudden acceleration and deceleration 4. Operating Issues a. Use crane cable as a sling or drag a load b. Refuel with the engine running c. Permit anyone to ride the crane, sling, hook or load d. Operate the crane in a high wind e. Operate the crane if you feel there are unsafe / unstable conditions f. Engage in any distraction activity while operating equipment g. Leave the crane when a load is suspended h. Swing loads over personnel or traffic i. Smoke when operating the crane 5. Accident Reporting: a. CALL THE SAFETY Department IMMEDIATELY b. Call police, rescue squad, etc. If needed c. Call the supervisor d. Seek medical attention for injured e. Don't move anything except to extract injured f. Injuries must be reported to OSHA; this will precipitate a thorough investigation g. Obtain any witnesses names, phone numbers, etc. h. Don't make a commitment to fault i. Go over in your mind what you were doing, the position of the boom and the load j. The Safety Department will come to the scene to investigate the incident 6. Power Line Safety-No person shall operate a crane or hoist below a power line unless the employer has confirmed that the utility owner/operator has de-energized and visibly grounded the power line. The employer must assume that all power lines are energized unless it is confirmed that the line has been, continues to be de-energized, and is visibly grounded. If the lines cannot be de-energized, then we must ensure no part of the equipment, load line, or load gets closer than 20 feet to the power line. This is accomplished by use of an elevated warning line or barricade equipped with high visibility markings at the 20-foot distance from the power line. In addition, a designated and dedicated spotter may be utilized to ensure the load never gets within the limits provided by the OSHA guidelines. OSHA regulations specify minimum distances from electric lines depending on their voltage:
REV2.1 February 13, 2018 Page 114 | 165 The Elliott-Lewis Safety Manual Clearance While Equipment Working KV Up to 50 10 feet Over 50kv to 200kv 15 feet Over 200kv 20 350kv 20 feet Over 350kv to 500kv 25 feet Over 500kv to 750kv 35 feet Over 750kv to 1000kv 45 feet Over 1000kv As established by line owner Help in determining the voltage of electric lines is available by calling a local PECO office. PECO will be happy to assist at the job site and tell you the voltage of the line and the distance you must keep away. If you require this service, please give the local PECO office advance notice. 25.3 Crane-Suspended Work Cages 1. Accidents that occur during the use of crane-suspended work cages are caused by: a. Failure of the cable suspending the work cage b. Fall from the work cage c. Snagging obstructions while hoisting or lowering the work cage d. Failure of the load line due to two-blocking 25.4 Procedure 1. Crane suspended work cages may only be used when all other means of hoisting personnel prove impossible or impractical. 2. The work cage must be capable of supporting at least four times the intended personnel load. The cage must be fully protected with guardrails, midrails and toe boards. The top of the work cage does not have to be protected. Supporting attachments should be installed at each corner. When suspended, the supporting cables should not create a hazard to the employee inside of the work cage. 3. Each employee working from a crane suspended work cage must wear safety belts and remain tied off to an independent overhead lifeline at all times. 4. The lifeline may be a nylon sling or steel choker securely attached above the headache ball of the load cable, or to attachment "ears" on the side of multi-part load line blocks. The nylon sling or steel choker must be capable of withstanding 5,400 pounds. breaking load for each employee tied off to it. The lifeline must never be secured to a building or other fixed structure. 5. Crane suspended work cages may not be used as a personnel elevator without permission from the company safety director. Employees may not climb from the work cage while it is elevated. 6. Both the crane operator and the signalman must be informed whenever a crane suspended work platform is occupied. The signalman must be attentive to obstructions that could cause the work cage to tip. 7. The rigging of a crane suspended work cage must be inspected each day before use. 8. The crane utilized to hoist the work cage must have an operation anti-two blocking device. Inspection and testing of this device must be performed each day before hoisting personnel. 9. The work cage must be certified and engineered to meet or surpass OSHA requirements. 10. Before lifting personnel in a work cage, a "Test Lift" must be performed with weights equal to the weight of the personnel being lifted. 11. A crane inspection and authorization letter permitting use of a work cage must be obtained from the crane manufacturer prior to the job start.
REV2.1 February 13, 2018 Page 115 | 165 The Elliott-Lewis Safety Manual 25.5 Gantry Cranes 1. Rigging/Material Handling can be accomplished using gantry cranes and chain fall hoists. Only designated personnel shall be allowed to use this equipment on any project. This designated person shall be considered “qualified”. A qualified person is one who, by possession of a recognized degree in an applicable field, or certificate of professional standing, or who, by extensive knowledge, training, and experience, has successfully demonstrated the ability to solve or resolve problems related to the subject matter and work. 2. New or repaired gantry cranes shall be inspected by a designated person prior to initial use to verify compliance with ASME B30.2. Inspection intervals shall be designated as frequent and periodic. Frequent inspections are visual examinations by the operator or other designated personnel with records not required. This equipment shall be inspected prior to each use on each shift. Periodic inspections are visual inspections of the equipment performed monthly by a designated person making records of apparent external conditions to provide the basis for a continuing evaluation. These inspection reports shall be made and kept on file for critical items such as hoisting machinery, sheaves, hooks, hoist chains, ropes, and other lifting devices. Under normal service an annual inspection and load test shall be done by a Certified Inspector. The gantry crane’s rated load shall be placed in an easily visible area. The annual inspections and load tests will be maintained in the corporate office. 25.6 Helicopter Cranes 1. Unlike hydraulic cranes, certain specific procedures must be followed when utilizing a helicopter crane. All hired aircraft shall comply with all applicable regulations of the Federal Aviation Administration. 2. Based on our prior experience, Keystone or Carson Helicopter Service is available for hire. The safety director must be notified before any lifts are scheduled. It is the responsibility of the Project Manager to insure receipt of a job specific certificate of insurance. 3. Pre-Task Tailboard Briefing: Prior to lifting, the operator will assemble all site employees for a briefing on the plan of operation for each day’s work. Each crane service will supply its own rigger. The rigger shall do all hook-up of the materials to be lifted, using his own slings and shackles. He will also provide and maintain the two-way communication with the operator. Tag lines shall be of a length that will not permit their being drawn up into the rotors. Prior to the first lift, the helicopter shall make a brief pass and hover over the ground level loading site to blow dust, dirt, and debris out of the area. 4. Personal Protection Equipment- All employees shall wear hard hats with chinstraps and be issued elastic- banded goggles. Loose fitting clothing likely to flap in the rotor downwash to possibly get snagged on the material or hoist lines may not be worn. Long pants and long-sleeved shirts are required. 5. Cargo Hooks- All electrical cargo hooks shall have the electrical activating device so designed and installed as to prevent accidental operation. They also shall be equipped with an emergency mechanical control for releasing the load. 6. Approach Distance- No employees shall be permitted to approach within fifty (50) feet of the helicopter when the rotors are turning unless their work duties require their presence in that area. 25.7 Safe Rigging Practices The term rigging refers to both of the following:
1. The hardware and equipment used to safely attach a load, equipment, or material to a lifting device. The process of safely attaching a load, equipment, or material to a hook by means of adequately rated and properly applied slings and related hardware and equipment.
REV2.1 February 13, 2018 Page 116 | 165 The Elliott-Lewis Safety Manual 2. Synthetic slings will be provided to employees and we be subject to an annual inspection from the safety department. During that process, slings will be taken out of service that show signs of defects and wear. 3. All slings given out are marked Elliott-Lewis and are intended to be used only for company approved tasks.
Sling angles are extremely important in calculating the capacity of a sling on any particular lift. As the angle increases (degree number gets smaller), the stress applied to the sling increases, which results in a decrease in capacity of the sling. Always strive for 45 degrees or greater. Never go below 30 degrees.
1. Personnel on large rigging jobs must be trained and qualified for all assembly/disassembly of cranes. This includes setting counterweights. 2. Always inspect all rigging to be used, prior to lifting, whether it is company rigging or not. Then complete the rigging checklist to ensure all rigging complies with the standards 3. Defective equipment shall not be used and will be removed from service immediately: a. Synthetic slings i. Abnormal wear ii. Torn stitching iii. Visible red thread from the interior of the sling fabric iv. Broken or cut fibers v. Discoloration or deterioration vi. Evidence of heat damage b. Wire-rope slings with i. Kinking, crushing, bird-caging, or other distortions ii. Evidence of heat damage iii. Cracks, deformation, or worn end attachments iv. Broken wires in excess of regulatory requirements v. Hooks opened more than 15% at the throat vi. Hooks twisted sideways more than 10° from the plane of the unbent hook 4. Plan all aspects of the lift including the rigging process well before proceeding 5. Ensure you know the rated capacity of the sling 6. Ensure you know the size, weight, and center of gravity of the load 7. Never load more than the capacity of the sling 8. Synthetic slings are lightweight and easy to use. However, they are easily damaged. Ensure that you protect ragged or sharp edges to keep slings from being cut and possibly losing the load. Synthetic slings must be marked with their capacity. If safety threads are exposed, remove the sling from service 9. Wire rope sling capacities should be checked for capacity on a rigging chart if not tagged. Wire rope slings are to be removed from service when 10 broken wires in one lay are found, or when 5 broken wires in one strand in one lay are found 10. Always ensure that no employees or passersby can get near or under a suspended load 11. Chain slings are highly resistant to heat and abrasion. However, they are prone to weak link failures. Only Grade 8 or 10 steel chain slings are permitted. They must have capacity and inspection tags attached 12. No sling should be used when knotted, twisted, kinked, or if they have any burned or chemically affected areas 13. Always pad and protect slings from sharp edges REV2.1 February 13, 2018 Page 117 | 165 The Elliott-Lewis Safety Manual 14. All employees will be kept clear of a suspended load that are not authorized to be involved with the task 15. Tag lines shall be used unless their use creates a greater hazard. Tag lines shall be used for guidance 16. Do not use slings, eyebolts, shackles, or hooks that have been cut, welded, or brazed. 25.8 Wire Rope 1. Pre-Lift Inspection- Running ropes shall be visually inspected once each working day by the operator. This visual inspection shall consist of observing any rope that can reasonably be expected to be in use during that day’s operations. These visual observations should be concerned with discovering gross damage that may be an immediate hazard, such as rope distortion such as kinking, crushing, un-stranding, bird caging, main strand displacement, core protrusion, corrosion, and broken or cut strands. 2. Annual Inspection- A thorough inspection of running rope and standing rope shall be made during the Annual Certification performed by a third party 3. Criteria for Replacement- The following criteria determine when a wire rope is no longer acceptable for service: a. In running ropes, six randomly distributed broken wires in one lay or three broken wires in one strand in one lay (for rotation-resistant rope, more than one broken wire in any one lay shall be sufficient reason to consider not using the rope) b. One outer wire broken at the point of contact with the core of the rope which has worked its way out of the rope structure and protrudes or loops out from the rope structure. Additional inspection of this section is required c. Wear of one-third the original diameter of outside individual wires d. Kinking, crushing, bird caging, or any other damage resulting in distortion of the rope structure e. Evidence of any heat damage from any cause. f. Reduction from nominal diameter of more than g. 1/64 inch for diameters to and including 5/16 inch h. 1/32 inch for diameters 3/8 inch to and including 1/2 inch i. 3/64 inch for diameters 9/16 inch to and including 3/4 inch j. 1/16 inch for diameters 7/8 inch to and including 1 1/8 inches k. 3/32 inch for diameters 1 1/4 inches to an including 1 ½ inches l. In standing ropes, more than two broken wires in one lay in sections beyond end connections or more than one broken wire at an end connection. (For inspection purposes, consider the area within two rope diameters of an end connection to be “at an end connection.”)
All rope which has been idle for a period of a month or more due to shut down or storage of a crane on which it is installed shall be given a thorough inspection before it is used. This inspection shall be for all types of deterioration and shall be performed by an authorized person whose approval shall be required for further use of the rope.
REV2.1 February 13, 2018 Page 118 | 165 The Elliott-Lewis Safety Manual 26 Emergency Response Program
26.1 General Hazardous waste spills and releases pose a significant threat that endangers the environmental quality and human and animal life. An effective plan includes communication procedures, pre-emergency planning, notification procedures, training, emergency medical treatment, site security, use of personal protection equipment, and follow-up critique. 26.2 Emergency Planning Projects that produce, use or store a designated Extremely Hazardous Substance above a specific threshold planning quantity, the Safety Director must be notified who will in turn notify that the project is subject to The Superfund Amendments and Reauthorization Act of 1986 (SARA TITLE III) per the sample form letter (see Attachment A). ***
The proper Local Emergency Planning Committee for the project's county location will also be notified.
Emergency Response Procedures
In all cases, should a spill/release occur, IMMEDIATELY call the safety department:
Bill Schwartz: Office: (215) 698-4499 Cell: (215) 399-7417
Kraig Wicklund: Office: (215) 698-5976 Cell: (215) 341-8221
A determination of the proper response will be made and guidance for prompt containment and clean-up will be given.
