Employee Safety Manual

ASGCO MANUFACTURING INC. SAFETY MANUAL TABLE OF CONTENTS

Section 1 Introduction Section 2 Bloodborne Pathogens Section 3 Chemical Safety – Hazard Communications Section 4 Compressed Gas Cylinder Storage and Handling Section 5 Confined Space/Permit Required Confined Space Section 6 Continual Monitoring and Improvement Section 7 Conveyor Safety Section 8 Driver and Vehicle Safety Section 9 Electrical Safety Section 10 Fire Extinguishers Section 11 General Safety Section 12 Hoisting and Rigging Section 13 Industrial Trucks/Forklifts Section 14 Ladders Section 15 Machine Guarding Section 16 Office Safety Section 17 On-site Safety Section 18 Overhead Cranes Section 19 Personal Protective Equipment Section 20 Power Tools Section 21 Respiratory Protection Program Section 22 Safety Training Section 23 Urethane Blade Pouring Process Section 24 Welding and Cutting Section 25 Workers Compensation Section 26 Fabrication Shop Safety Section 27 Service Shop Area Safety Section 28 Agreement to Participate 2

SECTION 1 ASGCO MANUFACTURING SAFETY MANUAL INTRODUCTION

A. PURPOSE The purpose of risk management is to assure that ASGCO Manufacturing delivers services and products in an environment and in a manner conducive to the safety of all employees and customers. The program seeks to: 1) Reduce the possibility of personal injury from accidents, natural disasters or negligence. 2) Reduce the possibility and severity of property losses due to fire, theft or natural disasters. 3) Protect the financial resources and reputation of the Company from liability and adverse publicity. 4) To ensure that all employees are qualified, trained and educated to do the job safely at all times.

B. AUTHORITY AND ORGANIZATION Every Employee is responsible for his/her safety as well as the safety of fellow employees. All hazards or unsafe activities should be reported to your immediate supervisor and/or the Safety Director. All employees will participate in ASGCO’s safety program by following the our policies and procedures; by identifying and reporting safety concerns and environmental hazards, and by affirming, as part of their duties, the accurate and timely reporting of all incidents and near misses. Employees are required to follow all of the safe work practices and procedures that ASGCO has addressed.

The Safety Director is responsible for the development, implementation and maintenance of the Company’s risk management program.

The purpose of the Health and Safety Committee is to ensure that the company’s physical structure, emergency equipment, contractors or manufacturing equipment, vehicles, utilities, and mechanical equipment are properly maintained and promote the safety of all employees, customers and visitors.

Representatives of the Health and Safety Committee will inspect the facility and operations of ASGCO on a prescheduled basis to identify activities or procedures which may lead to adverse incidents. This inspection process will be used on a routine bases as will as for new process, new equipment, changes in operations or changes in products. Members of the safety committee whose responsibility it is to conduct inspections will be trained in the process as well as trained in hazard identification and proper use and care of PPE, so that these categories can be included in the inspection process. The Health and Safety Committee will review previous incidents to establish existing trends as well as individual occurrences to determine the severity and requirement for immediate corrective action.

When a new process, new piece of equipment, change in operations or a change in product occurs, the Safety Director will inform the Safety Committee. The committee will then review the process or equipment to be certain that no new hazards are created by the new process or equipment.

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The Health and Safety Committee will meet monthly and will include representative of employees and management from each department within the ASGCO.

C. REVIEW AND EVALUATION ASGCO’s program will be evaluated annually by the Health and Safety Committee to determine its effectiveness in the reduction of adverse incidents. The company Safety Director will update the policies and procedures as needed.

A copy of the manual will be readily available for review by all employees as well as all customers. Each job box will contain a copy of the manual so that ASGCO’s policies and procedures are available at each job site.

D. ACCOUNTABILITY FOR SAFETY Everyone is accountable for safety. Management, the Safety Director, and/or the Safety Committee will establish safety objectives and develop and direct accident prevention activities. All employees should strive to reach those objectives and will be evaluated accordingly. All managers and supervisors annual review will include safety (results to objectives in their area and companywide) as well as an audit of their performance of their safety responsibilities. All employees salary reviews will be affected by the company’s safety performance record. Appraisals, which include safety records, will also be performed on all employees seeking a promotion or raise.

E. AGREEMENT TO PARTICIPATE Every employer is required to provide a safe and healthful workplace. ASGCO Manufacturing is committed to fulfilling this requirement. A safe and healthful workplace is one of our highest priorities.

The information in this manual constitutes a written injury and illness prevention program. While we cannot anticipate every workplace hazard, the following principals should guide your conduct. To be safe, you must never stop being safety conscious.

Study the guidelines contained in this manual. Discuss the workplace situation with your supervisor. Attend all company sponsored training and safety meetings. Read all posters and warnings. Listen to instructions carefully. Follow the Code of Safe Work Place Practices contained herein. Participate in accident investigations as required. Accept responsibility for the safety of others. Maintain all required documentation.

By signing the acknowledgement to participate, each employee promises to read and implement this injury and illness prevention program. If you don’t understand any policy, please ask your foreman, manager, or Safety Director.

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SECTION 2 BLOODBORNE PATHOGENS

A. POLICY ASGCO Manufacturing is committed to providing a safe and healthful work environment for our employees. In pursuit of this goal, the following exposure control plan (ECP) is provided to eliminate or minimize occupational exposure to bloodborne pathogens in accordance with OSHA standard CFR 1910.1030. The ECP is a key document to assist us in implementing and ensuring compliance with the standard, thereby protecting our employees. This ECP includes: • Determination of employee exposure • Implementation of various methods of exposure control • Post exposure evaluation & follow-up • Procedures for evaluation • Recordkeeping • Vaccine Declination

B. PROGRAM ADMINISTRATION The Safety Director will maintain, review, and update the ECP at least annually, and whenever necessary to include new or modified tasks and procedures.

The Safety Director will be responsible for training, documentation of training, and making the written ECP available to employees, OSHA and NIOSH representatives. The appointed person will also determine employee exposures.

None of our employees are determined to have an occupational exposure to blood or other potentially infectious materials on a daily bases. Maintenance Foreman, Fab Supervisor and Lightweight Supervisor may be exposed on a rare occasion, these personnel are trained as to ASGCO procedures for handling an event and are expected to provide emergency care. But in the event of an employee is exposed they must comply with the procedures and work practices outlined in this chapter.

The company will provide and maintain all necessary personal protective equipment, engineering controls, labels and red bags as required by this standard. Bloodborne Pathogens kits are in the Service(Maintenance Personnel), Fab Shop(Supervisor) and Lightweight Divisions(Supervisor) of our company. We will ensue that adequate supplied of the aforementioned equipment are available in the appropriate sizes.

C. METHODS OF IMPLEMENTATION AND CONTROL 1. Universal precautions All employees will utilize universal precautions. Under Universal Precautions all patients are considered to be possible carriers of blood-borne pathogens.

2. Exposure Control Plan Employees covered by the bloodborne pathogens standard receive an explanation of this ECP during their initial training session. It will also be reviewed in their annual refresher

5 training. All employees can review this plan at any time, by contacting the Safety director. If requested, we will provide an employee with a copy of the ECP free of charge and within 15 days of the request

3. Engineering Controls Engineering controls and work practice controls will be used to prevent or minimize exposure to bloodborne pathogens. Hand washing stations, throughout the facility are equipped with antiseptic soap and antiseptic towelettes are available from the tool room. The specific engineering controls and work practices used are: • In the event of a situation where there is exposure to human blood or bodily fluids. Local Emergency Personnel should take the lead in any necessary clean up. If red bags are used then emergency personnel will be responsible for disposal.

This facility will identify the need for changes in engineering controls and work practices through the review of OSHA records, employee interviews and committee activities. We will evaluate new procedures and new products on regular bases. Both front line workers and management officials are involved in this process.

4. Personal Protective Equipment PPE is provided to our employees at no cost to them. ASGCO’s exposure determination was made without the regard to the use of PPE. Training in the use of the appropriate PPE for specific tasks or procedures is provided by the company. All employees using PPE must observe the following precautions: • Wash hands immediately or as soon as feasible after removing gloves or other PPE. • Remove PPE after it becomes contaminated and before leaving the work area. • Used PPE may be disposed of in the appropriate manner • Wear appropriate gloves when it is reasonably anticipated that there may be hand contact with blood or OPIM, and when handling or touching contaminated items or surfaces; replace gloves if torn, punctures or contaminated, or if there ability to function as a barrier is compromised. • Utility gloves may be decontaminated for reuse if their integrity is not compromised; discard utility gloves if they show signs of cracking, peeling, tearing, puncturing or deterioration. • Never wash or decontaminate disposable gloves for reuse • Wear appropriate face and eye protection when splashes, sprays, spatters or droplets of blood or OPIM pose a hazard to the eye, nose or mouth • Remove immediately or as soon as feasible any garment contaminated by blood or OPIM, in such a way as to avoid contact with the outer surface.

5. Housekeeping Regulated waste is placed in containers which are closable, constructed to contain all contents and prevent leakage, appropriately labeled or color coded (red)and closed prior to removal to prevent spillage or protrusion of contents during handling. All equipment, as well as, surfaces will be cleaned and decontaminated after contact with blood or other infectious materials. Appropriate cleaning agents are available in the supply room as well as in Personnel Department.

6 Contaminated sharps are discarded immediately or as soon as possible in containers that are closable, puncture resistant, leak proof on sides and bottoms, and appropriately labeled or color coded. Bins and pails are cleaned and decontaminated as soon as feasible after visible contamination. Broken glassware that may be contaminated is only picked up using mechanical means, such as a brush and dustpan.

6. Laundry The following laundering requirements must be met: • Handle contaminated laundry as little as possible, with minimal agitation. • Place wet contaminated laundry in leak proof, labeled, or color coded (red) containers before transport. • Wear appropriate PPE with handling and or sorting contaminated laundry.

7. Training Designated employees who may be exposed to bloodborne pathogens will receive training on the epidemiology, symptoms, and transmission of bloodborne pathogens diseases. In addition, the training program covers, at a minimum, the following elements: • A copy and explanation of the OSHA bloodborne pathogen standard. • An explanation of our ECP and how to obtain a copy. • An explanation of methods to recognize tasks and other activities that may involve exposure to blood and OPIM, including what constitutes an exposure incident. • An explanation of the use and limitations of engineering controls, work practices, and PPE. • An explanation of the types, uses, location, removal, handling, decontamination and disposal of PPE. • An explanation of the basis for PPE selection. • Information on the hepatitis B vaccine, including information on its efficacy, safety, method of administration, the benefits of being vaccinated, and that the vaccine will be offered free of charge. • Information on the appropriate actions to take and persons to contact in an emergency involving blood or OPIM. • An explanation of the procedures to follow if an exposure incident occurs, including the method of reporting the incident and the medical follow-up that will be made available. • Information on the post-exposure evaluation and follow-up that the employer is required to provide for the employee following an exposure incident. • An explanation of the signs and labels and or color coding required by the standard and used at this facility. • An opportunity for interactive questions and answers with the person conducting the training.

D. POST EXPOSURE EVALUATION AND FOLLOW-UP Should an exposure incident occur, contact your immediate supervisor and the Safety Director. An immediate confidential medical evaluation and follow up will be conducted by a Workers Compensation Panel physician.

7 Following initial first aid (clean the wound, flush eyes or other mucous membrane, etc) the following activities will be performed: • Document the routes of exposure and how the exposure occurred. • Identify and document the source individual (unless the company can establish that identification is infeasible or prohibited by state or local law). • Obtain consent and make arrangements to the source individual tested as soon as possible to determine HIV, HCV, and HBV infectivity; document that the source individual’s test results were conveyed to the employees’ health care provider. • If source individual is already known to be HIV, HCV or HBV positive, new testing need not be performed. • Assure that the exposed employee is provided with the source individual’s test results and with information about applicable disclosure laws and regulations concerning the identity and infectious status of the source individual. • After obtaining consent, collect exposed employee’s blood as soon as feasible after exposure incident, and test blood for HBV and HIV serological status. • If the employee does not give consent for HIV serological testing during collection of blood for baseline testing, preserve the baseline blood sample for at least 90 days; if the exposed employee elects to have the baseline sample tested during this waiting period, perform testing as soon as feasible.

E. PROCEDURES FOR EVALUATION The Safety Director and immediate supervisor will review the circumstances of all exposure incidents to determine: • Engineering controls in use at the time • Work practices followed • A description of the device being used (including type and brand) • Protective equipment or clothing that was used at the time of the exposure incident. • Location of the incident • Procedure being performed when incident occurred • Employee training

If revisions to this ECP are necessary the company will ensue that appropriate changes are made.

F. RECORDKEEPING Training records are completed for each employee, who may have an exposure, upon completion of training. These documents will be kept for at least three years at the Allentown location. The training record will include: dates of training, contents or summary of training, persons and qualifications of those conducting the training, the names and job titles of all personal attending the training.

Employee training records are provided upon request to the employee or the employee’s authorized representative within 15 working days. Such requests should be addressed to an officer of the company.

Medical records are maintained for each employee with occupational exposure in accordance with 29 CFR 1910.1020. The company is responsible for maintenance of the required medical records. These confidential records are kept for at least the duration of employment plus 30 years. Employee medical records are provided upon request of the employee or to anyone having written consent of the employee within 15 working days. Such requests should be sent to an officer of the company. 8 G. VACCINE DECLINATION

I understand that due to my occupational exposure to blood or other potentially infectious materials I may be at risk of acquiring hepatitis B virus (HBV) infection. I am aware that I may be vaccinated, at no charge to myself. However, I decline hepatitis B vaccination at this time. I understand that should I be exposure, I continue to be at risk of acquiring hepatitis B, a serious disease. If in the future, I want to be vaccinated with hepatitis B vaccine, I can receive the vaccination series at no charge to me.

Signed: (Employee)______

Date:______

9 SECTION 3 CHEMICAL SAFETY

A. INTRODUCTION The objective of this chapter is to provide guidance to all employees who use hazardous material so that they may perform their work safely. Many of these materials are specifically explosive, corrosive, flammable, or toxic; or they may have properties that combine these hazards. Many chemicals are relatively non-hazardous by themselves but become dangerous when they interact with other substances, either in planned operations or by accidental contact.

All employees must be aware of the hazards involved when working with chemicals and the remedies that need to be used when an accident does occur. Your supervisor or the Safety Director will conduct training on how to handle the chemicals you use and the first aid to be applied to victims of chemical exposure. On hire and annually all employees will have general Hazcom training? Training records will be kept on file in the Safety Director’s office. When an employee participates in Hazard Communications training, they are agreeing that:

• They have received general training and understand how to read the Safety Data Sheet (SDS) and container labels regarding hazardous products. • They understand that they are required to review the SDS for any material they am using for the first time. • They know where the SDS book for their work area is kept and understand that they are available for review at any time. • They understand that if they have any questions or concerns, they will ask a Manager or the Safety Director. • They understand that they are required to follow the necessary precautions outlined in the Hazard Communication Policy and SDS, including use of personal protective equipment and/or apparel.

Workers must know the acceptable levels of exposure to a chemical and what safety systems must be in place when working with a chemical. Workers must also ensure that facilities and/or work areas are adequately ventilated when using chemicals on and off premises. Before using any chemical, workers must review the SDS, if appropriate.

If ASGCO Manufacturing is presented with a situation that an employee does not speak English, the company will be responsible for obtaining training in their native language.

This program is complied with Hazard Communication requirements for Mine Safety and Health Administration and Occupation Safety and Health Administration. The Hazard Communication Program will be reviewed on an annual base by the Safety Director.

B. HAZARD COMMMUNICATION PLAN This section describes how ASGCO Manufacturing and our employees are informed of the potential chemical hazards in their work area so they can avoid harmful exposures and safeguard their health. Components of this program include labeling, Safety Data Sheet (SDS), and the right to know and training.

Supervisors/Managers must: 1) Identify hazards and hazardous materials for respective work areas. 10 2) Ensure hazards are properly labeled. 3) Obtain/maintain copies of safety data sheets, as required, of each hazardous material. 4) Inform Safety Director of any changes to chemicals or procedures 5) Have written Hazard Communication Program available to all employees. 6) Provide hazard-specific training to employees. 7) Substitute less toxic materials whenever possible. 8) Inform all front line employees of any known chemical hazards in a non-routine task and will address the use of proper PPE.

Employees must: 1) Attend Hazard Communication Training. 2) Perform operation in safe manner. 3) Notify supervisors immediately of any safety hazards or injuries. 4) If ordering material, identify all hazardous chemicals. 5) Note all locations of the readily available emergency washing stations throughout the facility

Safety Director must: 1) Develop and keep updated a written Hazard Communication Program. 2) Maintain a central file of SDS in a readily accessible location for all employees. 3) Assist Managers in obtaining the required SDS 4) Review and update stock safety labels. 5) Provide generic training programs. 6) Assist supervisors in developing hazard-specific training programs. 7) Oversee the Hazard Communication written policy and implementation plans. 8) Alert on site sub-contractors and contractors to hazardous materials in work areas. 9) Alert on site sub-contractors and contractors that they must provide to the employees information on hazardous materials they bring to the work site. 10) Assist in a hazard chemical inventory list with each department. 11) Monitor potentially hazards chemical exposures by appropriate means. This means may include, but is not limited to, air sampling. 12) Be certain that at no times all are employees to be exposed a higher than acceptable concentration of a harmful substance.

All employees must follow general safety precautions when working with chemicals. These precautions are: 1) Keep work area clean and orderly. 2) Use necessary safety equipment. 3) Carefully label every container with the identity of its contents and appropriate hazard warnings. 4) Store incompatible chemicals in separate areas. 5) Limit the volume of volatile or flammable material to the minimum needed for short operation periods. 6) Provide means of containing the material if equipment or containers should break or spill their contents. 7) Follow the requirements of this manual. 8) Provide a back up method of shutting off power to a heat source if any hazard is involved. 9) Obtain and read the SDS.

Labeling 11 The Globally Harmonized System (GHS) provides a readily recognized, easily understood system for identifying specific hazards and their severity by using Pictograms. These pictograms will be displayed in any of our facilities that manufacture, process, use or store hazardous materials. Interpretations of the pictograms are as follows:

C. HAZARDOUS CHEMICAL EXPOSURES TRAINING Asgco Manufacturing, Inc. will conduct a yearly training program on handling, hazards, storage, exposure risks, symptoms of chemical exposure and first aid. The annual training program will also be part of any new employee training. There must also be follow up training sessions regarding any new chemical or processes that may be initiated by the company. Follow up training sessions act as a reinforcement of safety standards that need to be followed on a daily basis.