Temporary containment can be provided by the use of sandbags, oil-dry, or "hot dogs." Correct use of personal protection equipment shall be observed. The site can be secured with caution tape or any type of temporary fencing. All wastes and contaminated clean-up materials must be placed and sealed in plastic bags for proper disposal.
Should a major spill occur, a commercial spill/waste disposal company will be brought in, i.e. J&J Spill Company, (610) 277-4511.
Emergency Response Notification Procedures
With hazardous chemical accidents, time is critical to prevent a major disaster. After the safety director has been notified, he will determine if it is above the specific reportable quantity (RQ) regulated by The Federal Superfund (CERCLA). See Attachment B for additional agencies that may require notification. Notifications will include the chemical name, CAS number, level of hazard, estimate of quantity, time and duration of spill/release, the medium into which the accident happened, health risks, precautions, and the telephone number of the contact person. Follow-up written notice will update previous response action and information.
REV2.1 February 13, 2018 Page 119 | 165 The Elliott-Lewis Safety Manual 26.3 Sara Title III Emergency Planning (Sample form letter the employer may use to notify emergency planners of the workplace being subject to Sara Title III emergency planning.)
(Date)
To: Pennsylvania State Emergency Response Commission c/o Pennsylvania Emergency Management Agency P.O. Box 3321 Harrisburg, PA 17105
Attention: Sara Title III
This is to notify the Commission that, pursuant to Section 302(c) of SARA Title III, our facility is subject to Subtitle A emergency planning requirements because the following extremely hazardous substances are on the premises (list the substances). The facility representative who has been designated as the emergency coordinator to participate in the emergency planning process is (name and position) at (telephone number).
Sincerely,
(Signed by facility owner or operator)
Address: (actual address, not P.O. Box)
cc: Local Emergency Planning Committee
(In Pennsylvania, a copy of this notification letter must also be sent to the local Emergency Planning Committee in the county where the facility is located.)
REV2.1 February 13, 2018 Page 120 | 165 The Elliott-Lewis Safety Manual 26.4 PA State Emergency Response Commission (SERC)
24 Hours
(717) 783-8150
24 Hours/Emergency only
NATIONAL RESPONSE CENTER
(800) 424-8802 24 Hours
LOCAL EMERGENCY PLANNING COMMITTEE (LEPC)
Philadelphia County 574-1138
Bucks County 348-7518
Montgomery County 631-6530
Delaware County 565-8700
Berks County 374-4800
Lehigh County 820-3073
FOR ACCIDENTS INVOLVING TRANSPORTATION
Call 911
REV2.1 February 13, 2018 Page 121 | 165 The Elliott-Lewis Safety Manual 27 Boiler Safety Policy
It is the policy of Elliott-Lewis Corporation to provide boiler service that surpasses the rigid requirements of the State of Pennsylvania and our local utility companies. It is the commitment of our employees, at all levels, to conduct our operations from the planning stage to implementation in a manner reflecting the goals of the Company Safety Program. Achieving these goals involves education, planning, coordination, and implementation.
New product development and changes in permit and licensing laws governing boiler installation and retrofits provide a continual educational challenge for Elliott-Lewis and its technicians. The company has the additional challenge and responsibility to educate the client. Total awareness of the environmental impact and possible liability exposures of each type of boiler system allow the client a unique opportunity to choose a system to fit his current and future needs.
With the proper education, we can proceed with planning. Our in-house engineer will develop a proposal adaptable to the confines of the existing system or present a total replacement system.
The energy source determines the path of coordination. Our engineer, in conjunction with our technician expert with the energy source, will present the plan for approval with the Department of Labor and Industry, Philadelphia Electric, Philadelphia Gas, and local licensing bodies. This plan must also be presented to and approved by the client's insurance carrier.
Implementation means more than installation. During installation, all OSHA standards must be met including those applicable to confined space and welding procedures. The client's insurance inspector should be present to witness the Hydrostatic test of the boiler. The inspector from the Boiler Division of the Pennsylvania Department of Labor will verify the completed installation. Photos of the completed installation and a copy of the boiler certificate should be kept in the project file in the office.
Boiler system inspections require an educated technician, equipped with the applicable testing monitors, following a set of fixed company procedures. This inspection checklist is in duplicate form, one to be left attached to the system, the other is kept in the office file.
The cooperation of Elliott-Lewis management in conjunction with the education of the client, the approval of licensing bodies, and the proper installation and testing of the system will guarantee a safe boiler program.
For Lockout/Tagout procedures for our boiler operations, please see section
REV2.1 February 13, 2018 Page 122 | 165 The Elliott-Lewis Safety Manual 28 Forklift Safety
28.1 General Forklift trucks, when operated properly by a qualified person, are made to stock and move material. They can be powered by propane, electricity, gasoline, or diesel fuel. OSHA regulations pertaining to forklifts can be located in 29 CFR 191078.
The majority of forklift accidents involve the driver striking a co-worker because of a judgment error. Only two percent of all accidents involve overturning the vehicle.
A forklift with a lifting capacity of 8,000 pounds will weigh approximately 14,000 pounds. Safety awareness is not only important to the operator, but also to those in close proximity of its operations.
Always think, act, and be professional in your defensive driving. This forklift policy applies to any type of motorized, material or passenger moving piece of equipment. 28.2 Definitions Center of Gravity: That point of an object at which all of the weight of the object is considered to be concentrated
Counterweight: The weight that is part of the structure of a forklift that is used to offset the load and reduce the tendency for it to tip over
Fulcrum: The axis of rotation of the forklift when it tips over
Grade: The slope of any surface that is measured as the number of feet of rise or fall over a hundred-foot horizontal plane
Lateral Stability: The resistance of a forklift to tip over sideways
Line of Action: Is an imaginary vertical line through the center of gravity of an object
Load Center: Is the horizontal distance from the edge of the load to the line of action through the center of gravity of the load
Longitudinal Stability: The resistance of a forklift to overturn forward or backward
Moment: The product of the weight times the distance from the line of action
Track: The distance between wheels on the same axles
Wheelbase: The distance between the centerline of the front and rear axles
Stability Triangle: A forklift has a three-point suspension system, i.e., the vehicle is supported at three points. Even if it has four wheels, the steering axle is attached by one pivot pin. The triangle is formed by the connection of an imaginary line between the three points.
Stability: The determination of whether an object is stable is dependent on the moment (weight) of an object at one end of a system being greater than, equal to or less than the moment of an object at the other end of a system. A simple illustration is a seesaw. The weight of one person at one end of the seesaw at a certain distance from the fulcrum (pivot point) "balances" another weight of a person at a certain distance from the fulcrum.
REV2.1 February 13, 2018 Page 123 | 165 The Elliott-Lewis Safety Manual 28.3 Operator Qualification and Training 1. Operators must be a minimum of 18 years of age and possess a valid automobile driver's license. 2. The operator shall be instructed and approved by a competent person – the Safety Director -- as to the safe operation of each type/model of forklift. 3. All operators must wear the seat belt and a hard hat. 4. The operator will be provided with a copy of the manufacturer's operating manual. 5. Untrained employees may not operate the forklift. 6. Training shall consist of a combination of classroom instruction, utilization of videos and practical, "in-the- seat" training. 7. The designated trainer shall evaluate each operator's performance before certifying that person's ability and approval. 8. A copy of each operator's certification shall be retained. 9. An annual performance evaluation shall be implemented and documented for each operator. 28.4 Forklift Safety Checklist 1. Complete a visual "walk-around" safety check including: a. Check position of forks. b. Check position of rear steering wheels. c. Check for any tools or materials on the floor or deck of the forklift. d. Check position of any material stacked adjacent to forklift. 2. Complete a safe operation check list including: a. Check engine oil level. b. Check fuel level. c. Start forklift, test brake pedal height. d. With engine running, turn steering wheel from "lock-to-lock," checking for any loose play or belt squeal. e. Check horn operation. f. Check back up beeper operation. g. Check clutch and gear shift operation. 28.5 Safe Forklift Operating Rules 1. Keep to the right, the same as an automobile. 2. Do not speed. 3. No riders are allowed. 4. No "horseplay" is allowed. 5. When doing maintenance work on the forklift, remove the key from the ignition. 6. Always keep your arms and legs inside the forklift. 7. Always face the direction of travel. 8. Be alert for oil or grease spots on your roadway. 9. Never travel with the load raised high. 10. No towing or pushing is allowed. 11. Be aware of edge of the loading dock if applicable. 12. Stop completely before raising or lowering a load. 13. Make certain the forks are all the way into a pallet. 14. Certain that the load is balanced. 15. Do not move loads with a broken pallet. 16. When moving with a load, always tilt the mast slightly backward to stabilize the load. REV2.1 February 13, 2018 Page 124 | 165 The Elliott-Lewis Safety Manual 17. No smoking while operating a forklift. 18. When parking on an incline, "block" the wheels; do not rely on the parking brake. 19. Never park with the forks in the air. 20. When parked at the end of each shift, the forklift must be shut off, the forks lowered, parking brake engaged, and the gear shift in neutral. 28.6 Forklift Operation Area 1. Warehouse ceiling height including sprinklers, fans and lights must be of proper clearance. 2. When operating the forklift, the overhead exhaust fans must be engaged. 3. Lighting must be sufficient to operate the forklift without the headlights. 28.7 Forklift Maintenance 1. Prior to each shift, the operator must check all fluid levels. Any operating problems must be documented and submitted to the operator's supervisor for correction. The supervisor will determine if the forklift should be removed from service. 2. The preventive maintenance program will be rendered by Delaware Valley Forklift. 3. Full service will be completed every 500 hours of operation. 4. All safety checks, documented P.M.'s, and service invoices shall be kept in an equipment folder.
29 Emergency Action Plan
29.1 General Purpose The purpose of an Emergency Action Plan is to protect the employees from serious injury, property loss, or loss of life in the event of a major disaster. A major disaster constitutes one of the following: fire, tornado, earthquake, bomb threat, hazardous chemical spill, or an airplane crash into the main office building. This emergency action plan is available at any time for any employee to review. 29.2 Emergency Control Committee An Emergency Control Committee, composed of the Safety Director, Facility's Manager, the company President, or Vice President shall make all decisions assessing the type of disaster and the appropriate response. Additionally, they will assign personnel to prepare and administer an evacuation map including a test evacuation. This map will designate the emergency exits and the shut-offs for the water, gas, and electrical utilities. It will also locate any hazardous materials stored on site for the emergency response personnel. All contact with the news media shall be addressed only by a representative of the committee. 29.3 Emergency Alarms In case of a fire, the sprinkler system will come on in the fire area. As the water begins to flow, an audible alarm will sound, warning all employees to evacuate. A natural disaster will announce itself, sometimes without warning. During the day, the switchboard operator will notify all employees of any disaster or bomb threat. 29.4 Bomb Threats Bomb threats should be treated as real emergencies. The switchboard operator or the person receiving the threat shall attempt to remain calm, and if possible, complete the bomb threat questionnaire form. The form shall be presented to a member of the Emergency Control Committee to determine the appropriate procedures to be taken and the law enforcement agencies to be contacted. (See attachments) *** REV2.1 February 13, 2018 Page 125 | 165 The Elliott-Lewis Safety Manual 29.5 Tornado/Earthquake In the event of a natural disaster where we have some warning, employees will be immediately informed. Employees should shut off their equipment and proceed to safe areas. Doors and windows should be opened to equalize pressure, listen for radio updates. Do not go outside the building until it has ended. Be calm, help your fellow employees to exit the building, and take a head count. Allow the emergency response personnel to do their job. 29.6 Emergency Phone Numbers POLICE 911 or 8th District: (215) 686-3080 FIRE: 911 FBI: (215) 629-0800 PGW (GAS): (215) 235-1212 WATER DEPT. (215) 592-6300 PECO (ELECTRIC): (215) 841-4141 STATE POLICE: (215) 560-6200 POISON INFO: (215) 386-2100 OSHA: (215) 597-4955 EPA: (800) 424-8802 SUICIDE: (215) 686-4420
29.7 Bomb Threat Checklist
Instructions:
Be calm and courteous, listen, and do not interrupt the caller. Try to continue the conversation to learn as much as possible.
Name of Call Recipient: ______
Time: ______am/pm Date: ______
Caller Identity:
Name: ______
Male Female Adult Child Accent Location
Call Origin:
Local Long Distance Cellular Phone Booth
Bomb Specifics:
1. When will bomb go off? 2. Location of bomb. 3. What kind of bomb? 4. How do you know so much about the bomb?
REV2.1 February 13, 2018 Page 126 | 165 The Elliott-Lewis Safety Manual ______
Did caller seem familiar with our property? ______
Notify a member of the "Emergency Control Committee" IMMEDIATELY.