In the training program, employees will learn acceptable levels of chemical exposures, proper storage and labeling of chemicals, and the use of protective clothing and equipment for handling chemicals. They will also learn about potential fire and toxicity hazards, when not to have a 12 chemical in a confined area, or to store in closed containers, the use of eye wash stations and safety showers, and the necessary posting of open and dangerous areas. It is important that an employee recognize the Threshold Limit Values or Permissible Exposure Limits of airborne contaminants and physical agents in the workplace

A procedure manual or set of instructions must be part of the program, with periodic inspections that clearly indicate whether an employee may be mishandling a chemical or endangering himself or others. Part of the manual or procedures must establish a standard of when and how to deal with chemical spills, neutralizing and disposing of spills or overflows.

Specialized first aid training and equipment will be routine in any facility where chemicals are used. Employees must know how to handle equipment in emergency situations, what equipment needs to be used and whether the equipment is adequate for the situation. Ventilation is another major factor in facility design and maintenance. Whether by natural means or mechanical, the system must be designed to control dust, fumes, solvents, gases, smoke or vapors which may be generated in the workplace.

When an employee is on-site at a customer’s facility, the facility must conduct a site specific hazard training which will include all chemical hazards, emergency procedures and required Personal Protective Equipment.

D. GENERAL RESPONSIBILITIES 1) It is the responsibility of employees and all who use the ASGCO’s facilities to understand the properties of the chemicals with which they will work and to follow all precautions that apply to each specific task. 2) When a chemical is received shipping will notify the Safety Director and will be responsible for passing the SDS Sheet on to the person responsible for maintaining the SDS books. 3) When faced with an unexpected malfunction, injury or damage, employees are expected to choose a course of action that provides the most protection to themselves and to others in the area. 4) Each employee is expected to report to their supervisor/manager an unsafe condition seen in the area that would not permit him or her to work safely. 5) Supervisors, Managers and Safety Director will assist employees in following safe work practices by providing information on the hazardous properties of materials, recommending methods for controlling the hazards of specific operations and by monitoring the work environment. 6) Supervisors/Managers must instruct their personnel about the potential hazards involved in the work, proper safety precautions to follow, possible consequences and emergency procedures to use if an accident should occur. It is also their responsibility to ensure that the protective equipment needed to work with the chemicals is available. This is especially true of any non-routine task. 7) All vehicles must contain an up to date SDS Book. The foreman and driver are responsible for keeping this book up to date. When on a job site, the SDS book and the specific hazards associated with the chemicals we used must be relayed to all contractors on a multi-contractor site. 8) If Engineering controls are not practicable or available to reduce the exposure, employees are required to wear respiratory protective equipment that is assigned to you by the Safety Director.

13 E. LABELS All containers (including glassware, safety cans, and plastic squeeze bottles) must have labels that identify their chemical contents. Information on the labels will include but not limited to: Chemical name, warnings, and the name and address of manufacturer. Labels should also contain information on the hazards associated with the use of other chemicals. Labels must be legible at all times and never removed. If you require a new label, please see the Safety Director immediately. If at any time a container is used for any other purpose, the hazard chemical label MUST be removed and container then label correctly.

F. CHEMICAL STORAGE The separation of chemicals (solids or liquids) during storage is necessary to reduce the possibility of unwanted chemical reactions caused by accidental mixing. Chemicals must not be stored in the same refrigerator used for any type of food storage. Storage units must follow OSHA guidelines stated in CFR, section 1910.106.

G. EMERGENCIES In case of an emergency, consider any of the following actions if appropriate:

1) Evacuate people from the area. 2) Isolate the area. 3) If the material is flammable, turn off ignition and heat sources. 4) Call the Fire Department or 911 for assistance. 5) Wear all necessary Personal Protective Equipment. 6) Pour Sorb-all or appropriate neutralizing agent on spill. 7) Clean up; place waste in proper bag or waste disposal container for disposal.

H. DISPOSAL OF CHEMICALS All ASGCO employees, participating guests and visitors using hazardous chemicals are responsible for disposing of chemicals safely:

1) Federal and State regulations mandate strict disposal procedures for chemicals. To comply with these regulations all personnel using our facilities must observe these procedures

2) Routine disposal of chemicals: a) In the general disposal of hazardous chemicals to the sanitary sewer, is not permitted. Managers, Supervisors and Safety Director will advise on the proper disposal of chemical wastes. b) In using chemical waste storage containers, certain procedures must be observed, as listed below. c) Incompatible chemicals must not be mixed in the same container. d) Waste oils must be collected in 55 gallon drums.

3) The following requirements must be met as a condition for pickup and disposal of chemicals: a) Chemicals must be separated into compatible groups. b) Dry materials must be securely contained in plastic bags and over packed in a cardboard box. Packages that are wet or have sharp protruding objects will not be accepted for pick up. c) Unknown chemicals will require special handling. The responsible department must make every effort to identify the material that is to be disposed of. If all the user’s 14 attempts to identify the waste chemicals have failed, the Manager or Safety Director will make the decision as to how to proceed. d) Each breakable container must be properly boxed. Place all bottles in plastic bags, then place in a sturdy container and use an adsorbent cushioning material that is compatible with the chemicals. e) Each primary container must be labeled with contents, amount, physical state and the percentage breakdown of a mixture. f) Each box must have a complete list of contents or description. g) For safety purposes, boxes must be of a size and weight so that one person can handle them. Boxes that exceed 45 pounds or 18 inches on a side cannot be safely handled by one person and will not be acceptable for pick up.

4) General Housekeeping rules: a. Maintain the smallest possible inventory of chemicals to meet you immediate needs. Periodically review your stock of chemicals on hand. b. Ensure that storage areas or equipment containing large quantities of chemicals are secure from accidental spills. c. Rinse empty bottles that contain acids or inflammable solvents before disposal d. Recycle unused chemicals whenever possible. e. DO NOT: 1) Place hazardous chemicals in salvage or garbage receptacles. 2) Pour chemicals into the ground. 3) Dispose of chemicals through the storm drainage system. 4) Dispose of highly toxic, malodorous, or lachrymatory chemicals down sinks or sewer drains.

15 SECTION 4 COMPRESSED GAS CYLINDER STORAGE AND HANDLING

A. INSPECTION Each employee will determine that compressed gas cylinders under his/her control are in a safe condition by a visual inspection of the cylinder prior to each use. Employees must read, understand and follow the markings on the cylinder, the label(s) on the cylinder, and the material safety data sheets (MSDS). Appropriate PPE is supplied by ASGCO Manufacturing and must be worn when working with compressed gasses.

B. LABELING All vendors must deliver properly labeled compressed gas cylinders with safety caps in place.

Compressed gas cylinders will be legibly marked for the purpose of identifying the gas content with either the chemical or the trade name of the gas. Markings will be by means of stenciling, stamping, or labeling and must not be readily removable. Whenever possible, marking will be located on the shoulder of the cylinder, according to OSHA standards. 1. A durable label should be provided and cannot be removed from the compressed gas cylinder. 2. Compressed gas cylinders that do not clearly identify its contents by name will not be accepted by ASGCO Manufacturing. 3. Color coding is not a reliable means of identification and will be not accepted by ASGCO Manufacturing. 4. If labeling on the gas cylinder becomes unclear or defaced so that the contents cannot be identified, the cylinder should be marked “contents unknown” and the manufacturer/vendor must be contacted and the cylinder must be removed from premises.

C. HANDLING OF CYLINDERS All employees must observe the following rules in the handling of compressed gas cylinders. The Fab Shop supervisor is responsible for training and making certain that all rules are followed: 1. Always wear proper Personal Protective Equipment (PPE). 2. Cylinders must always be transported on a wheeled cylinder cart with retaining straps or chains. 3. When done welding, you are required to turn off all cylinders. You should then bleed the lines, to confirm that there is no gas left behind in the lines. 4. Cylinders must be secured in a boot or by a chain to a fixed support to prevent them from being dropped or from falling over. 5. Never remove or change numbers or labeling on cylinders. 6. Cylinders can not be dropped, banged or permitted to strike each other or against other hard surfaces. 7. Never use compressed gas to dust or blow off clothing. 8. Never lift or move a cylinder by the valve cover.

9. If an employee has any questions or concerns, it is his/her responsibility to ask the Fab Shop Supervisor.

16 D. STORAGE ASGCO Manufacturing is responsible for providing proper storage for compressed gas cylinders. Each employee is responsible for making certain that cylinders are properly storage in these areas. 1. Store cylinders uprights and secure them with a chain, strap or cable to a stationary, sturdy, support or to a cylinder cart to prevent cylinders from tipping or falling. 2. Used only approved only containers to store and transport cylinders. 3. Oxygen cylinders should be kept at a minimum of 20 feet away from fuel-gas cylinders or separated by a non-combustible barrier at least 5 feet high with a fire-resistance rating of at least one-half hour. 4. Cylinders must not be placed or stored within 10 feet of a fire exit. 5. Cylinder Storage areas must be marked with proper precautionary signs. 6. Cylinders must not be placed or stored where they will be subject to mechanical or physical damage, heat, or electrical circuits. 7. Empty cylinders must be stored separate from full cylinders. 8. Caps used for valve protection will be kept on the cylinders at all times, except when the cylinder is actually being used or charged. 9. Cylinder valves must be closed when cylinders are not actually being used. This includes while cylinders are on carts, as well as in storage or when empty. 10. Never plug, remove or tamper with any pressure relief device. 11. Do not exposure cylinders to open flames or to any temperature above 125 degrees Fahrenheit. 12. Cylinders should not be exposed to continuous dampness, stored near any salt or other corrosive chemicals or fumes. 13. When empty cylinders are to be returned to the vendor as the earliest possible date.