30 Emergency Recovery Plan
30.1 General Purpose The purpose of our Emergency Recovery Plan is to provide uninterrupted service to the customer in the event of a major disaster. A major disaster could include, but is not limited to, a hurricane, tornado or earthquake. 30.2 Coordination It is the responsibility of each Division Manager (construction, industrial service, commercial service, residential service, facilities service and crane service) and his field supervisors and dispatchers to inform his/her technicians of the type of severity and possible length of the disaster. If the corporate headquarters is rendered unavailable, home offices are to be assigned. Each Division Manager will ascertain the priority of the customer's needs and effects on the general public, and the corresponding response. 30.3 Communication Emergency communication is achieved by continuous use of our pager and cellular phone systems if electricity and regular phone service is unavailable. Response to the customer supersedes cellular costs. 30.4 Vendor Supplies In direct cooperation with the principals of our vendors, in particular, United Refrigeration and its twenty-seven local branches, we have twenty-four-hour access to any required equipment and parts. 30.5 Safety Each technician has been trained to render each workplace safe and to complete his tasks in a safe manner. The Safety Manual in each van is readily available for reference. The Safety Engineer can be paged at 215-998-6262 to answer any additional concerns.
REV2.1 February 13, 2018 Page 127 | 165 The Elliott-Lewis Safety Manual 31 Security Policy
31.1 General Purpose The purpose of a security policy is to provide the highest level of security and safety to our employees and property in our main office and in the field. This policy should be used as a risk management tool to minimize business interruptions caused by intruders, vandals, or terrorists.
31.2 Building Security Unauthorized entry events may involve a vandal, a thief, an irate spouse, a deranged individual, or a terrorist. All employees have the duty and the obligation to be diligent when allowing visitors into the corporate headquarters. All visitors, prior to entering the building, should be questioned as with whom they are meeting and the nature of their business. All visitors shall be escorted by an Elliott-Lewis employee throughout the building and shall not be left unaccompanied. All employees must courteously, but forcefully, challenge any individual who does not look familiar, is unaccompanied, or appears suspicious in any way while on the premises. Do not assume that an unfamiliar person wandering in the building is a member of the staff. 1. Whenever an employee is expecting a visitor for a meeting, they are to notify the receptionist, in advance, of the name, company and arrival time to minimize the questions he/she will be required to ask of the visitor. 2. All employees shall be issued a name, number, and photo identification. Security pass cards will be issued to those required to be in corporate headquarters on a daily basis. These entry cards are restricted to times and areas of entry. 3. When a burglar alarm is activated after hours, meet the police outside the building and allow them to enter first. 31.3 Warehouse Security 1. Do not allow an unfamiliar person to remove equipment from the corporate warehouse without questioning authorization. 2. At the end of the day or on a weekend, if you appear to be the last person to exit the building, confirm that the warehouse overhead doors and exit doors are closed and secured. The janitorial service will generally leave the building without investigating the reason the security alarm will not set. This will assure that the alarm can be easily armed by the last person out. 3. The outside crane and equipment storage areas are under 24-hour camera security. In addition, the last person out shall do a final walk-around to check for any abnormalities. 4. In order to minimize corporate risk exposures, the owners of all non-company owned equipment stored at our facility must submit a certificate of insurance listing that equipment. 31.4 Off-Site Security All field personnel should be aware of the other ELCO employees and sub-contractors with whom they work and challenge anyone that doesn’t belong in the jobsite area. 31.5 Van, Tool, and Equipment Security Service vans and delivery trucks should not be left running unattended. All door locks and side and rear padlocks should be secured at all times. All ladders should be secured by chains and locks. All on-site toolboxes shall be padlocked and chained to a structure. Keys, tools, cellular phones and laptop computers should not be left in plain sight in any vehicle.
REV2.1 February 13, 2018 Page 128 | 165 The Elliott-Lewis Safety Manual 31.6 Computer Security Elliott-Lewis has a computer network system with a firewall installed for proper security safeguards. In addition, all computers are set up with password protection. However, it is up to the employees to assure that security is never compromised. Always sign out your computer when you are leaving for an extended period of time or at the end of the day. Never give your password to someone else. Laptops, because of their portability, are easy targets of theft. Use the proper safeguards to avoid this situation. Report any unauthorized use of your computer or any other computer to your supervisor. 31.7 Telephone Security Do not answer surveys or questions from marketing people. Do not give anyone information such as the number of employees, number of vehicles, or names of employees and staff. During a threatening call, stay calm, keep the individual on the phone as long as possible, and ascertain as much information about the threat as possible. Immediately notify your supervisor and the police. 31.8 Handling Suspicious Packages Anthrax and related terrorist acts have increased the need for proper handling of suspicious packages and envelopes. Disposable latex gloves are available for those employees who handle mail. The following guidelines are to be used when handling such an item: 1. Do not shake or empty the contents of the envelope or package. 2. Put the envelope or package in a plastic bag or other container to prevent the contents from leaking. 3. Leave the room and close the door or section off the area. Keep others from accessing the area. 4. Wash your hands with soap and water. 5. Report the incident to your supervisor and local police. 6. Make a list of all people in the room or area when the letter or package was recognized. 7. If powder has spilled from a suspicious envelope or package: a. Do not try to clean up the powder. b. Cover the spilled contents immediately with anything. c. Leave the room and close the door or section off the area. Keep others from accessing the area. d. Wash your hands with soap and water. e. Report the incident to your supervisor and local police. f. Remove heavily contaminated clothing as soon as possible. Place it in another container that can be sealed. Give the bag of clothing to emergency responders. g. Shower with soap and water as soon as possible. Do not use bleach or other disinfectant on your skin. h. Make a list of all the people in the room or area, especially those who came in contact with the powder. Provide this list to law enforcement and public health officials. 31.9 Pandemic Preparedness This pandemic disease plan has been developed to set priorities and choices that need to be considered to maintain essential levels of service and to ensure advanced planning and preparedness to help sustain the critical operations within the company. The Safety Director working with the Chief Operating Officer will be responsible for dealing with critical issues. The following procedures should be utilized prior to the onset of just such an event: 1. Employees shall be trained on the health issues including prevention, symptoms, means of spreading, and return to work policies. Ensure language challenged employees are included in the training process. 2. Use of hand sanitizers, tissues, hand washing facilities, and disposable towels should be encouraged by the company. All will be provided by the company. 3. Where possible, work-at-home situations can be developed to limit the spread of disease. 4. A plan should be prepared for mass absenteeism to ensure continuity of the business. REV2.1 February 13, 2018 Page 129 | 165 The Elliott-Lewis Safety Manual 5. The company should encourage employees to receive all appropriate immunizations. 6. A communication system should be developed to provide all personnel with the means to track company business and employee status. This system should include contacts for all customers and suppliers who could be impacted by our ability or inability to provide service. Notification should be made to them when operations stop or resume. 7. In the event of an outbreak, social distancing should be implemented to limit spreading. 8. All areas frequently contacted such as doorknobs, faucets, and handrails, should be frequently cleaned and disinfected. 9. Periodic testing of these strategies should be done to ensure they are effective.
32 Home-Based Employees
32.1 General Purpose Work-from-home arrangements can suit the needs of both the employee and Elliott-Lewis Corporation. Guidelines regarding the responsibilities and rights regarding occupational health and safety, rehabilitation and worker’s compensation are designed to protect both parties. 32.2 Requirements Employees must cooperate with Elliott-Lewis Corporation in its efforts to comply with occupational, health, and safety requirements. A workplace assessment is a self-certification that is utilized to identify potential health and safety hazards and to deal with them appropriately. This assessment should be done by a trained individual and the assessment should be confined to that part of the home which is used as a workplace. The assessment shall establish the equipment necessary for an employee to undertake safely home-based work. If necessary, the company shall provide suitable equipment such as a desk, chair, and computer. A first aid kit should be readily available in the event of an emergency. The following are a few questions that should be answered in the assessment: 1. Are temperature, noise, and ventilation and lighting levels adequate for maintaining a normal level of job performance? 2. Are all stairs with four or more steps equipped with handrails? 3. Are exits from the work area clear of obstructions and permit visibility and movement? 4. Are there sufficient smoke detectors in the house? 5. Are there sufficient outlets to avoid any electrical overloads? 6. Are all circuit breakers or fuses properly labeled? 7. Is all electrical equipment free of hazards such as exposed, lose or frayed wiring? 8. Are all outlets properly grounded? 9. Are all phone lines, electrical cords and extensions secured along the baseboard and not a tripping hazard? 10. Are carpet seams well secured to the floor and not a tripping hazard? 11. Is the employee’s chair in good condition and adjustable? 12. Is the workspace adequate ergonomically? (i.e., proper back, wrist, and foot support) The goal of Elliott-Lewis Corporation is to assure that the home-based employee has a safe and pleasant work environment that maximizes their working experience and minimizes worker’s compensation costs and lost productivity.
REV2.1 February 13, 2018 Page 130 | 165 The Elliott-Lewis Safety Manual 33 Bloodborne Pathogens
33.1 General Statement Elliott-Lewis will limit or eliminate the employee’s occupational exposures to blood and other potentially infectious materials since any exposure could result in the transmission of blood borne pathogens resulting in disease or death. This applies to any and all employees who could possibly be exposed through the performance of their job demands to come in contact with blood, any blood-tainted equipment or other infectious materials. “Good Samaritan” acts such as assisting a co-worker with a nosebleed would not be considered occupational exposure. Since the Company provides facility maintenance services at non-heath care facilities, these facilities maintenance personnel and janitorial staff have minimal occupational exposure. It is the employer’s responsibility to determine which job classifications or specific tasks or procedures expose the employee to this hazard. 33.2 Training All employees will receive blood borne pathogen training and training on the hazards associated with various jobs throughout the company at the time of initial hire or job assignment and annually thereafter. Each employee shall have access to a copy of the Corporate Exposure Control Plan. 33.3 Definitions Blood: Human blood, human blood components, and products made from human blood. Blood borne Pathogens: Pathogenic microorganisms that are present in human blood and can cause disease in humans. Body Substance Isolation (BSI): A control method that defines all body fluids and substances as infectious and is an acceptable alternative to Universal Precautions. Clinical Laboratory: A workplace where diagnostic or other screening procedures are performed on blood or other potentially infectious materials. Contaminated: The presence or the reasonably anticipated presence of blood or other potentially infectious materials on an item or surface. Contaminated Laundry: Laundry that has been soiled with blood or other potentially infectious materials or may contain sharps. Contaminated Sharps: Any contaminated object that can penetrate the skin including, but not limited to, needles, scalpels, broken glass, broken capillary tubes, and exposed ends of dental wires. Decontamination: the use of physical or chemical means to remove inactive or destroy blood borne pathogens on a surface or item to the point where they are no longer capable of transmitting infectious particles and is rendered safe for handling. Engineering Controls: Controls that isolate or remove the blood borne pathogen hazards from the workplace. Exposure Control Plan: A written Plan designed to eliminate or minimize employee exposure to blood and OPIM, reviewed annually. Exposure Incident: A specific eye, mouth, other mucous membrane, non-contact skin, or parenteral contact with blood or other potentially infectious materials that results from the performance of an employee’s duties. HBV: Hepatitis B virus.
REV2.1 February 13, 2018 Page 131 | 165 The Elliott-Lewis Safety Manual HIV: Human immunodeficiency virus. Other Potentially Infectious Materials (OPIM): The following human body fluids: semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any bodily fluid that is visibly contaminated with blood, any unfixed tissue or organ, any culture medium containing any related materials. Parenteral: Piercing mucous membranes or the skin barrier through events as needle-sticks, human bites, cuts, and abrasions.