E. TRANSPORTING 1. Cylinders must be transported by wheeled cart and must be fastened securely in an upright position so that they will not fall or strike against each other. 2. Cylinders must be transported with the safety cap in place. The cap should be screwed all the way down on the cylinder’s neck ring and should fit securely. Never lift the cylinder by the cap. 3. Cylinders should not be transported with the regulator attached to the cylinder. 4. Never move a cylinder by sliding, dragging or rolling.

F. PERSONAL PROTECTIVE EQUIPMENT When handling gases that are harmful to the skin, protective gloves and/or aprons must be worn to prevent skin absorption. Choose clothing made of materials that resist penetration or damage by the compressed gas. Refer to the MSDS for recommendations pertaining to PPE. If in question, see the Fab shop Supervisor.

17 SECTION 5 CONFINED SPACES/PERMIT REQUIRED CONFINED SPACE

A. INTRODUCTION Confined Spaces are one of the most dangerous places to work. An area must meet all three of the requirements listed below in order to be a confined space. 1. Must have limited opening for entry and exit. 2. Must be large enough and so configured that an employee can bodily enter and perform assigned work: and 3. The space is not designed for continuous worker occupancy.

When ASGCO Manufacturing employees are on a work site, the foreman is responsible for determining what Confined Space Policy is to be followed. In all circumstances a confined space per met must be completed prior to entering any type of confined space. ASGCO will never require an employee to enter a confined space on premise or on a worksite, if the employee feels that the space is immediately dangerous to life and health.

Confined space training is part of the annual training for ASGCO Manufacturing employees. The training will consist of:

B. ASGCO MANUFACTURING’S CONFINED SPACE POLICY Before entry into a confined space, all impellers, agitators, or other moving equipment contained in the confined space must be locked out. Ventilation must be either natural or mechanically provided into the confined space. Where there are no means of supplying ventilation, employees must wear a supplied air respirator. All hazardous or corrosive substances that contain inert, toxic, flammable or corrosive materials must be valved off, blanked, or disconnected. Atmospheric tests must be performed to check for oxygen content, toxicity and explosive concentration. No employee is permitted in a confined space if more than 20% of the lower explosive limit of any explosive substance is present in the atmosphere. Remember that, atmospheric tests must also be performed on a regular basis in a confined area where entry is required. The individual entering the confined space should witness the atmospheric tests and verify the results. The area must also be checked for decaying vegetation or animal matter that could produce methane. Adequate lighting must be provided within the space. If the confined area is located below the ground or near where motor vehicles are operating, care must be taken that vehicle exhaust or carbon monoxide does not enter the space.

Employees will follow site specific policy and procedures for physical barriers, protective shields or other safety equipment and procedures when working in a confined space where any electrical hazards may be present.

When personnel enter a confined area, assigned safety standby employees must be in the area, must be alert to the work being done, and must be readily available to respond to an emergency. They should be able to sound an alarm if necessary and to render assistance. Those standby employees must be trained to assist in handling lifelines, respiratory equipment, cardiopulmonary resuscitation (CPR), and first aid and be able to employ rescue equipment that will remove the individual from the confined space. Standby personnel should be in teams of two during such an operation and within the vicinity if working separately. There must also be an effective communication system utilized the entire time that the operation is occurring.

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When equipment which uses oxygen, such as salamanders, torches or furnaces, is used in a confined space, adequate ventilation must be provided to guarantee oxygen contents and combustion for the equipment. When this equipment is used, adequate measures must be taken to assure that exhaust gases are vented outside the enclosure. When gas welding or burning is used, hoses must be checked for leaks. Compressed bottled gas must be outside the area, and torches must be lit outside the area as well.

The atmosphere must be tested each time before lighting a torch.

Hot Work permits will be issued by the site Safety Director or his representative and must be reviewed by the job foreman.

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CONFINED SPACE ENTRY PERMIT ASGCO MANUFACTURING, INC. The permit must be completed prior to entry into the confined space. Entry cannot be performed if any boxes are marked “No”. This permit is valid for 8 hours only.

Date of entry:______Time of Entry______Location:______Type of space:______Equipment to be worked on:______Anticipated time needed to complete work:______Anticipated hazards:______Entry personnel:______Attendants:______

Acceptable conditions

1. Atmospheric Check Oxygen______%0-2 19.5% to 23.5% Explosive______L.F.L. <10% L.E.L./L.F.L Toxic______ppm 0-35 ppm Carbon Monoxide 0-10 ppm Hydrogen Sulfide Atmospheric Tester’s Initials:______Time:______2. Isolation of pumps/lines: NA Yes No Pumps or lines blocked, ( ) ( ) ( ) Blinked or disconnected 3. Ventilation: NA Yes No Mechanical ( ) ( ) ( ) Natural ventilation only ( ) ( ) ( ) 4. Hot Work Permit Required ( ) ( ) ( ) 5. Atmospheric checks after isolation and ventilation, if applicable Oxygen: ______% 0-2 Explosive:______% L.E.L. Toxic: ______PPM 6. Communication procedures:______7. Lockout/tagout procedures, if applicable:______8. Hazard awareness training done:______9. Equipment NA Yes No Direct Reading sample device properly calibrated ( ) ( ) ( ) Safety harnesses and lifelines for entrants and attendants ( ) ( ) ( ) Mechanical retrieval/hoisting equipment ( ) ( ) ( ) Communication equipment ( ) ( ) ( ) SCBA or Type C air line respirator ( ) ( ) ( ) Electrical equipment/Lightening/Non-sparking tools ( ) ( ) ( ) Traffic barriers/entrance covers ( ) ( ) ( )

I have reviewed the work authorized by this permit and the information pertaining to each item. Safety procedures have been received and are understood by all personnel. Entry Supervisor:______Date: ______

20 SECTION 6 CONTINUAL MONITORING AND IMPROVEMENT

A. SAFETY COMMITTEE All employees will be represented on the committee. The purpose is to bring workers and management together on a regular basis in a non-adversarial, cooperative effort to promote workplace safety.

The Safety Committee will have no more than 10 people on it at any one time. The Safety Committee By-laws are available to all employees for review.

The committee will meet at least once a month and minutes will be taken during all meetings.

The Safety Committee has many functions. Here is a list of responsibilities often assigned to the committee: 1. Planning and direction of loss control activities 2. Create, review, update and implement areas of the safety manual and other safety programs. 3. Review losses 4. Assist in accident investigations 5. Follow up on employee suggestions 6. Conduct inspections 7. Implement loss prevention recommendations 8. Complete job hazard analyses 9. Non safety issues can be addressed if requested by management

B. TAILGATE TALKS Foreman or managers will hold a 10 minute tailgate box at the beginning of each job. All employees at the worksite are required to attend. Foreman or managers should update all employees present as to the site specific hazards, that safety needs to be put first, and to always look out for your fellow co-workers. These meeting must be documented and all attending must sign the documentation. Signed documentation must be given to the Safety Director on a regular basis.

C. EMPLOYEE INPUT Front line employees are a valuable asset to our company. That is why it is important that all employees have a means of reporting safety and health hazards or problems. ASGCO has two means of doing this. The first is through the Safety Committee’s Safety Suggestion Box. These boxes are located, in the administrative kitchen, near the service area time clock and near the office in the Lightweight Division. Hazards and suggestions can be written up and put in the box anonymously. These suggestions, when appropriate, will be addressed at the Safety Committee Meeting.

The Safety Director has an open door policy which can also be used to report hazards and or unsafe conditions.

21 Under no circumstances will be employee be reprimanded for reporting, correcting or calling any type of hazard to the attention of the Safety Director, any management or any executive of ASGCO.

D. CORRECTION OF FOUND HAZARDS When a hazard is discovered either on premises or on the job site, corrections to those hazards will be made in order of priority based on severity. When corrections are made on the job site, they will be noted in on the

Tailboard form by the crew foreman. When hazards are called to the attention of the Safety Committee, when handled in order of severity, corrections will be noted in the Safety Committee Minutes. When hazards are found or called to the attention of the Safety Director, once corrected, the individual involved will be consulted and/or notified.

22 SECTION 7 CONVEYOR SAFETY

Conveyors are our business, therefore, it is always important to consistently follow all safe practices. Whether you are working on a single belt or a series of belts, all conveyors have inherit dangers while in motion and may have certain hazards while idle. The risk to our workers can be reduced by following safe working habits during operation and maintenance.

Although the size of the belts vary, basic safe practices are the same. Most importantly, you need to be concentrating on you job at all times. Leave your personnel problems out of your work day.

A pre-job plan should be discussed prior to starting maintenance on any job site, as well as on ASGCO premises. Hazards must be made aware of and conveyed to each employee. The foreman must do what is practical to reduce any known hazards throughout the job. Hazards can be reduced, by calling them to the attention of the job site safety personnel. If hazards are not correctly by the site personnel, employees should call the ASGCO Safety Director, who will then work with the customer to have the hazards reduced.

Always be aware of sharp edges, electrical hazards, incorrectly installed ladders, proper lock out/tag out procedures and slip, trip and fall hazards, and the hazards of a moving conveyor. Never touch or get in the position that you can get caught in a moving conveyor. Be certain that all body parts are kept clear of any conveyor in motion.

Travel ways need to be kept clear while working, in order to avoid trips and falls. Employees should use hand holds when available. If lock out/tag out is not being applied, all employees must know where emergency stop devices are located and a pre-job inspection to confirm that these devices are in working order must be done. If lock out/tag out procedures are to be done, each employee must have a lock AND tag on the device with each employee keeping their key in their possession at all times. Refer to the ASGCO Lockout/Tagout portion of the safety manual. All employees must follow either our lockout/tagout policy or the site specific lockout/tagout policy. Remember that stored energy may also come from; gravity, hydraulics, air pressure, mechanical and water. Constantly be aware of the possibility of flying or falling material, tools or product.

If on the job site, you are to enter a Confined Space, you must follow with the ASGCO Confined Space policy or the on site Confined Space policy. If at all possible, the attendant should be from the site that you are working at, as they know their emergency respond procedures and have practiced what steps to take in the event of an emergency.

If on a job site, you must use a standard ladder (not fixed) then be certain that the ladder is in good working condition and is the correct ladder for the job. The ladder must be placed on a solid even surface. The ladder should extend 3 feet above the working surface. Never place a ladder next to an electrical hazard. Once the ladder is positioned correctly, the top of the ladder must be tied off.

Proper PPE must be worn on job sites as well as on ASGCO premises. If you are in need of PPE or if you have any questions about proper PPE, please see the ASGCO Safety Director.

23 After work is completed on the conveyor, make sure that guards are replaced properly. Guards are meant to protect the on site workers and they depend on the proper placement of the guards.

There are severe hazards inherent to a conveyor in motion. An Employee is never to place any parts of their body in or near a moving conveyor. It is also very important to keep all loose clothing away from a moving conveyor.

As always, if you see a fellow worker performing an unsafe act, stop him, let him know the safe and correct way of doing the job. You have the opportunity to save a life by being .

Always work under the SLAM principle

S Stop. Think about the task, even if you have done it 20 times before

L Look around. Think of every step in the job and what hazards may be present. Think about how those hazards may change as the job progresses.

A Analyze. Determine each works skills, make certain you have the right tools to complete the job safely.

M Manage. Actively put in place the proper controls to eliminate or reduce the hazards, Stay focus on safety until the job is finished

24 SECTION 8 DRIVER AND VEHICLE SAFETY A. INTRODUCTION ASGCO Manufacturing recognizes that drivers play a key part of our mutual efforts to reduce claims, injuries, deaths and property damage through accidents. Driving an ASGCO vehicle is a privilege and should not be taken lightly. This policy is designated to promote safety awareness and accident prevention. These guidelines are to be adhered to at all times. Feel free to see your supervisor if you have any questions or concerns.

It is the policy of this company to require employees holding jobs that require driving to operate vehicles in a manner consistent with the state Motor Vehicle Code. Only employees who have prior authorization from the Service Manger may drive an ASGCO vehicle.

B. GENERAL VEHICLE OPERATING PROCEDURES GENERAL VEHICLE OPERATING PROCEDURES

1) Drivers are required to operate the vehicle in a safe and legal manner at all time.

2) Under no circumstances should a driver transport an individual who is not employed by the company.

3) All occupants of the vehicle during all times that the vehicle is in motion must use seat belts. All drivers are responsible for ensuring that all occupants of the vehicle use seat belts. Failure to comply with this standard will result in discipline, up to and including discharge

4) At no time, will a driver be permitted to operate a vehicle when his or her physical or mental condition would present a direct threat to the health and safety of himself, herself or others. This includes, but is not limited to, circumstances in which the driver is temporarily unable to operate the vehicle safely or legally because of illness, injury, medication, intoxication or while under the influence of any type of drugs. Upon discovering that an employee has driven under these circumstances, disciplinary action will be taken, up to and including discharge.

5) The driver is responsible for safeguarding the vehicle and its occupants at all times.

6) Drivers are responsible for informing their supervisor of any citations received during the course of employment. The driver is responsible for the resolution and payment of any citations or parking tickets that result from the action of the driver. The driver will be subject to corrective action.

7) When backing up a company vehicle the passenger will be out of the vehicle acting as a spotter for the driver. If there are no passengers then the employee will get out of the vehicle and do a walk around to assure that there are no obstacles in the vehicles path. If possible, the driver will request that an onsite person spot him while backing.

25 8) When driving any company vehicle, our employees must always act in a courteous manner and remember that they are the face of ASGCO. Never be disrespectful or boisterous to any person or persons, while representing ASGCO.

9) At various times, our vehicles will be required to carry cargo of some type. It is the driver’s responsibility to be certain that the weight of the load does not exceed the vehicle capability and to adequately secure the load. This also applies to any items normally carried on our vehicles. All items must be secured to prevent any type of unintentional movement.

10) ASGCO has many different types of vehicles. At no time should an employee use a vehicle for a use other than what it was intended to be used for. Always use the correct vehicle for the job.

10) When parking an ASGCO vehicle, it is always preferable to use a pull-through space. When a pull through technique is not available, first move forward should be utilized. When on an MSHA site a first move forward is required.

C. LICENSE REQUIREMENTS

1) It is the employees’ responsibility to inform their Department Manager and the Safety Director if you receive a DUI or if your license is suspended, revoked or non-renewed for any reason. Employees are not permitted to drive any company vehicle with an invalid license. Restoration of driving privileges will be at the discretion of the Safety Director and your Manager.

2) ASGCO Manufacturing, Inc. requests Motor Vehicle Reports on an annual basis from the Pennsylvania Department of Motor Vehicles, for all employees who drive a company vehicle. A 3 year Motor Vehicle Report is also required at time of hire. Employees are required to sign a release form. The Motor Vehicle reports will be done at no cost to the employee. If an employee does not reside in the state of Pennsylvania, that employee will be responsible for obtaining a 3 year Motor Vehicle Report and filing an expense report to be reimbursed for the cost of the report. Motor Vehicle Reports will be requested from the Department of Motor Vehicle upon notification of a license being suspended, revoked, or non- renewed, and upon valid investigated complaints from an outside source, or reasonable suspension

D. ACCIDENT REPORTING 1. The driver will notify police immediately in the event of an accident. The driver will record the names of any police officers and other authorities present at the scene of the accident 2. The driver will obtain motorist’s name, driver’s license number, vehicle license number, make of the vehicle and insurance company and policy number. 3. Employees will cooperate fully with authorities. However, employees should make no voluntary statement to anyone present, other than in reply to questions. 4. The driver will obtain motorist name, address, vehicle information etc. 5. Your supervisor and the Safety Director must then be notified of the accident/incident

26 6. Any theft or damage to company vehicles should be reported to your supervisor immediately. 7. Management will investigate and review all accidents, developing recommendations to prevent future occurrences.

E. MAINTENANCE 1) Any signs of malfunction, unusual sounds, vibration are to be reported and logged in driver’s mileage log. A maintenance request should also be submitted. Where the malfunction represents a hazard to the safe operation of the vehicle, the vehicle will not be used to provide transportation until such time as the malfunction is corrected. Any malfunction should be immediately reported to your supervisor. 2) Breakdowns are to be reported to your supervisor. 3) All vehicles are to be kept in safe, clean operating condition. 4) A vehicle Preventive Maintenance checklist is to be followed in regard to the maintenance and upkeep of the vehicle. Management will designate an individual to complete the checklist. 5) Corrective action must be taken in response to all warning lights and other signs of maintenance problems. 6) The vehicle interior and exterior must be kept clean. 7) All service should be performed by a certified mechanic. 8) The driver should ensure that all maintenance, inspections and serving is done at the proper time. 9) Drivers are responsible for checking the vehicle over prior to taking it out on a job. The checklist attached does not have to be completed unless there is something to report.

F. TRAINING New employees will be instructed as to company policy, procedures and safety regulations. Management or your supervisor may ask the Safety Director to conduct or instruct on. 1) Road test. 2) Written test. 3) Physical exam. 4) Drug testing. 5) Defensive driving techniques. 6) Driver Responsibility.

G. CELL PHONE USAGE Driver inattention is a factor in a majority of motor vehicle accidents. We are not only concerned about your welfare as an employee, but also the welfare of others who could be put in harm’s way by an inattentive driver.

Mobile phones and other hand held devices used while driving is a common, often harmful, distraction. Therefore, any employee driving a company vehicle is not permitted to use a cell phone for calling or for texting while driving, unless it is used in conjunction with a hands free device, which ASGCO will supply to you, if need be. Hand held devices, which are not permitted to be used while driving include but are not limited to; cell phones, pagers, palm pilots, and other communication devices.

If at any time you need to place a call or answer a call without a hands free device, pull off the road to a safe location and stop the vehicle before using your phone.

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H. ACCIDENT DATA CHECKLIST

Date of Accident:______Time:______

Location of Accident:

Drivers Name:

Drivers Phone Number: ______

Drivers License Number: ______

Vehicle Involved In Accident:

Damage:

Driver of Other Vehicle:

Address:

Phone Number:

Year, Make and Model of Vehicle:

Plate Number:

Damage:

Insurance Company:

Policy Number:

Police Officers Name:

Badge Number:

Injuries:

Supervisor Name:

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SECTION 9 ELECTRICAL SAFETY

A. INTRODUCTION It is the policy of ASGCO Manufacturing to take every reasonable precaution in the performance of work to protect the health and safety of employees and the public, and to minimize the probability of damage to property. The electrical safety requirements contained in this chapter are regulations set forth by OSHA and adopted by ASGCO Manufacturing. The Electrical Safety program is implemented by The ASGCO Safety Director and designated persons from the Service Department. These designated person are: Service Manger and Maintenance Supervisor.