Personal Protective Equipment: Specialized clothing or equipment worn by an employee for protection against a hazard. Regulated Waste: Refers to the following categories of waste which require special handling at a minimum (1) liquid or semi-liquid blood or OPIM, (2) items contaminated with blood which would release these substances in a liquid state if compressed, (3) items that are caked with dried blood and are capable of releasing these materials during handling, (4) contaminated sharps, (5) pathological and microbiological wastes containing blood or OPIM. Does not include discarded feminine hygiene napkins. Source Individual: Any individual, dead or living, whose blood or other potentially infectious materials may be a source of occupational exposure to the employee. Sterilize: The use of a physical or chemical procedure to destroy all microbial life including highly resistant bacterial endospores. Universal Precautions: An approach to infection control whereby all human blood and certain human body fluids are treated as if known to be infectious for HIV, HBV, and other Bloodborne pathogens. Work Practice Controls: Controls that reduce the likelihood of exposure by altering the manner in which the task is performed. 33.4 Exposure Control Plan 1. Employee Communication: The use of a warning label creates employee awareness and includes the universal biohazard symbol followed by the term “biohazard” which is placed on all bags/containers of contaminated laundry, regulated waste, on refrigerators and freezers that are used to store blood or OPIM and/or on bags/containers that are used to transport or ship blood or OPIM. a. This label has required colors: the background must be fluorescent orange or orange-red with lettering in contrasting color. Red bags may be substituted for the biohazard labels. All blood- soaked bandages or other potentially infectious materials must be put in these leak proof bags for handling, storage, and transport. 2. Exposure Determination: It is a function of the Safety Director in conjunction with the site project manager or salesperson to review the scope of the facility maintenance service rendered and prepare a written determination of all employee’s occupational exposures. Janitorial personnel have certain specific job tasks that have occupational exposures. a. We anticipate exposures in the cleaning and emptying of trash in bathroom facilities. A client’s employee may have suffered a nosebleed, allowing a splash residue in the washbowl or toilet bowl. Blood contaminated towels or toilet paper may be discovered in the trash receptacle. Discarded sanitary napkins shall be placed in a container provided by the facility that is leak proof on the sides and bottom. 3. Methods of Compliance: Universal precautions shall be observed to prevent contact with blood or other potentially infectious materials. Under circumstances in which differentiation between body fluid types is difficult or impossible, all body fluids shall be considered potentially infectious materials. REV2.1 February 13, 2018 Page 132 | 165 The Elliott-Lewis Safety Manual 4. Work Practice Controls: Work practice controls shall be utilized to eliminate or minimize employee exposure. These controls shall be examined and maintained on a regular schedule to ensure their effectiveness. The employer has readily accessible hand washing facilities on-site and shall ensure that the employees avail themselves immediately or as soon as feasible after the removal of gloves or other personal protective equipment. The employee is to use soap and water to flush any exposed skin or contacted body areas. a. If soap and running water are unavailable, antiseptic hand cleaner in conjunction with cloth/paper towels or antiseptic towelettes are an acceptable alternative. 5. Personal Protective Equipment: In all cases, employees are instructed to wear “appropriate” PPE. PPE will be considered appropriate only if it does not permit blood or OPIM to pass through to, or reach the skin, employee’s underlying garments, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of the time that the PPE will be utilized. PPE is to be provided at no cost to the employee. The employer shall ensure that appropriate PPE in the appropriate sizes is readily accessible. a. PPE may include non-porous rubber gloves, safety glasses with side shields, full laboratory coats, and full-face masks. All PPE must be removed and properly disposed of in a container prior to leaving the work area. It is the financial responsibility of the employer for repairing, replacing, cleaning and disposing of PPE. However, this does not include general work clothes. 6. Housekeeping: EPA-registered tuberculocidal disinfectants are appropriate for the cleanup of blood or OPIM. A solution of 5.25 percent sodium hypochlorite (household bleach), diluted between 1:10 and 1:100 with water is also acceptable for cleaning contaminated surfaces. 7. Hepatitis B Vaccination: This vaccination series is available to all employees who have occupational exposure within 10 working days of initial work assignment. The cost is the responsibility of the employer. An employee has the right to refuse the vaccination; however, the Company requires that the employee sign a refusal document. 33.5 Exposure Incident 1. Incident Investigation: An employee’s supervisor must prepare a documentation of the employee’s duties as relates to the exposure incident, the location and time of the incident, and the route or circumstances surrounding the exposure incident. This investigation shall include the source of the infectious material and the results of the exposed individual’s blood test. Consent must be obtained from the exposed employee, however, if consent is not received, the employee must sign a document to that effect. 2. Post-Exposure Counseling: All exposed employees shall receive post-exposure counseling that includes USPHS recommendations for prevention of HIV. These recommendations include refraining from blood, semen, organ donation; abstaining from sexual intercourse or using measures to prevent HIV transmission during sexual intercourse; and refraining from breast-feeding infants during the follow-up period. 3. OSHA 300 Log: All occupational exposure incidents must be entered on the OSHA 300 Log as an injury if the incident results in one of the following: a. the incident is work-related and involves the loss of consciousness, a transfer to another job, or restriction of work or motion b. the incident results in a recommendation of medical treatment c. the incident results in a diagnosis of seroconversion 33.6 Record Keeping The employer shall establish and maintain an accurate record for each employee with occupational exposure in accordance with CFR1910.1020. These records must be kept for the employment duration plus 30 years. Training records will include dates and contents of training, names and job titles of persons attending. Training records must be kept for a period of three years from the training date. The employer shall ensure that all records shall be made available upon request of employees, Assistant Secretary and the Director for examination and copying.
REV2.1 February 13, 2018 Page 133 | 165 The Elliott-Lewis Safety Manual Medical records must have the written consent of the employee before being released. The employer shall comply with requirements involving transfer of records set forth in 29CFR1910.1020(h).
34 Pressure Testing
34.1 General Statement Pressure testing of closed vessels and piping systems is an unavoidable requirement of reliability assurance. Engineers’ specifications typically dictate the degree to which tests must be performed. The two most common forms of reliability testing are hydrostatic and pneumatic. Hydrostatic testing uses water to fill the test area. This system is then pressurized using compressed air to the specified poundage expressed in psi. Because water cannot be compressed, it has little or no stored energy if done properly. Should a failure of a component occur, the sudden release is minimal due to the negligible stored energy. Damage is usually confined to the water release and related problems. Pneumatic testing, on the other hand, uses compressed air or nitrogen to pressurize the system to specific psi. Air can be compressed and during the compression phase, an extreme amount of energy is being stored within the testing vessel. With volumes and pressures being equal, the pneumatic testing method can store up to one thousand times more energy than the water testing process. Consequently, if a mishap occurs, we can anticipate an increased risk of injury to the testing personnel and any other tradesmen or building occupants in the area of the system failure, as well as, more extensive physical damage to the immediate surroundings of the incident. Thus, hydrostatic testing is the preferred alternative method of testing and should be implemented whenever possible. 34.2 Goals and Responsibilities The goal of this operational procedure is intended to provide the safest and most practical systems testing method. It is to be implemented in conjunction with the project and/or client specifications. This procedure applies to all job sites that utilize water or air pressure-to-pressure test systems, components, piping, or any of these combinations, either in the field or in the shop. Project managers are responsible for verifying contract test specifications to ensure compliance with this procedure. When discrepancies exist, the Project Manager will notify the Safety department. The Project Manager will also assign a Test Supervisor and ensure that all testing personnel have been trained and that the tagging systems are in place prior to testing. It is the responsibility of the testing supervisor to execute the requirements of this procedure. DANGER...SAFETY WARNINGS! Hydrostatic and pneumatic testing pressures are not equivalent. 1. The following equivalency chart identifies the energy that can be stored during a pneumatic test: Test Area Units Stored TNT Equivalent Energy 500 feet – one-inch pipe 412 psi 1.6 oz. 500 feet – one-inch pipe 1,635 psig 8 oz. 500 feet – one-inch pipe 6,548 psi 1 lb. 500 feet – one-inch pipe 14,723 psig 5 lbs.
REV2.1 February 13, 2018 Page 134 | 165 The Elliott-Lewis Safety Manual 2. During the sudden release of energy, i.e. valve opening, fitting failure, etc., this release can also be expressed as velocity. Any particle expelled from the line during a test failure can be measured in feet per second.
Velocity Velocity Pressure 100 # 127 ft/sec 125 # 141 ft/sec 150 # 156 ft/sec 175 # 170 ft/sec NOTE: a car traveling at 60 mph travels at 88 ft/sec Pneumatic testing failures are typically devastating with the degree of hazard directly proportional to the stored energy in the system. A low pressure, high volume system is just as hazardous as a high pressure, low volume system. 34.3 Testing Procedures 1. Hydrostatic Testing a. Water temperature i. Domestic water systems codes do not provide any temperature parameters. For testing, however, since water in the test lines will freeze when air temperatures are in the range of 32 degrees F, a suitable water substitute or an antifreeze additive will be employed when this condition exists. ii. Testing under the requirements of ANSI B31.1 requires the test be performed in accordance with ASME Section 1. This section forbids testing below 70 degrees. ANSI B31.3 does not mandate any temperature restrictions and is applicable to process piping. ASME Section VIII, Boilers, Pressure Vessels, recommends but does not mandate temperatures, but recommends temperatures to be a minimum of 60 degrees. b. Test pressures i. Typically, test pressures are specified in the contract and are usually promulgated from trade standards. ii. ANSI B31.1 Power piping: 1.5 times the design pressure, not to exceed any ratings of pumps, valves, vessels, or other components iii. ANSI B31.3 Process piping: non-metallic pipe-not less than 1.5 times the design pressure, but shall not exceed 1.5 times the maximum rated pressure of the lowest rated component in the system...metallic piping with non-metallic lining- the same as non- metallic. iv. Fire Protection System NFPA 13 - All new systems including yard piping shall be tested at not less than 200 psi for two hours, or at 50 psi above the maximum working pressure when the maximum working pressure of the system is in excess of 150 psi. v. Domestic Water Lines- Uniform Plumbing Code: five psi air maximum for 15 minutes or filling the system with water with no introduction of air or additional water: Hot & Cold Water Supply: test pressure-hydrostatic not to exceed the working pressure. NAPHCC: Drains, vents & sewers: the building sewer shall be plugged at the point of connection with the public sewer and shall be filled with water under a head of not less than ten feet. The water level shall not drop for at least 15 minutes. c. Test procedures
REV2.1 February 13, 2018 Page 135 | 165 The Elliott-Lewis Safety Manual i. The Test Supervisor shall coordinate and monitor each test and shall make other on-site trades aware of the test time and location. He shall also ensure that all employees are trained in the test procedures prior to the test start. ii. Each section of the system to be tested shall be reviewed to ensure no pressure condition exists within the system components. Potable water only shall be used for domestic systems. iii. A means shall be provided to drain test water directly into building sanitation or to the facility storm water system. Test water shall not be drained onto a floor with slope drainage to sanitation or storm water. iv. Where a safety relief valve is to be installed, it is to be set at 10 percent above the test pressure. v. When additional pressure is required due to pump limitations, only compressed air is to be used. Nitrogen or any other gas is not to be used. vi. When freezing hazards exist, a substitute liquid can be used, consult with the safety supervisor. vii. Test crewmembers shall maintain radio communications among themselves and those monitoring the gauges. viii. All valves used to block or isolate the system tests shall be tagged “DO NOT OPERATE.” ix. Upon completion of the test, the system shall be immediately returned to zero energy level. x. All test results shall be documented and retained in the job folder. 2. Pneumatic Testing a. Test Pressures i. ANSI B31.3 power piping: the minimum required test pressure shall be 1.20 times the design pressure with a maximum of 1.25 times the design pressure...the pressure cannot exceed the maximum pressure for any one component, but shall maintained for a period of ten minutes or the time to verify integrity. ii. ANSI B31.3 process piping: non-metal or metallic with non-metallic lining is only permitted with the owner’s approval yet within the manufacturer’s guidelines iii. Fire Protection Systems NFPA 13: all testing is permitted at 40 psi which must be allowed to stand for a period of 24 hours with not more than 1.5 psi leakage...if hot air is pumped into the system, it loses 1.5 psi depending on volume, as the air cools. iv. Uniform Plumbing Code-sanitary wastes, vents-maximum pressure is five psi, held for a period of 15 minutes...domestic hot and cold water supply: maximum pressure is 50 psi and held for a period of 15 minutes. v. NAPHCC-building sanitation-no requirements specified...domestic hot & cold water supply- pressures in accordance with manufacturer’s specs. b. Test procedures i. Pneumatic testing can be carried out using air...additional venting precautions must be developed when using nitrogen as this gas could become trapped in a room which could result in an oxygen deficiency. ii. All systems being tested shall be tagged “DO NOT OPERATE” in accordance with established lock-out/tag-out procedures. iii. Signs shall be posted in the test area for any tradesmen to report leaks to “______.” iv. A safety relief valve shall be installed and set at 10 percent over test pressure. v. Test pressures shall be increased to no more than 50 percent of the final test pressure. Additional pressure shall not be added until the system is verified that no leaks are present; additional pressure shall be increased at no more than 10 percent increments in 10-minute intervals. REV2.1 February 13, 2018 Page 136 | 165 The Elliott-Lewis Safety Manual vi. No repairs can be made when the system has more than 25 psi applied. vii. All gauges shall be calibrated and current within three months of the test date. viii. Upon completion of the test, the system shall be slowly bled until a zero energy level is achieved. ix. All test results shall be documented and retained in the job fold 35 Process Safety Management
35.1 Purpose The major objective of process safety management (PSM) of highly hazardous chemicals is to prevent or minimize consequences of unwanted releases of toxic, reactive, flammable or explosive chemicals especially into locations that could expose employees and others to serious hazards. An effective program requires a systematic approach to evaluating the whole chemical process. Using this approach, the process design, process technology, process changes, operational and maintenance activities and procedures, non-routine activities and procedures, emergency preparedness plans and procedures, training programs, and other elements that affect the process are all considered in the evaluation. 35.2 Training Each employee must be instructed in the known potential fire, explosion, or toxic release hazards related to their job and the processes and the applicable provisions of the emergency action plan at the site. Although the standard applies generally to manufacturing industries, the Company has exposure to refrigerants and the hazardous chemical ammonia as used in refrigeration. It is these chemicals that our assessment and management addresses. The following elements are required by OSHA standards: 1. Perform a workplace hazard assessment including identification of potential sources of accidental releases and prepare a range estimate of effects on the workplace and employees. This shall be reviewed with all employees including advising the host facility/client of any unique hazards presented specific to our work 2. Establish a system to respond to the workplace hazard assessment findings, which shall address prevention, mitigation, and emergency responses. Review the response system periodically 3. Safe work practices will be followed during operations such as lockout/tagout, confined space entry, opening process equipment or piping and control over entrance to a facility. Hot work shall not be performed until a hot work permits is obtained from the host facility client 4. Develop and implement operating procedures for the chemical processes, including procedures for each operating phase, operating limitations, and safety and health considerations. 5. Ensure all employees are provided the appropriate training for all the above and documentation as required. 6. Ensure that the working area or ammonia machinery room is classified as a “non-hazardous location”. This can be accomplished by providing a continuously operating mechanical exhaust system that ventilates at a minimum rate of 0.5 cfm per sq. ft. of machinery area with an independent emergency ventilation system available (ANSI/ASHRAE-15) 7. Wear the appropriate Personal Protective Equipment: Safety goggles Impervious clothes Impervious Gloves Respirator w/appropriate filter 8. Ensure that the exposure limit for ammonia of 50ppm over an 8-hour time weighted average is never exceeded. For the purpose of respirator selection, NIOSH has established an immediately dangerous to life and health level of 300ppm 9. Know the symptoms of exposure and the appropriate first aid procedures
REV2.1 February 13, 2018 Page 137 | 165 The Elliott-Lewis Safety Manual 10. PSM requires that an employee must immediately report any incident or near miss. An investigation of any incident, including a near miss, that results in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical in the workplace must be initiated. This investigation must be initiated as promptly as possible, but not later than 48 hours following the incident. A report shall be generated indicating the date of incident, date investigation began, description if the incident, factors that contributed, and recommendations resulting from the investigation. 11. The Company must make available all information necessary to comply with PSM to those persons responsible for compiling the process safety information, those developing the process hazard analysis, those responsible for developing the operating procedures, and those performing incident investigations, emergency planning and response, and compliance audits, without regard to the possible trade secret status of such information. Nothing in PSM, however, precludes the employer from requiring those persons to enter into confidentiality agreements not to disclose the information.
36 Mine Safety and Health
36.1 General Mine Safety and Health Administration (MSHA) established rules and regulations to amend existing training requirements of CFR Part 46 and Part 48. These requirements pertain to shell dredging, sand, gravel, surface stone, surface clay, phosphate and surface limestone mines. These final rule amendments allow the mine operator the flexibility to tailor training programs to their specific operations. These training programs are site-specific and must be aimed to address the needs of each operation. The scope of the corporate operations and thus, the risk exposure, involves the service, repair and replacements of rooftop air conditioners on buildings at surface level and at the bottom of an open-pit mine. Additionally, air conditioning service may be required on earth-moving vehicles utilized in the movement of product within the mine operation. As independent contractors, these operations fall under one of two categories with different and separate requirements. The first is New Miner Training or Newly Hired Experienced Miner Training. This training is required if you are: engaged in mining operations including developing, drilling blasting, extracting, milling, crushing, screening or hauling materials within the mine; a maintenance or service worker; working on mine equipment for frequent (a pattern of recurring exposure) or extended periods (more than five consecutive work days); or a construction worker who is exposed to the hazards of mining operations for frequent or extended periods. The second and applicable category is “Site-Specific Hazard Awareness Training.” This training is required for persons who may come onto a mine site but who are not miners. Examples include: office or staff employees, scientific workers, delivery workers, customers, vendors and visitors, maintenance or service workers who are working on non-mining equipment or who are not at the mine for extended periods, or miners (such as blasters or drillers) who move from one site to another while being employed by the same independent contractor. The corporate safety manual is divided into nine sections: a copy of 30 CFR Parts 46 and 48, an instructor’s guide a site-specific training plan, new miner training program, newly-hired experienced miner training program, new task-training program, annual refresher training program, hazard-awareness training program and the last section is devoted to various associated forms. Our approved plan per Section 46.3(b) contains the following information: the mine name, the MSHA mine identification number, the name and position of the designated person responsible for safety and health
REV2.1 February 13, 2018 Page 138 | 165 The Elliott-Lewis Safety Manual training at the mine, a description of the teaching methods, the course materials that are utilized in the training program, including the subject areas covered, the approximate time to be spent on each subject area, a list of persons who will provide the training and the subject areas in which each person is competent to instruct, and finally, the evaluation procedures used to determine the effectiveness of the training. The program also provides for eight hours of refresher training every 12 months. All training is to be documented and records are to be retrained for a period of two years.
Safety Manuals are also site-specific. The corporate safety manuals for the Hercules Plant and ESSROC Plants #1, Plant #2 and Plant #3 have been compiled and are available for review from the Safety Director. As the company bids and is awarded additional contracts with mine safety exposure, additional manuals must be prepared and training completed prior to mine entry. 36.2 MSHA Headquarters
U.S. Department of Labor Mine Safety and Health Administration 4015 Wilson Boulevard Arlington, Virginia 22203-1984 www.msha.gov (703) 235.1400
Eastern Regional Manager Educational Field Services 1301 Airport Road Beaver, West Virginia 25813-9426 (800) 678.6746
Western Regional Manager Educational Field Services P.O. Box 25367 Denver, Colorado 80225-0367 (800) 579.2647
36.3 Educational Video and Training Materials National Mine Health and Safety Academy Mary Lord 1301 Airport Road Beaver, West Virginia 25813-9426 (304) 256.3257 FAX: (304) 256.3368 [email protected]
37 Electronic Hazards on the Worksite
REV2.1 February 13, 2018 Page 139 | 165 The Elliott-Lewis Safety Manual 37.1 Cell Phones Cell phone usage is permitted on our worksites when it is limited to company business. Cell phones are not permitted when operating any type of motor vehicle. This includes but is not limited to company vans, cars, cranes, forklifts, aerial lifts and utility carts. If a cell phone call needs to be made or received, remove the vehicle from any hazardous or congested area to make the call.
37.2 Headphones Telephones, Blue Tooth, radio and IPOD earpieces/headphones, or any other device that hooks around the ear or about the head, are not permitted on any Elliott-Lewis worksite under any circumstances.
38 Aerial Lift Safety
1. Employees shall not operate an aerial lift without proper training. This training shall be completed with a qualified trainer and the employee shall carry a card verifying completion of this training. 2. No aerial lift shall be operated unless it has been designed and constructed in conformance with the applicable requirements of ANSI A92.2-1969, “Vehicle Mounted Elevating and Rotating Work Platforms”. 3. Aerial lifts may be “field modified “for uses other than those intended by the manufacturer but only provided the modification has been certified in writing by the manufacturer or an equivalent entity. 4. Lift controls shall be tested each day prior to use to determine they are in safe working condition. Tests shall be made at the beginning of each shift during which the equipment is to be used to determine that the brakes and operating systems are in proper working condition. 5. Boom and basket load limits specified by the manufacturer shall not be exceeded under any circumstances. 6. The aerial lift shall have a functioning reverse signal alarm that is audible above the surrounding noise level. In lieu of an alarm, a signalman may be used. 7. An aerial shall not be operated within 10 feet of any electrical lines. 8. Employees shall always stand firmly on the basket floor and shall not sit or stand on the edge of the basket or use planks or ladders for a work position. 9. Approved fall protection shall be worn and a lanyard attached to a designed anchor point when working from an aerial lift. 39 Mobile Equipment
39.1 General The objective of this policy is to recognize the hazards associated with the operation of heavy/mobile equipment. This policy has been developed to establish guidelines to eliminate injuries and accidents related to this type of equipment. 39.2 Scope This policy applies, but is not limited to, equipment such as cranes, boom trucks, support trucks, stake body trucks, maintenance support trucks, forklifts, scissor lifts, aerial lifts, and backhoes. 1. Only qualified and authorized employees are permitted to operate this type of mobile equipment. Training for forklift, scissor lift, and aerial lift are provided by the company. No employee is to ever use one of these vehicles without the proper training.
REV2.1 February 13, 2018 Page 140 | 165 The Elliott-Lewis Safety Manual 2. At the beginning of each shift, the operator shall inspect and check the assigned equipment, reporting immediately any malfunction of the unit to the supervisor or mechanic. A qualified employee operating any road worthy equipment weighing 10,001 lbs. or more must complete a Driver’s Vehicle Inspection Report prior to leaving for that shift and returning at the end of that shift. 3. No equipment, whether on road or off, shall be operated without the use of seat belts, if so equipped. 4. All construction equipment shall have a working backup alarm. 5. Eye protection is required at all times on all jobsites, especially while operating any equipment that may have an open cab. 6. Equipment is not to be used in any other way or for any other purpose than what was designed and intended by the manufacturer. 7. No passengers are permitted on any mobile equipment unless a proper seat with seat belt is available to accommodate. 8. Never overload any piece of equipment and ensure that all load securement rules are adhered to including balancing the load and ensuring there are at least two tie downs on each piece. 9. Smoking is not permitted anywhere near a vehicle that is being refueled. Use only designated smoking areas. a. While fueling, always ensure the engine is turned off b. While fueling, always ensure filler nozzle contact with the tank
40 Core Drilling Safety Program
40.1 Purpose Core drilling is a method of cutting circular holes in reinforced or pre-cast concrete and other structures for plumbing, heating, and air conditioning installations. The Safety Department of Elliott-Lewis Corporation has designed this safety policy to provide our employees with guidelines for ensuring the safest work environment possible during core drilling tasks. It is of the utmost importance that our technicians provide our clients with high quality, reliable, efficient and, above all else, safe and uninterrupted service. By following this formalized safety policy, the benefits will be a safer jobsite and the elimination of injuries and property damage. 40.2 Training All Elliott-Lewis employees who engage in core drilling activities will be qualified to perform the tasks assigned. A qualified employee is a person who possesses a recognized degree, certificate, or professional standing, or who by extensive knowledge, training and experience, has successfully demonstrated his/her ability to solve or resolve problems related to the work. The Superintendent shall ensure that all employees assigned to core drilling tasks are qualified. 40.3 Procedure There may be times when it is known with certainty that an area where concrete cutting or coring is being considered is free of embedded utilities. This certainty may have been reached by various means including corporate knowledge of construction of the facility, review of as-built drawings, or other means. In these cases, Elliott-Lewis Corporation Construction Management (i.e. Project Manager, Superintendent) is not required to arrange a scanning process for locating possible embedded utilities. It is sufficient for the General Contractor to certify in writing that such area is devoid of embedded utilities. This certification shall be attached to the Pre-Task Hazard Analysis. When it is not known with certainty that an area is free of embedded utilities, construction management shall secure the services of a vendor that will locate all embedded utilities in the designated work area. If the GC contracts the scanning vendor, Elliott-Lewis Corporation reserves the right to investigate and approve the REV2.1 February 13, 2018 Page 141 | 165 The Elliott-Lewis Safety Manual choice based on past history. No matter who hires the scanning company, the ELCO foreman responsible for that job shall be present during the scanning process. This will ensure that all designated areas are scanned completely and thoroughly and marked appropriately so there is no question as to where utilities are located. If any changes have occurred to the site or the scan markings have been skewed in any way, the coring shall not proceed until all questions are answered and the foreman is absolutely certain he has a safe situation. Appropriate markings include, but are not limited to, highly visible, four-sided markings, which clearly identify the safe area for the coring. 40.4 Subcontractors In most instances, Elliott-Lewis Corporation will subcontract core drilling work greater than 10” in diameter. Only preferred and pre-qualified subcontractors will be permitted to work on our job sites. The final decision on subcontractors shall be the responsibility of the Superintendent or Director of Construction. Under no circumstances are preferred subcontractors permitted to assign the work to another subcontractor without prior approval of ELCO management. This must be done well in advance of the job date and only after that contractor has been approved and pre-qualified will it be able to perform the work. The subcontractors shall ensure that all employees assigned to Elliott-Lewis jobsites shall be qualified personnel. Subcontractors shall be under the constant supervision of an Elliott-Lewis foreman at all times during the performance of the core drilling procedure. 40.5 Personal Protective Equipment Each employee involved in core drilling activities is required to wear, at a minimum, safety glasses, hard hat, sturdy work shoes, hearing protection, gloves, and proper work clothing. When drilling is done overhead a full face shield and safety glasses to protect the eyes and face are required. If it is known that embedded utilities exist in the core drilling area, we must make every effort to de-energize and lockout/tagout all known circuits. If de-energization is not possible, we must assume that an energized circuit could be cut and therefore we must consider shock and arc flash as potential hazards of the task. Therefore, it is required that the drilling employee wear arc-rated coveralls, face shield with balaclava, and electrically rated gloves as prescribed by NFPA 70E outlined in Section 16 of this manual. This arc-rated equipment is available to any employee involved in the core drilling task upon request. Electrical hazards require that additional steps be taken to protect the worker from shock or electrocution. The cutting/coring machine must be adequately grounded and have its power supplied through a GFCI, even if it is double insulated. All individuals involved in this task shall receive a job briefing by the foreman as outlined in section 41.6. 40.6 Job Hazard Analysis Prior to the start of any project that may require core drilling, the Project Manager and/or Foreman shall perform a job hazard analysis to determine what hazards exist in completing the work. This JHA has been created and provided by the Safety Department and shall be completed by a qualified Elliott-Lewis employee before every drilling process commences. If the drilling will be performed by an approved subcontractor, the JHA will be completed by the qualified Elliott-Lewis employee and shall include the subcontractor employees in the process. This will ensure that all parties involved in the process understand the hazards of the task at hand. This JHA is attached below.