B. TRAINING Employees who are exposed to electric shock hazards but who are not qualified persons will receive training annually on ASGCO Electrical Safety Practices. Training will pertain to on the job assignments and exposures. If on the job assignments change then the individual will be retrained prior to assignment changes. Training will consist of Safe Practices, On the Job Hazards, appropriate safe clearances or distances and any additional items that the Foreman and Safety Director feel are appropriate.

C. RESPONSIBILITIES All personnel are responsible for all aspects of safety within their own group. ASGCO’s Safety Director is responsible for providing information and assistance where appropriate.

ASGCO does not employee any individuals who are defined as “qualified” as described by the Code of Federal Regulation (29 CFR). If at any time during a job a “Qualified” individual is required, the on site facility will supply that person.

Individual employees are responsible for their own and their co-workers safety. This means that each employee should: 1) Become acquainted with all potential hazards in the area in which they work. 2) Use and follow the appropriate standards, procedures and hazard control methods. 3) Stop any operation you believe to be hazardous. 4) Notify your supervisor of any condition or behavior that poses a potential hazard. 5) Wear all appropriate Personal Protective Equipment. 6) Immediately report any occupational injury, illness or near miss to your immediate supervisor or to the company Safety Director.

Supervisors and supervisory positions should: 1) Develop an attitude and awareness of safety in the people supervised and seeing that individual’s safety responsibilities are fully carried out. 2) Maintain a safe work environment, and take immediate corrective action on any potentially hazardous operation or condition. 3) Ensure that the personnel you direct are knowledgeable and trained in the tasks they are asked to perform. 4) Ensure that safe conditions prevail in the area and that everyone is properly informed of the area’s safety regulations and procedures.

29 5) Ensuring that no employee is assigned to potentially hazardous work appears to be fatigued, injured, emotionally disturbed or under the influence of alcohol or drugs (prescription, over the counter medicinal or otherwise). 6) Conduct periodic inspections of individuals assigned to them. Completed individual inspections will be given to the Safety Director. 7) Any equipment that has been de-energized but can not be locked out or tagged out must be treated as being live.

Management shall: 1) Be responsible for being aware of all potentially hazardous activities within the area of responsibility. Only allow qualified persons may work on energized parts. 2) Assign responsibility or delegate authority for performance of any function, but remains accountable to higher management for any oversight or error that leads to injury, illness or damage to property.

Safety Committee shall: 1) Conduct inspections of premise, no less than quarterly, making certain that all equipment is grounded properly, all power tools have safe cords, each receptacle is properly covered and the GFCI’s are installed and working properly

D. GENERAL SAFETY RULES 1) OSHA Minimum approach distance for on site qualified personnel only will be adhered to at all time. Those distances are listed below and in the 29CFR1910.333:

VOLTAGE RANGE MINIMUM APPROACH DISTANCE 300v and less Avoid Contact Over 300v not over 750v 1 ft Over 750v not over 2kv 1 ft 6 inches Over 2kv not over 15kv 2 ft Over 15kv not over 37kv 3 ft Over 37kv not over 87.5kv 3 ft 6 inches Over 87.5kv not over121kv 4 ft Over 121kv not over140kv 4ft 6 inches

2) All operations are to be conducted with the equipment in a positively de-energize state, locked and tagged out. All external sources of electrical energy must be disconnected by some positive action (e.g. lock out breaker). 3) When manipulative, measurement and observation operations are to be conducted with the equipment fully energized and with the normal protective barriers removed is permitted only when fully justified and should be conducted under the closest supervision and control. One knowledgeable person should be involved in addition to the worker. 4) An up to date set of instructions for operation, maintenance, testing and safety should be provided and made readily available to anyone working on hazardous equipment. 5) Employees will adhere to the ASGCO written no jewelry policy. 6) A minimum distance of 10 feet must be adhered to when working by overhead lines. If at all possible those lines need to be de-energized. 7) Periodic individual inspections must be done on each employee who is authorized to do Lockout/tagout.

30 8) Communication equipment (e.g., fire alarm box, telephone) should be provided near any hazardous equipment. Its location should be clearly marked to ensure that the person requesting assistance can direct the people responding to a call for help to the emergency site quickly. 9) Any component on ASGCO property, that in its common use is non-hazardous, but in its actual use may be hazardous, must be distinctively colored and/or labeled. (An example might be a copper pipe carrying high voltage or high current.) 10) When new receptacles are installed GFCI’s must be used in those locations. When repairs are made to electrical equipment, where possible, GFCI’s will be used to replace current equipment. 11) Under no circumstances should flammable or combustible material be stored near electrical equipment. If flammable material must be stored indoors, materials must be stored at least 10 feet from any electrical equipment.

E. GROUND FAULT PROGRAM: 1) All GFI equipment will be tested for continuity while on premise. Be certain that when tested are electrically continuous 2) Testing will be done: a. On a semi- annual bases b. Before each use c. When equipment is serviced d. Immediately after any incident which may have damaged the equipment e. When inventory is done on equipment– which is approximately every 3 months.

The testing will be done to be certain that the grounding conductor is connected to its proper terminal.

Tests performed as required by this program will be recorded by the maintenance department as to the identity of each receptacle, cord set, & cord & plug connected equipment that passed the test. Records will be kept by means of logs, and will be made available for any person to inspect.

F. EXTENSION CORDS Extension cords are never to be used as a permanent part of any wiring, whether in the field or on premises. No extension cord is to be fastened with staples or otherwise hung in such a manner that could damage the outer jacket or insulation of the cord.

Cords are to be visually inspected before each use for any external defects and internal damage. If any damage is noticed, the cord is to removed from service, tagged “Out of Service”, and no employee may use it until OSHA approved repairs are made. If proper repairs can not be made prior to use, then the cord must be discarded.

All extension cords must be grounded and any devise or equipment used may not be altered to allow the grounding pole of a plug to be inserted into slots intended for connection to the current-carrying conductors.

When working in areas where there is a possibility of contact with water or dampness only extension cords made for that purpose may be used.

Extension cords with locking type connectors will be properly secured after connection is made.

31 G. LOCKOUT/TAGOUT PROCEDURES Repairs of all machinery, tools and equipment at ASGCO Manufacturing is to be done by qualified and authorized personnel only

The purpose of a Lock Out Tag Out program is to prevent machinery from unexpected start up or release of hazardous energy. Potential hazardous energy may include any source of energy from, electrical, hydraulic, mechanical, pneumatic, chemical and thermal sources. All of these sources are potentially dangerous. Therefore, before any work may begin on any electrical conductor or electrical equipment, Lock Out Tag Out must be used.

All machinery and equipment capable of movement must be de-energized or disengaged and locked out and tagged out during cleaning, preventive maintenance, servicing, adjusting or setting up operations. The locking out of the control circuits in lieu of locking out main power disconnects is prohibited, unless this is the only means of locking out. All equipment control valve handles must be provided with a means for locking out. If a piece of machinery is on property and the machine is hard wired or requires multiple steps to lock out, the lock out procedure will be posted on or near the machine itself.

Appropriate employees will be provided with individually keyed personal safety locks and tags. These are your lockout devices and Employees name and phone number must be on each lock and tag. If a machine can not be locked out, employees will apply a tags. A lock out tags will: be durable, be standardized, be substantial and be identifiable. The tags will be supplied to you my ASGCO Manufacturing and the wording will say one of the following, DO NOT START, DO NOT OPEN, DO NOT CLOSE , DO NOT OPERATE OR DO NOT ENERGIZE. When locking out both tags and locks MUST be used at all times. Employees are required to keep personal control of their keys while they have safety locks in use. When the power disconnect does not also disconnect the electrical control circuit, the appropriate electrical enclosures must be identified. The control circuit can also be disconnected and locked out.

Steps for appropriate lockout/tagout are: 1. Prepare for shutdown 2. Shut down equipment 3. Isolate equipment 4. Apply lockout/tagout device 5. Control stored energy 6. Verify isolation 7. Notify affected personnel, remove tools and equipment, remove lockout/tagout device.

All of the steps taken to lock out a machine must be documented on the tailboard report. Documentation will include who performed the procedure as well as who verified it. Immediate supervisors or job foreman are responsible for periodic inspections of individuals on their crew. Completed inspection forms must be given to the Safety Director.

Locks and tags are only to be removed by the person who originally attached the lock and tag. If that person is not available, every effort must be made to contact that person. If contact is not made, the foreman on the job, with permission from the Service Manager and the Vice President of Service, may cut the lock off. If this is done on a customer’s site, an authorized representative from the customer must be present.

32 When on job site locations, ASGCO will follow the safest Lock out/Tag Out policy and procedures. This may be those policies/procedures that are in force at the specific location or ASGCO procedures. The important factor is that ASGCO employees use locks provided to them, (keeping keys in their possession) with properly completed tags at all times. Employees will also verify that the piece of equipment or machinery is de-energized, prior to beginning work.