REV2.1 February 13, 2018 Page 142 | 165 The Elliott-Lewis Safety Manual CORE DRILLING JOB HAZARD ANALYSIS Jobsite Name: Location On Site:
Date: Foreman: DONE BASIC JOB STEPS HAZARDS INVOLVED METHOD TO ELIMINATE HAZARDS (√) 1. Ensure safe access to Working at heights Comply with mobile elevated platform, point of operation scaffold, and ladder safety guidelines Ensure safe access and egress to both upstairs and downstairs points of operation prior to commencing work Working in congested Evaluate and protect against possible adverse areas impacts to nearby equipment and systems. Ensure operations are compatible w/drilling Cover or shield equipment and controls to prevent impacts Notify other personnel that could be impacted that the crew will be working overhead Working overhead Install DANGER/CAUTION barricades and signs to notify other personnel that hazardous work is in progress in the area and overhead Working near floor Ensure that all openings and leading edges openings and leading have appropriate protective rails, and/or edges barricades and signs When coring is completed, ensure the new hole is protected by a cover that can't be dislodged and "HOLE-DO NOT REMOVE" is written on the cover Communicating through Confirm uninterruptible communications via floors and walls either telephone or portable radio Ensure top and bottom-side crews understand essential procedures, signals, and instructions 2. Assemble equipment, Blocking aisles and Ensure all tools, equipment, and materials, are tools, and materials exits staged so as not to create a trip and slip hazard Muscle strains Much of the equipment is heavy and bulky. Use good manual materials handling practices and help each other whenever possible Finding electrical 3. Pre-planning for circuits, If scanning was done, what method was hidden utilities pipelines, etc. used?______Analyze where all utilities Are all border and utility markings for area scanned enter area and leave area clearly visible and without doubt as to their meaning?
REV2.1 February 13, 2018 Page 143 | 165 The Elliott-Lewis Safety Manual IF THERE IS ANY QUESTION, DO NOT PROCEED! Evaluate whether re-bars or structural steel members will be affected by the coring operation 4. PPE Shock and Arc Flash Ensure all employees are properly protected as the Core Drilling Program outlines in Section 41.4 5. Drilling pilot holes Using portable tools Comply with all portable power tool safety guidelines Always use ground fault circuit interrupters (GFCI), especially for wet environments 5. Drilling pilot holes Using portable tools If drilling overhead, use a full face shield and (cont'd) (cont'd) safety glasses to protect eyes and face Ensure that all potential falling debris is controlled and contained Ensure that the center point is carefully measured and double checked to avoid hidden hazards Use protective shields, covers, or shelters to cover delicate systems and controls 6. The coring operation Vibration and motion Coordinate with the building owner/manager to ensure vibrations in the operation will not impact delicate tools or systems in the area Ensure that the coring machine is firmly anchored to prevent shifting or upset Noise The drilling crew and should wear appropriate hearing protection (ear plugs or ear muffs) Water leaks Ensure that all water fittings are tight and secure Ensure that the crew has absorbent dikes, pads, sponges, mops, etc. to contain any water excess Falling debris The downstairs crew must wear hard hats, safety glasses, full face shield, and work gloves Concrete dust can contain silica. These particles may cause damage to the lungs. When appropriate, the crew should wear disposable dust masks to avoid inhalation Use a HEPA vacuum to control dust. Do not use a standard vacuum which will allow dust to spread Establish a procedure for the "catching crew" to receive the core when it is released to ensure injury or property damage does not occur Be prepared with absorbent materials for the water released when the penetration occurs Ensure that smoke detection systems are managed to prevent false alarms 7. Clean up Dust/water Ensure that all dust and water are collected and
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7. Clean up properly disposed of Floor openings Ensure that any new holes, greater than 2" in dia. are protected by a cover that cannot be displaced and can withstand twice the weight needed for that area Ensure that all tools and equipment are properly cleaned and stored in approved locations Additional Hazards Found:
Crew Member Signatures 1 4
2 5
3 6
Elliott-Lewis Competent Person Signature:
41 Heat/Cold Stress Identification
Training- Employee training is an essential element of an effective temperature extreme program. Workers and managers who are able to identify the symptoms of early heat/cold stress will be able to prevent disorders, conditions, and possible death to themselves and their fellow workers. Workers should be trained initially and continually reminded during regular safety meetings to identify the symptoms of heat and cold stress . Employee training is an essential element of an effective temperature extreme program. Workers and managers who are able to identify the symptoms of early heat/cold stress will be able to prevent disorders, conditions, and possible death to themselves and their fellow workers. Workers should be trained initially and continually reminded during regular safety meetings to identify the symptoms of heat and cold stress
1. Heat Stress- Hot conditions, whether indoor or outdoor, increase the risk of dehydration, heat stroke, heat exhaustion or other heat-related conditions for our employees. Under normal conditions, the body’s natural control mechanisms which include the skin, vascular system, and perspiration, adjust to the heat. But those systems could fail if exposed to high temperatures for extended periods of time. If these systems fail, the body’s ability to dissipate heat by sweating and regulating circulation and fluids is compromised, which could result in a serious heat-related illness due to excessive body temperature a. Disorders and their Symptoms: i. Sunburn- Pinkness or redness and skin that feels warm or hot to the touch. Pain or tenderness, swelling, small fluid blisters, headache, fever and fatigue
REV2.1 February 13, 2018 Page 145 | 165 The Elliott-Lewis Safety Manual ii. Heat Cramps- Overall cramping and muscle spasms, especially in the calf, leg, and abdominal muscles iii. Heat Exhaustion- Heavy sweating, cool8/moist skin with goose bumps when in the heat. Faintness, dizziness, fatigue, weak and rapid pulse, low blood pressure upon standing, muscle cramps, nausea, and possible headache iv. Heat Stroke- This is the most serious of all temperature related conditions since temperature regulation fails and the body temperature rises to critical levels. Failure to sweat causing dry skin, nausea, dizziness and confusion and, in extreme cases, coma b. If any employee is found to be experiencing any of these symptoms, call 911, remove them to cooler conditions and attempt to cool them down slowly with cool compresses or similar c. Employees will have access to potable drinking water. Where a drinking fountain is not available, bottled water shall be provided in sufficient quantity throughout the work shift. d. Employees suffering from heat related illness will be provided an area with shade that is open to the air or provided with ventilation or cooling. Access to shade will be permitted at all times. e. Supervisor will be trained in preventing heat related illnesses; along with recognizing the symptoms and the illnesses related to heat stresses. They will be able to identify the symptoms and understand the corrective actions need to be put into place. This training must be completed prior to supervising other employees. f. Supervisors will be trained in heat illness procedures to prevent heat illness. A supervisor will understand and know how to implement the procedures to follow when an employee exhibits symptoms consistent with possible heat illness, including emergency response procedures. i. Supervisors must ensure personal factors that contribute to heat related illness are taken into consideration before assigning a task where there is the possibility of a heat-related illness occurring. ii. Common physical factors that can compound/aid to heat related illness are type of work, level of physical activity and duration, and clothing color, weight and breathability. g. Employees will monitor the outside temperature, along with the humidity. Each employee has received a chart to determine safe work practices in specific temperatures. 2. Cold Stress- Under most conditions, your body maintains a healthy temperature. However, when exposed to cold temperatures or to a cool, damp environment for prolonged periods, your body’s control mechanisms may fail to keep your body temperature normal. Early recognition of the symptoms of cold exposure is essential in preventing serious or permanent disorders or conditions. Workers and managers involved in cold weather operations should be adequately trained to recognize the symptoms: a. Hypothermia Internal body temperature drops to less than 95 degrees F, causing uncontrollable shivering, irregular heartbeat, weakened pulse, and change in blood pressure. Slowed or slurred speech, memory lapses, incoherence, and drowsiness also may occur b. Frostbite-This occurs when there is freezing of fluids around the cells of the body tissues due to extremely low temperatures. Damage to the tissue may be serious enough to require amputation or permanent loss of movement. If any employee is found in any of these conditions, call 911 and move out of the cold. Remove any wet clothing and slowly warm them by placing warm compresses to the neck, chest wall, and groin. Don’t attempt to warm the arms and leg. This will force cold blood back to the heart, lungs, and brain, causing the core body temperature to drop. This can be fatal.
REV2.1 February 13, 2018 Page 146 | 165 The Elliott-Lewis Safety Manual 42 Pandemic Preparedness Program
42.1 Purpose This Pandemic Preparedness Plan has been developed to set priorities and choices that need to be considered to maintain essential levels of service and to ensure advanced planning and preparedness to help sustain the critical operations within the company. The Safety Director working with the Chief Operating Office, will be responsible for dealing with critical issues. 42.2 Training Employees shall have periodic training on the health issues including prevention, symptoms, means of spreading, and return to work policies. Accommodations need to be made to ensure that language challenged employees are included in the training process. 42.3 Procedures 1. A plan has been prepared for mass absenteeism to ensure the continuity of business. A communication system has been installed to provide all personnel with the means to track company business and employee status. This system includes contacts for the employees, customers, and suppliers who could be impacted by our ability or inability to provide service. Notification will be made to them when operations stop or resume. These emergency communications systems shall be tested and reviewed periodically to ensure they are up to date and workable. 2. Use of hand sanitizers, tissues, hand washing facilities, and disposable towels shall be encouraged by the company. All will be provided for by the company. 3. All areas frequently contacted such as doorknobs, faucets, and handrails, shall be frequently cleaned and disinfected. 4. Employees are encouraged to receive all appropriate immunizations. In many instances, the company already has a program to provide immunizations. 5. In the event of an outbreak, options to limit spreading shall include increasing the space between employee cubicles and work spaces and decreasing the possibility of contact by limiting large or close contact gatherings. 6. In the event of an outbreak, social distancing should be implemented to limit the spreading. Where possible, work-at-home situations will be developed to limit the spread of disease.
43 Radio Frequency Safety
43.1 Purpose An RF Safety Program is the key to establishing and maintaining an environment that ensures the personal protection of all our employees. Risk assessment is an integral part of the program to determine if the hazards exist and to what degree they exist. Because our work normally does not expose our employees to dangerous levels of RF radiation, a program such as this is not required. However, Elliott-Lewis Corporation wishes to ensure that our employees are aware that these hazards exist in the workplace and, because of this program, will be capable of identifying the hazards if they are encountered in the field. 43.2 Training Field technicians and mechanics who could be exposed to radio frequency radiation shall be trained periodically to identify the hazards, the equipment and PPE available to ensure their safety in the field.
REV2.1 February 13, 2018 Page 147 | 165 The Elliott-Lewis Safety Manual 43.3 Ionizing vs. Non-Ionizing Radiation “Ionization” is a process by which electrons are stripped from atoms and molecules. This process can lead to damage in biological tissue, including effects on DNA, the genetic material of living organisms. This process requires interaction with very high levels of electromagnetic energy that occur in processes such as x-rays, gamma rays, and nuclear power generation. However, the most important use for RF energy is in providing telecommunications services such as radio and television broadcasting, cellular telephones, pagers, cordless telephones, business radio, radio communications for police and fire departments, microwave point-to-point links and satellite communications. The energy levels associated with RF from these devices, on the other hand, are not great enough to cause the ionization of atoms and molecules, and RF energy in these communication devices is, therefore, a type of non-ionizing radiation. 43.4 Health Effects There can be inherent effects from RF energy. Biological effects that result from heating of tissue by RF energy are often referred to as “thermal” effects. This is the principle by which microwave ovens cook food. Exposure to certain RF intensities can result in heating tissue and an increase in body temperature. Two area of the body, the eyes and the testes, are particularly vulnerable because of their inability to cope with or dissipate the excessive heat that can be generated. 43.5 RF Energy Levels The quantity used to measure the rate at which RF energy is actually absorbed in the body is called “Specific Absorption Rate” (SAR). It is usually expressed in watts per kilogram (W/kg). In the case of exposure to the whole body, a standing ungrounded human adult absorbs RF energy at a maximum rate when the frequency of the RF radiation is in the range of 30-300 MHz and appears to be the most harmful to the body. Cellphone antennas that we are most likely to encounter operate in the range of 850-1900 MHz where the SAR levels are not harmful as long as long as we stay out of the line of the emitting frequencies.
43.6 Identify Antennas and Emission Patterns Before you start work, look for antennas and their relationship to your work space. Stay safe by assuming that all antennas are active. 1. Rectangular-shaped antennas emit RF in a single direction straight out from the antenna. 2. Cylindrical/rod–shaped antennas emit RF all the way around 360 degrees 3. Parabolic/dish-shaped antennas deliver RF in a pattern similar to a spotlight beam 4. Stealth antennas are made to blend into the building-scape 43.7 Safe Distances Stay at least six (6) feet away from a single antenna that’s emitting RF in your direction. Stay at least 10 feet away from two (2) or more antennas emitting RF in your direction. RF dissipates considerably, losing its potency the further it travels away from the antenna. The further you’re away from an RF source, the less risk of overexposure. Limit the amount of time you walk through or work in an RF field. Look for warning signs and labels on the building and equipment. They should show an electromagnetic radiation symbol and somehow indicate that the area may be restricted. 43.8 Protective Clothing and Equipment 1. RF protective clothing is made of Nomex and is partial steel fibers. To protect the employee, this clothing must adequately address the following characteristics: 2. Material Breakdown Threshold must be well in excess of the RF induced heating experienced during the intended use of the protective clothing
REV2.1 February 13, 2018 Page 148 | 165 The Elliott-Lewis Safety Manual 3. Surface Temperature Stability data must ensure that the fabric dissipates RF induced heating sufficiently so that its surface temperature does not become excessive to the wearer within the field intensities of intended use 4. Specific Absorption Rate must be reduced by the clothing sufficiently based on the specific conditions that exist 5. Maintainability and Worker Acceptance requires the clothing be able to withstand treatment comparable to standard-issue industry work clothes and construction of the clothing should minimize restriction of the wearer’s movements and vision 6. To provide full-body protection, components of the RF protective gear must include a full integrated hood, overshoes, and gloves. The Safety Department shall determine the necessary protective clothing to provide adequate protection based on the intended worse case field exposures
44 Ammonia Refrigeration
44.1 Purpose All field employees who may use and may be affected by the presence of ammonia refrigerant on a jobsite shall attend awareness training before initial assignment with ammonia refrigerant systems and annual refresher training thereafter. Employees will be instructed on the specific hazards, hazard identifiers, mitigation techniques, and continuous air monitoring. 44.2 Scope This procedure will cover any employee(s) working with or around refrigeration systems containing ammonia.
44.3 Definitions Ammonia is a chemical consisting of one atom of nitrogen and three atoms of hydrogen. It is designated in chemical notation as NH3. Ammonia is extremely soluble in water and is frequently used as a water solution called aqua ammonia. Ammonia chemically combines with water to form ammonium hydroxide. Household ammonia is a diluted water solution containing 5 to 10 percent ammonia. On the other hand, anhydrous ammonia is essentially pure (over 99 percent). "Anhydrous" is a Greek word meaning "without water", therefore, anhydrous ammonia is ammonia without water. Ammonia Refrigerant grade R-717, is a chemical combination of nitrogen and hydrogen. This is a clear liquid that boils at a temperature of -28°F, and contains very little water. It is at least 99.95 percent pure ammonia. In refrigeration systems, the liquid is stored in closed containers under pressure. When the pressure is released, the liquid evaporates rapidly, generally forming an invisible vapor or gas. 44.4 Health Effects Ammonia, even in small concentrations in the air, can be extremely irritating to the eyes, throat, and breathing passages. Repeated exposure to ammonia can cause chronic effects on the human body such as cough, asthma, and brinchial issues. Anhydrous ammonia primarily affects three areas of the body: eyes, lungs and skin. 1. Eyes- Everything from mild irritation to destruction of the eye can occur depending on whether a spray or gas is involved. Ammonia penetrates the eye more rapidly than other alkalis 2. Lungs- In the lungs, liquid anhydrous ammonia causes destruction of delicate respiratory tissue. Exposure to ammonia vapor may cause: a. Convulsive coughing. REV2.1 February 13, 2018 Page 149 | 165 The Elliott-Lewis Safety Manual b. Difficult or painful breathing. c. Pulmonary congestion. d. Death. 3. Skin- Skin damage depends upon the length and concentration of exposure and can range from mild irritation, to a darkened freeze-dry burn, to tissue destruction. Because liquid ammonia boils at -28°F, the expanding gas has the potential to freeze anything in its path of release, including human flesh and organs. Because water can absorb ammonia so readily, it is a factor that contributes to human toxicity. Ammonia will keep spreading across contacted skin until the chemical is diluted by skin moisture. As a result, anhydrous ammonia burns keep spreading until the chemical is diluted. In addition to liquidation, super-cooled anhydrous ammonia spray causes a freeze dry effect like frost bite when it hits the skin. The spray is also capable of freezing clothing to skin so that if the clothing is removed incorrectly whole sections of skin can be torn off. 44.5 Personnel Protective Equipment (PPE) When working with or around ammonia, employees must take the precaution to protect themselves from exposure from the liquid form and gaseous state. This list contains the requirements for PPE: 1. Eye-Ventilated, splash proof goggles will provide adequate protection in most instances. In addition, where splashing may occur, wear a full-face shield to protect the face. 2. Skin and Body Protection- Gloves that are impervious to ammonia such as neoprene gloves are recommended. During clean-up operations or when ammonia may still be present in the system, an ammonia-impervious suit or pants and jacket, and shoe covers. If impervious clothing is not available, wear cotton, which is the preferred fabric for work clothing because it is more alkali resistant than wool. Clothes, especially gloves, should also be insulated to prevent freezing of the skin. 3. Lungs- Depending on the task in the ammonia refrigeration process, a self-contained breathing apparatus may be required or the task may be required to be completed while working with a fresh air breathing system. a. This would require additional medical clearances before being used. Completion and review by a doctor of the OSHA Medical Qualification Survey, spirometry test, and fit-tested for the appropriate respirator. Annual fit tests are required thereafter. b. Additional training is required for the use and “donning and doffing” of both half-face respirators and full-face respirators. 44.6 Pre-job set up 1. Prior to entering the host facility, employees must become a member of the Refrigerating Engineers and Technicians Association (RETA). Once a membership has been obtained, the employee must receive a certification as a Certified Industrial Refrigeration Operator (CIRO). Employees must also attend the HAZWOPER 40-hour course. 2. All personnel are to be trained on the dangers associated with ammonia, including early exposure detection techniques. a. If crew members have not received training on the hazards and identifications/detection techniques, they cannot be present for the duration of the project. 3. All host facility SOP, policies, and processes must be adhered to in regards to ammonia process piping. 4. Notify facility personnel of the operation to be performed and verify the continuity of the modifications to their system a. Plant personnel affected by the cut-ins should be notified. b. If the system is to be open over several shifts, all affected shifts must be notified. c. If the system is being opened to install new equipment, the new equipment should be installed prior to the cut-in, if possible. 5. Test all Personnel Protective Equipment (PPE) that may be used during the cut-in. All PPE should be tested per manufacturers’ recommendations. REV2.1 February 13, 2018 Page 150 | 165 The Elliott-Lewis Safety Manual 6. Those individuals making the cut-in, or assisting in the cut-in, should be familiar with the operation and maintenance manuals of the equipment to be used. 7. It is essential that piping and fittings are suitable to be used with ammonia refrigeration. 44.7 System Piping Isolation 1. Consult the system documentation for isolation points. Field verify that all affected piping matches the documentation. 2. Do not attempt to isolate any part of the system until the isolation points and associated piping have been field verified and the shut down process completed. 3. Instruct all personnel involved in the isolation procedure. a. Do not attempt to isolate the equipment without consent of the host client. 4. While isolating the system, personal protective equipment is required at all times due to the potential for a leak to occur. 5. Remove liquid ammonia from the system section. 6. Once the system section is pumped out, hold the section in a vacuum sate to ensure all isolation valves are correctly sealed. a. If liquid ammonia is still present in the system, an alternate isolation point shall be used b. All liquid ammonia shall be removed from the piping prior to cutting/line breaking. 7. Dry nitrogen shall be used to purge the ammonia vapors from the piping system. a. Inert gases such as nitrogen can pose asphyxiation hazards by creating an oxygen deficiency in the worker’s breathing zone. This hazard where these gases are being used and all affected personnel shall be trained as to the hazards associated with their use 8. Shut off valves to isolate the section of the system that will be worked on. a. Do not isolate section of piping still contain liquid. i. Hydrostatic lock may occur. ii. A rapid release of ammonia vapors may occur if liquid still present. 9. Apply lockout device and follow company policy from section 17.5 44.8 Line Opening 1. Verify all isolation devices and methods are in place (Closed valves, blanks, double block & bleed, etc.) a. Careful consideration must be given to all connecting paths in the process piping and equipment. b. Verify that all energy sources are properly locked and tagged out. Ensure all employees involved have placed a personal lock out lock on the system. 2. Zero energy verification. 3. Verification of no atmospheric hazard (Includes both inside and outside piping system). a. Appropriate monitor available (calibrated & bump tested) 4. Ensure all Personal Protective Equipment is in place a. Valves may not always close or seal well 5. Fire Protection requirements a. Grounding and Bonding - Consult customer representative for specific instructions on grounding and/or bonding of materials to prevent static ignition sources around flammable gas or liquids. 6. Tool Requirements a. If potential exists for flammable gas or liquids to be present or released around the line break area, the customer must be consulted to provide specific instructions regarding the acceptable tools (brass, air, etc.) that must be used to prevent a hazardous condition. 44.9 Hot Work 1. Prior to beginning hot work, verify system is not in a vacuum or under pressure.
REV2.1 February 13, 2018 Page 151 | 165 The Elliott-Lewis Safety Manual a. If the system is opened under a vacuum, the oxygen in the air will mix with the ammonia creating a potentially explosive atmosphere. 2. Verify with client of a hot work permit process. a. Follow all client permitting processes for hot work. b. Follow section 13 Welding and Burning Safety of this manual for Hot Work procedures. If the host client has more stringent policies for Hot Work, they will supersede Elliott-Lewis procedures. c. Any concerns or additional precautions outlined in the Hot Work Permit must be addressed prior to commencement of hot work 3. Position fans to blow air away from the person welding or cutting. a. Position the fans as to not blow in the directions of other unaware employees 4. Refer to Section 13 for more details pertaining to Welding and Burning.
45 Working alone
45.1 Purpose To ensure that personnel who are required to perform work alone at facilities and job locations are able to secure competent assistance that is readily available in the event of an illness, injury or emergency. To control work using a written requirement that establishes and communicates the precautions necessary for safe working alone. 45.2 Requirements A risk assessment shall be conducted to evaluate the risk of working alone and to determine the appropriate control measures. The division manager is accountable for the requirements below and shall establish and maintain work procedures that meet the following requirements: 1. When performing any work beyond Low Risk and on any part of the facility, an individual must be accompanied by support person(s) qualified and authorized to provide emergency response, first-aid and rescue at that work environment. 2. A lone worker must have two forms of communication at all times (i.e. mobile phone, two-way radio or electronic monitoring device) 3. Communication protocol must be established to identify a check-in/check-out process where employees are being monitored or communicated with at regular intervals. 4. An individual (point of contact) will be designated as the person responsible for establishing and maintaining contact with the lone worker utilizing the agreed communication protocol. 5. Emergency Response procedures shall be established and communicated between the lone worker and the point of contact prior to anyone working alone. a. If an employee does not respond when contacted, that employee’s other contact method will be tried. If the employee still is not located, a supervisor will be sent to find this employee. In the case that they still can not be located, the local authorities will be contacted and given the information on the situation. 6. A hazard assessment (JSA) will be completed prior to beginning work. This will address hazards and identify control measures in order to minimize risk associated with working alone. 45.3 Situations covered by this policy Covered
REV2.1 February 13, 2018 Page 152 | 165 The Elliott-Lewis Safety Manual 1. Any work at height from which workers are exposed to a fall hazard of four feet or more from where they stand or sit to perform work. This includes potential falls to a lower level. 2. Any work being performed where there is a risk of a hazard(s) being released at the facility
46 Hearing Conservation 46.1 Purpose The purpose of this program is to help affected employees avoid work-related hearing loss. Elliott-Lewis has established and implements engineering and/or administrative controls to reduce noise levels to acceptable levels whenever it is feasible to do so. When engineering and/or administrative controls are infeasible or inadequate to reduce noise levels below the applicable action level shown below, Elliott-Lewis requires all affected workers to participate in, and fully comply with, this hearing conservation program. The program includes noise sampling, audiometric testing, hearing protection equipment, training, and other protective measures to help affected workers safeguard their hearing. 46.2 Definitions Action Level – The level of noise exposure at which an affected worker must participate in our Hearing Conservation Program. The action level for mechanical construction applications is 90 dBA over an 8-hour Time Weighted Average (TWA). The action level for mechanical service and fabrication applications is 85 dBA over an 8-hour TWA. Decibel (dB) – The standard unit used to measure sound levels. The A-weighted decibel scale, abbreviated as dBA, is used to measure sounds received by the human ear. Hertz (Hz) – The unit of measure for noise frequency in cycles per second – (1 cycle/second = 1 Hz) Permissible Exposure Limit (PEL) – The maximum permissible noise exposure established by OSHA. The current PEL for mechanical construction, service, and fabrication shops is 90 dBA over an 8-hour TWA. Noise Reduction Rating (NRR) – The anticipated measure of noise reduction that hearing protection equipment/devices provide. Standard Threshold Shift (STS) – A change in hearing threshold relative to the baseline audiogram of an average of 10 dBA or more at 2,000; 3,000; and 4,000 Hz in either ear.