Each foreman is supplied with a gang lock out device. When using this device, all employees on the job will use their individual locks to lock out on the gang lock. All Lock out, tag out procedures will continue to be followed. When job is complete all individual employees will be responsible for removing their own lock. Foreman will verify procedure to ensure the safety of all employees on the job.

ASGCO employees are not permitted to do work on electrical conductors or high voltage electrical equipment. If our employees are in a situation where there is a chance of injury from electrical shock and/or arc flash, personal protective equipment must be worn. This PPE consists of an arc flash suite with face shield, safety glasses, non-conductive head protection, rubber insulated gloves and proper footwear.

H. ASGCO MACHINERY LOCK OUT/TAG OUT PROCEDURES

MACHINE SPECIFIC LOCK OUT PROCEDURES:

Press Brake 1. Inform all personnel and Fab Shop Manager/Supervisor in shop that the Press will be locked out 2. Insert blocks under ram 3. Turn disconnect off 4. Unplug press plug from disconnect #1. 5. Apply proper plug lockout device to plug itself 6. Have Fab Shop Manager/Supervisor AND individual working on machine apply lock and tag to plug lockout device 7. Have Fab Shop Manager/Supervisor AND individual working on machine apply lock and tag to outside of disconnect #1 8. Verify that machine is no longer energized by using the computer control station. Turn lower key on, depress green button on lower portion of the computer control station. 9. Apply out of Service Tag to computer control station and hand control stand

When Servicing of the machine is complete, the steps below must be followed when re- energizing. 1. Inform all personnel in shop that the Press maintenance/repair is complete and that the Press will be re-energized. 2. Thoroughly inspect the entire area to make certain there are no tools or materials left behind 3. Properly replace/close any guards taken off during maintenance 4. Fab Shop Manager/Supervisor and individual working on machine will take lock and tag off of plug lockout device. 5. Fab Shop Manager/Supervisor and individual working on machine will take lock and tag off of disconnect #1 6. Perform secondary check of area, making certain no individuals are exposure to danger 7. Energize Press Brake by plugging into disconnect #1 33 8. Start Press by turning on lower key at computer station, checking Press to make certain it is operating properly. 9. Remove blocks from under ram 10. Remove out of Service tags on computer control station and hand control stand.

Sand Blaster 1. Notify Service Shop Foreman that you will be taking equipment down. The Tool Room has a LOTO kit. 2. Notify all shop personnel that machine will be locked out. 3. Turn off main source of air pressure using the turn off valve overhead and to the left. 4. Release stored air pressure energy by turning blast to on allowing air to purge the system. 5. Carefully unplug machine. 6. Insert plug into appropriate plug lockout box and apply your lock and tag to the plug lockout box 7. Apply your lock and tag to the main red switch on side where material comes out of blaster. If lock and tag does not fit into main red switch, apply appropriate means to tag out, then apply your lock to that means. 8. Verify that the machine has been de-energized.

When servicing the machine is complete the following steps must be taken to re-energizing the Sand Blaster 1. Notify everyone in the area that the machine will be re-energized. 2. Do a detailed search of the immediate area, making certain that all tools and equipment is cleaned up and put in its proper place. 3. Be certain all guards and other parts are on the machine prior to taking locks off. 4. Remove locks from machine and plug from plug lockout box 5. Plug unit into designated socket 6. Turn the sand blaster on looking and listening to the machine to verify that equipment is running properly.

Plasma Cutting Table To De-Energized Plasma Cutting Table 1. Notify Shop Manager/Supervisor that you will be taking equipment down, Shop Manager/Supervisor has a LOTO kit. 2. Notify all shop personnel that machine will be locked out. 3. Close pressured air valves for cutter (3A) and air purifier (3B) 4. Released stored air energy by opening regulators on both cutter (4A) and air purifier (4B) 5. Lockout/Tagout red dial on right side of control by turning to the off position and applying lock and tag. 6. Turn off disconnect box 6A and 6B and apply locks and tags to both. 7. Turn Torit control panel off with knob on rear of purifier. Apply lock and tag. 8. Lock out Breakers on panel P-1. Breakers to be locked out are 20, 22, 24 (for air purifier) and 25, 27, 29 (for plasma table).

To Re-energize Plasma Cutting Table 1. Notify Shop Manager/Supervisor that maintenance is complete and Plasma Cutting table will be re-energized. 2. Notify all shop personnel that machine will be re-energized. 3. Take locks and tags off of breakers 20, 22, 24 and 25, 27, 29 in panel P-1. Turn Breakers on. 4. Take lock and tag off of air purifier (Torit). Turn air purifier on. 5. Take locks and tags off of disconnects (6A) and (6B). Turn both disconnects on. 34 6. Take lock and tag off of red dial on right side of control box. Turn control box to the on position. 7. Close air regulators to both cutter (4A) and air purifier (4B) 8. Turn air valves for cutter (3A) and air purifier (3B) to the open position.

I. ELEVATED LOCATIONS Any person working on electrical equipment on a crane or other elevated location must take necessary precautions to prevent a fall from reaction to electrical shock or other causes. A second person, knowledgeable as a safety watch, must assume the best possible position to assist the worker in case of an accident

J. ELECTRICAL SAFE PRACTICES 1) Emergency lighting – there must be an emergency lighting system that activates when normal power fails in Class C conditions. 2) Flammable and Toxic Material Control - The use of flammable or toxic material must be kept to a minimum. When components with such fluids are used, a catch basin or other approved method must be provided to prevent the spread of these materials. 3) Isolation - Covers and enclosures must isolate all sources of dangerous voltage and current. The frame or chassis of the enclosure must be connected to a good electrical ground with a conductor capable of handling any potential fault current. 4) Overload protection – Overload protection and well marked disconnects must be provided. Local “off” controls must be provided on remote controlled equipment 5) All disconnects and breakers should be clearly labeled as to which loads they control. 6) Ratings – All conductors, switches, resistors etc. should be operated within their design capabilities. Pulsed equipment must not exceed either the average, the rms, or the peak rating of components. The equipment should be de-rated as necessary. 7) Safety Grounding – Automatic discharge devices must be used on equipment with stored energy of five joules or more. Suitable and visible manual grounding devices must also be provided to short to ground all dangerous equipment while work is being performed. 8) Primary Disconnect – a means of positively disconnecting the input must be provided. This disconnect must be clearly marked and located where the worker can easily lock or tag it out while servicing the power supply. The lock out device must have a removable key, unless the switch or breaker is in the off position. 9) Exposed wiring and cords with frayed or deteriorated insulation must be repaired or replaced. 10) Flexible cords and cables must be free of splices or taps. 11) All openings in electrical enclosures and fittings must have appropriate covers, plugs or plates. All switches, receptacles or junction boxes must be provided with tight fitting covers or plate.

Under no circumstances should a qualified and authorized employee work on any tools, equipment or machinery that is not isolated from the energy source. All electrical tools, machinery and equipment MUST be unplugged if there is to be ANY service performed.

K. UNDERGROUND MINING Underground mining has specific guidelines for electrical equipment which is permitted for use. All electrical equipment brought into an underground mine must be inspected prior to use, and must have properly working grounds. Any electrical equipment used underground must have a working GFCI. GFCI must be at the power center.

35 If there is a problem with any electrical equipment, that piece of equipment must be tagged “Out of Service” and at no time used for any purpose. Equipment may only be repaired by a qualified electrician. Only ASGCO electrical equipment which has been approved for underground use may be used at any time.

36

Lockout/Tagout Periodic Inspection – Checklist and Certification ASGCO Manufacturing, Inc. GENERAL INSPECTION Name of Authorized Employee Being Audited: Audited By: Title: Location of Audit: PREPARING FOR SHUTDOWN AUDIT ITEMS The employee has been trained in ASGCO Manufacturing’s Lockout/Tagout procedures. � Yes � No

The employee was able to identify all “stored” and “kinetic” energy sources for this piece of equipment. � Yes � No

SHUTTING DOWN THE EQUIPMENT AUDIT ITEMS The employees shut down the piece of equipment using normal stopping procedures (e.g., putting a switch in the “off” position or � Yes � No pressing a button). ISOLATING THE EQUIPMENT AUDIT ITEMS The piece of equipment was isolated from every energy source feeding into it (e.g., close valves, throw main disconnects, throw � Yes � No circuit breakers) APPLYING LOCKOUT/TAGOUT DEVICE AUDIT ITEMS Appropriate locks, tags, and lockout devices were available and utilized. � Yes � No

CONTROLLING STORED ENERGY AUDIT ITEMS All potential residual hazardous energy was relieved, disconnected, or restrained (e.g., trapped pressure relieved, pipe � Yes � No flanges blanked, elevated equipment blocked or supported). VERIFYING ISOLATION OF AUDIT ITEMS The equipment was tested to ensure the right system was locked out and to ensure that the equipment could not be operated. � Yes � No

REMOVING LOCKS AND TAGS AUDIT ITEMS All equipment components are intact and capable of operating properly. � Yes � No

All lockout/tagout devices are only removed by the employee who applied them and affected employees � Yes � No have been notified that locks and tags have been removed and the equipment is ready for use. PROBLEMS List any problems identified during the lockout/tagout audit: List corrective action steps to rectify these aforementioned problems: Auditor’s Signature: Date: Authorized Date: Employee’s Signature:

37 SECTION 10 FIRE EXTINGUISHERS

INTRODUCTION Upon hire and annually thereafter, each employee goes through training on how to use a fire extinguisher along with fire prevention training. It is ASGCO’s policy that in the event of a fire on premises, all employees are to exit the building immediately. Annual fire drills are held in order to reinforce that no employee is expected or asked to fight a fire.