46.3 Action Levels for Mechanical Construction, Service and Fabrication Shops
Action Level for Duration Per Day Sound Level (in Hours) (dBA Slow Response)
Mechanical Construction 8 90 Mechanical Service and 8 85 Fabrication Shops
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Duration Per Day (in Hours) Sound Level (dBA Slow Response) 8 90 6 92 4 95 3 97 2 100 1 1/2 102 1 105 1/2 110 1/4 or less 115
46.4 Workplace Noise Sampling 1. Noise Level Sampling- Noise level sampling will be performed whenever applicable by third party contractor specializing in noise sampling. The area and/or personal noise level sampling is performed in a manner that accurately identifies our employees who may be subject to work-related hearing loss without participation in the hearing conservation program. When sampling results determine that affected workers could be exposed to noise levels that exceed the applicable action level, this hearing conservation program becomes effective immediately for all affected workers. 2. Documentation- The results of all noise level sampling are documented by a third party contractor specializing in noise sampling. This documentation will be reviewed to show the data from the test. 3. Monitoring Results Meetings a. A representative from the safety department and the employee’s immediate supervisor will be responsible for informing affected workers about the results of all applicable noise sampling. The verbal reports to affected workers are presented in informal face-to-face meetings so that affected workers can get answers to their questions about the results, and a better understanding of the hearing conservation program. b. The safety department will be responsible for documenting the proceedings of each meeting, and making copies of the previously documented sampling results accessible to affected workers and their authorized representatives upon request. This information will be stored in the employees personnel file. 46.7 Audiometric Testing 1. If an employee is exposed to noise levels at or above the applicable action level, that worker will receive audiometric testing. A third party contractor specializing in audiograms will perform the testing. 2. Baseline Audiometric Test-The initial baseline test, which provides an initial endurance level for each ear, and a reference point for future audiometric testing, will be performed within six (6) months of each affected worker’s first exposure at or above 85 dBA. Subsequent Audiometric Testing are performed annually after the initial.
REV2.1 February 13, 2018 Page 154 | 165 The Elliott-Lewis Safety Manual 46.8 Hearing Protection and Follow-Up for Workers with Hearing Loss 1. Hearing Threshold Shift-If a comparison between an affected worker’s baseline and annual audiograms indicates a standard threshold shift, the affected worker will be informed in writing within 21 days from the date of discovery. 2. Re-evaluation-If a worker experiences a standard threshold shift, the following items will be reevaluated by a third party contractor specializing in audiograms will perform the testing. Any appropriate changes to the hearing protection practices and/or procedures will be made and implemented immediately. Situations where the re-evaluation will be needed: a. Type or types of hearing protection used by the worker; b. Whether the hearing protection that was selected/used requires refitting; c. Whether the hearing protection selected was being used properly; d. Whether additional hearing protection training is needed; and e. Whether a medical evaluation of the affected worker is needed. 3. If one or more of the re-evaluated items requires action to help protect the affected worker from additional hearing loss, those items will be addressed immediately. 4. Noise Reduction Rating (NRR) - This program uses the hearing protection equipment rating from the manufacturers’ NRRs to evaluate hearing protection equipment attenuation and effectiveness. 5. Types of ear protection a. Inserts (Earplugs) – Molded and Foam – The NRR range for inserts/earplugs is generally between 25 dB to 33 dB when used correctly. b. Canal Cap Protectors – The NRR range is generally between 17 dB and 25 dB when used correctly. c. Earmuffs – The NRR is generally between 22 dB and 29 dB when used correctly. 6. Hearing Protection Equipment- The safety department makes a variety of hearing protection equipment available to all affected workers at no cost to them. Affected workers select their hearing protection equipment after receiving training on the types of equipment that are available to them. The applicable Noise Reduction Ratings (NRR), information on what types of equipment work best and recommended with regard to each of their specific work applications. The pros and cons of each different type of hearing protection equipment that has been made available to them must be evaluated to determine the effectiveness of the protection. 46.9 Training and Information All affected employees receive initial and annual training on the hazards of excessive noise exposure and appropriate methods and procedures to help prevent work-related hearing loss. In addition to the initial and annual training sessions, if any supervisor determines that an affected employee is failing to comply with hearing protection requirements, the employee will receive re-training as soon as practical following determination. As part of all training sessions, each affected worker receives a copy of this hearing conservation program. Each training session addresses the following topics.
1. How the human ear works; 2. How excessive intermittent and continuous noise can affect human hearing initially, and over time; 3. When and where hearing protection is required; 4. Proper selection of hearing protection equipment based on specific work tasks and noise exposures; 5. Proper fitting of each type or types of hearing protection equipment selected; 6. Proper use of each type or types of hearing protection equipment selected; 7. Proper care of each type or types of hearing protection equipment selected;
REV2.1 February 13, 2018 Page 155 | 165 The Elliott-Lewis Safety Manual 8. The hearing conservation program, including information about area and personal noise level monitoring, audiometric testing, baseline and annual audiogram comparisons, and hearing threshold shifts. 9. Training Methods-The training is presented to all employees. The methods of training may include video presentations, PPT presentation, demonstrations and/or group discussions.
REV2.1 February 13, 2018 Page 156 | 165 The Elliott-Lewis Safety Manual Appendix Table 1: Specified Exposure Control Methods When Working with Materials Containing Silica Equipment / Task Engineering and Work Practice Required Respiratory Control Methods Protection and Minimum Assigned Protection Factor (APF)
≤ 4 hours > 4 hours /shift /shift (I) Stationary masonry Use saw equipped with integrated water None None saws delivery system that continuously feeds water to the blade.
Operate and maintain tool in accordance with manufacturer’s instructions to minimize dust emissions.
(ii) Handheld power Use saw equipped with integrated water saws (any blade delivery system that continuously feeds diameter) water to the blade.
Operate and maintain tool in accordance
with manufacturer’s instructions to
minimize dust emissions.
None APF 10
− When used outdoors. APF 10 APF 10 − When used indoors or in an enclosed area.
(iii) Handheld power For tasks performed outdoors only: saws for cutting fiber- None None cement board (with Use saw equipped with commercially blade diameter of 8 available dust collection system. inches or less) Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions.
Dust collector must provide the air flow recommended by the tool manufacturer, or greater, and have a filter with 99% or greater efficiency.
REV2.1 February 13, 2018 Page 157 | 165 The Elliott-Lewis Safety Manual
Equipment / Task Engineering and Work Practice Required Respiratory Control Methods Protection and Minimum Assigned Protection Factor (APF) ≤ 4 hours > 4 hours /shift /shift (iv) Walk-behind saws Use saw equipped with integrated water delivery system that continuously feeds water to the blade.
Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions. None None − When used outdoors. APF 10 APF 10 − When used indoors or in an enclosed area. (v) Drivable saws For tasks performed outdoors only: None None Use saw equipped with integrated water delivery system that continuously feeds water to the blade.
Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions. (vi) Rig-mounted core Use tool equipped with integrated water None None saws or drills delivery system that supplies water to cutting surface.
Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions. (vii) Dowel drilling rigs For tasks performed outdoors only: for concrete Use shroud around drill bit with a dust APF 10 APF 10 collection system. Dust collector must have a filter with 99% or greater efficiency and a filter-cleaning mechanism.
Use a HEPA-filtered vacuum when cleaning holes.
REV2.1 February 13, 2018 Page 158 | 165 The Elliott-Lewis Safety Manual
Equipment / Task Engineering and Work Required Respiratory Protection and Practice Control Minimum Assigned Protection Factor Methods (APF)
≤ 4 hours > 4 hours /shift /shift (viii) Handheld and Use drill equipped with stand-mounted drills commercially available shroud or None None (including impact cowling with dust collection system. and rotary hammer drills) Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions.
Dust collector must provide the air flow recommended by the tool manufacturer, or greater, and have a filter with 99% or greater efficiency and a filter-cleaning mechanism.
Use a HEPA-filtered vacuum when (ix) Vehicle-mounted Use dust collection system with close None None drilling rigs for rock capture hood or shroud around drill bit with and concrete a low-flow water spray to wet the dust at the discharge point from the dust collector.
OR
Operate from within an enclosed cab None None and use water for dust suppression on drill bit.
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Equipment / Task Engineering and Work Practice Required Respiratory Protection Control Methods and Minimum Assigned Protection Factor (APF) ≤ 4 hours > 4 hours /shift /shift (x) Jackhammers and Use tool with water delivery system that handheld powered supplies a continuous stream or spray of chipping tools water at the point of impact.
− When used outdoors. None APF 10
− When used indoors or in an enclosed APF 10 APF 10 area.
OR
Use tool equipped with commercially available shroud and dust collection system.
Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions.
Dust collector must provide the air flow
recommended by the tool manufacturer, or
greater and have a filter with 99% or greater (xi) Handheld grinders Use grinder equipped with commercially APF 10 APF 25 for mortar removal (i.e., available shroud and dust collection system. tuck-pointing)
Operate and maintain tool in accordance
with manufacturer's instructions to minimize dust emissions.
Dust collector must provide 25 cubic feet per minute (cfm) or greater of airflow per inch of wheel diameter and have a filter with 99%
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Equipment / Task Engineering and Work Practice Required Respiratory Control Methods Protection and Minimum Assigned Protection Factor (APF) ≤ 4 hours > 4 hours /shift /shift (xii) Handheld grinders For tasks performed outdoors only: for uses other than mortar removal Use grinder equipped with integrated water delivery system that continuously feeds water None None to the grinding surface.
Operate and maintain tool in accordance with manufacturer’s instructions to minimize dust emissions.
OR Use grinder equipped with commercially available shroud and dust collection system.
Operate and maintain tool in accordance with manufacturer's instructions to
minimize dust emissions.
Dust collector must provide 25 cubic feet per minute (cfm) or greater of airflow per inch of wheel diameter and have a filter with 99% or greater efficiency and a cyclonic pre- separator or filter-cleaning mechanism.
None None − When used outdoors.
When used indoors or in an enclosed area. None APF 10
REV2.1 February 13, 2018 Page 161 | 165 The Elliott-Lewis Safety Manual Equipment / Task Engineering and Work Practice Required Respiratory Control Methods Protection and Minimum Assigned Protection Factor (APF) ≤ 4 hours > 4 hours /shift /shift (xiii) Walk-behind Use machine equipped with integrated None None milling machines and water delivery system that continuously floor grinders feeds water to the cutting surface.
Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions.
OR
Use machine equipped with dust collection system recommended by the manufacturer. None None
Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions.
Dust collector must provide the air flow recommended by the manufacturer, or greater, and have a filter with 99% or greater efficiency and a filter-cleaning mechanism.
When used indoors or in an enclosed area, use a HEPA-filtered vacuum to remove loose dust in between passes. (xiv) Small drivable Use a machine equipped with supplemental None None milling machines (less water sprays designed to suppress dust. than half-lane) Water must be combined with a surfactant.
Operate and maintain machine to minimize dust emissions.
REV2.1 February 13, 2018 Page 162 | 165 The Elliott-Lewis Safety Manual Equipment / Task Engineering and Work Practice Required Respiratory Control Methods Protection and Minimum Assigned Protection Factor (APF) ≤ 4 hours > 4 hours /shift /shift (xv) Large drivable For cuts of any depth on asphalt only: milling machines (half- lane and larger) Use machine equipped with exhaust ventilation on drum enclosure and None None supplemental water sprays designed to suppress dust.
Operate and maintain machine to minimize dust emissions.
For cuts of four inches in depth or less on
any substrate:
Use machine equipped with exhaust ventilation on drum enclosure and None None supplemental water sprays designed to
suppress dust.
Operate and maintain machine to minimize
dust emissions.
OR
Use a machine equipped with supplemental None None water spray designed to suppress dust. Water must be combined with a surfactant.
Operate and maintain machine to minimize dust emissions.
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Equipment / Task Engineering and Work Practice Required Respiratory Control Methods Protection and Minimum Assigned Protection Factor (APF) ≤ 4 hours > 4 hours /shift /shift (xvi) Crushing Use equipment designed to deliver water spray None None machines or mist for dust suppression at crusher and other points where dust is generated (e.g., hoppers, conveyers, sieves/sizing or vibrating components, and discharge points).
Operate and maintain machine in accordance with manufacturer’s instructions to minimize dust emissions.
Use a ventilated booth that provides fresh, climate-controlled air to the operator, or a remote control station. (xvii) Heavy Operate equipment from within an enclosed None None equipment and utility cab. vehicles used to abrade or When employees outside of the cab are engaged None None fracture silica- in the task, apply water and/or dust containing materials suppressants as necessary to minimize dust (e.g., hoe-ramming, emissions. rock ripping) or used during demolition activities involving silica-containing materials (xviii) Heavy Apply water and/or dust suppressants as None None equipment and utility necessary to minimize dust emissions. vehicles for tasks such as grading and OR excavating but not including: When the equipment operator is the only None None demolishing, abrading, employee engaged in the task, operate or fracturing silica- equipment from within an enclosed cab. containing materials
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