A. CLASS OF FIRE: There are four classes of fires. All fire extinguishers are labeled, using standard symbols, for the class of fire they can be used to fight. A red slash through any of the symbols tells you the extinguisher cannot be used for that class of fire. A missing symbol tells you only that the extinguisher has not been tested for a given class of fire but may be used if another extinguisher specifically labeled for that class of fire is not available.

Class A Fires – ordinary combustibles such as wood, cloth and paper.

Class B Fires – Flammable liquids such as gasoline, oil and oil based paint.

Class C Fires – Energized electrical equipment – including wiring, fuse boxes, circuit breakers, machinery and appliances.

Class D Fires – Combustible metals, such as magnesium or sodium. Extinguishers for Class D fires must match the type of metal that is burning.

WARNING – it is very dangerous to use water or an extinguisher labeled only for Class A fires on a cooking grease or electrical fire.

B. HOW TO OPERATE A PORTABLE FIRE EXTINGUISHER Always keep your back to an exit and depending on the size of the extinguisher, start 10 to 20 feet away from the fire and follow these procedures:

• Pull the pin. This unlocks the operating lever and allows you to discharge the extinguisher. Some extinguishers may have other lever release mechanisms. • Aim low. Point the extinguisher hose or nozzle at the base of the fire. • Squeeze the lever above the handle. This discharges the extinguishing agent. Releasing the lever will stop the discharge. • Sweep from side to side. Moving carefully toward the fire, keep the extinguisher aimed at the base of the fire and sweep back and forth until the flames appear to be out. Watch the fire area. If the fire re-ignites, repeat the process. Always be sure the fire department inspects the fire site, even if you thing you have extinguished the fire.

WARNING – Portable fire extinguishers discharge faster than most people think, many within 15-30 seconds. ASGCO supplies the extinguishers for emergency use and no employee is expected to fight a fire. Extinguishers are in the building to use as an aid in escape.

Extinguishers will be inspected by an authorized company on an annual bases. Assigned ASGCO personnel will inspect the extinguishers on a monthly bases. This inspection is to confirm that the extinguishers are properly charged, the pin is secure, the hose is free from 38 obstructions. Upon the employee inspection, date of the inspection, and initial of the employee will be added to the back of the annual tag. If at any time the extinguisher is not serviceable, the Safety Director should be notified immediately.

C. UNDERGROUND FIRE FIGHTING EQUIPMENT When working underground it is essential that our employees have readily accessible fire fighting equipment. In the event that hot work is being done, the requirements for fire fighting equipment are listed under the welding section of this manual

If not doing hot work, the fire extinguishers/fire suppression systems must be within 500 feet of work area and must contain no less than 20 pounds of dry chemical or 10 gallons of foam .

Fire extinguishers/fire suppression systems must be in usable and operative condition. Chemical extinguishers will have a approved tag attached to the handle of the extinguisher and must be examined on a monthly bases. The date and initial of the person who examines the extinguisher must be on the tag.

39 SECTION 11 GENERAL SAFETY

A. VENTILATION Air quality is an important factor in creating a safe and healthy work environment. ASGCO manufacturing has supplied several areas with approved ventilation systems. These areas include the 3rd Street Fab Shop and the Service Area.

The Fab Shop has a portable ventilation system that must be used when welding or fabricating is being done. The Fab shop supervisor is responsible for instructing all employees who do work in that area how to use and maintain this system.

Service area has a building ventilation system. This system must be turned on whenever work is being done in the area that would produce fumes of any kind. The objective for the use of the system is to reduce the ppm of any toxic/dangerous fumes and to be certain that these fumes do not spread to other areas of the building. When in doubt, use the system.

B. SAFETY POSTER ASGCO is required by law to post certain employment related information. This required information is maintained on a bulletin board in personnel, inside sales and lightweight departments where employees can find the following required posters: • Various State and Federal orders regulating the wages, hours and working conditions in certain industries. • Anti-Discrimination poster • Equal Employment Opportunity is the Law (EEOC form) • OSHA Safety and Health Protection on the Job • Notice of Workers Compensation Carrier • Notice to Employees: Unemployment Insurance and Disability Insurance • Notice: Employee Polygraph Protection Act

In addition to the above listed notices, a copy of this injury prevention program, a log and summary of Occupational Injuries and Illnesses, and a Fire Prevention and Evacuation Plan will be posted.

C. LICENSES AND PERMITS In addition to other postings required by law, the company maintains a copy of all necessary business licenses, permits and notices required by the national Labor Relations Board or other governmental bodies, notices of citations during abatement periods and other required information which will be posted during appropriate times.

D. WALKWAYS All aisles, passageways and walkways must be kept clear. Also, where possible aisles and passageways should be clearly marked. Wet surfaces must be covered with non-slip material and all holes properly covered or marked with warning guards. All spills must be cleaned up immediately and a caution sign placed on all wet and drying surfaces.

40 In cases of passageways used by forklifts, vehicles or other machinery, signs posted warning pedestrians of vehicular use.

Equipment must be properly stored so that sharp edges do not protrude into walkways. Changes in elevation must be clearly marked, as must passageways near dangerous operations like welding, machinery operation or painting. If there is a low ceiling, a warning sign must be posted. If the walkway or stairway is more than 30 inches or 4 steps above ground, it must have a guardrail.

If an employee is aware of any breach of these standards, please inform your immediate supervisor.

E. FLOOR AND WALL OPENINGS Be careful when working near floor and wall openings. All floor openings should be guarded by a cover, guardrail or equivalent barrier on all sides except at the entrance to stairways and ladders. Freight-lift landings should be marked clearly with a yellow warning border. Toe boards must be installed around the edges of a permanent floor opening if; persons can pass underneath opening there is moving machinery underneath, or there is equipment which falling materials could create a hazard.

Glass used in windows, doors and walls (including block glass) must be able to withstand a human impact an dif required by code, be shatterproof “safety glass”. Before beginning work at a new location, inspect it to ensure that all floor openings, which must remain open, such as floor drains, are covered with grates or similar covers. In roadways and driveways, covers with capacity to carry a truck axle load of at least 20,000 pounds must protect all manholes and trenches. In office buildings, fire resistive construction requires that the doors and hallway closures be properly rated and be equipped with self closing features. Be sure that there are at least two fire emergency exits accessible from your location at all times.

F. TOOL MAINTENANCE Faulty or improperly used hand tools re a safety hazard. All employees shall be responsible for ensuring that tools and equipment (both company and employee owned) used are in good condition. Hand tools such as chisels, punches, etc., which develop mushroom heads during use, must be reconditioned or replaced as necessary. Broken an d fractured handles on hammers, axes, and similar equipment must be replaced promptly. Worn or bent wrenches should be replaced regularly. Appropriate handles must be used on files and similar tools.

Appropriate safety glasses, face shield, etc., must be worn while using hand tools or equipment which might produce flying material or be subject to breakage. Eye and face protection must be worn when driving in tempered studs or nails.

Check your tools often for wear or defects. Jacks must be checked periodically to assure they are in good working condition. Tool handles must be wedged tightly into the head of tools. Tool cutting edges should be kept sharp enough so the tool will move smoothly without binding or sloping. When not in used, tools should be stored in a dry secure location.

G. COMBUSTIBLE MATERIALS All combustible material must be stored in covered metal receptacles and removed from the work site promptly. Proper storage to minimize the risk of fire, including spontaneous combustion, must e practiced. Only approved containers are to be used for the storage and handling of flammable and combustible liquids. All connections on drums and combustible 41 liquid piping, vapor and liquid must be kept tight. All flammable liquids should be kept in closed containers when not in use.

Bulk drums of flammable liquids must be grounded and bonded to containers during dispensing. Storage rooms for flammable and combustible liquids must have explosion proof lighting and should have mechanical or gravity ventilation. Liquefied petroleum gas must be stored, handled, and used in accordance with safe practices and standards.

“NO SMOKING” signs must be posted on liquefied petroleum gas tanks. Liquefied petroleum storage tanks should be guarded to prevent damage from vehicles. All solvent waste and flammable liquids should be kept in a fire resistant covered container until they are removed from the work site.

“NO SMOKING” rules will be enforced in areas involving storage and use of hazardous materials. “NO SMOKING” signs are posted where appropriate in areas where flammable or combustible materials are used and/or stored. Safety cans must be used for dispensing flammable or combustible liquids at point of use. All spills of flammable and combustible liquids must be cleaned up promptly.

H. FIRST AID KITS First aid kits and required contents are maintained in a serviceable condition. Unit-type kits have all items in the first aid kit individually wrapped, sealed, and packaged in comparable sized packages. The commercial or cabinet kits do not require all items to be individually wrapped and sealed but only those which must be kept sterile. Items such as scissors, tweezers, tubes of ointments and caps or rolls of adhesive tape, need not be individually wrapped, sealed or disposed of after a single use or application. Individual packaging and sealing shall be required only for those items that must be kept sterile in a first aid kit. Kits are positioned throughout, and are inspected periodically, if at any time an employee sees that items are missing from the first aid kits, please contact the Safety Director. Each service vehicle will also have a functional First Aid Kit, drivers are responsible for restocking these kits. All ASGCO first aid kits will consist of items that are appropriate for the environment in which they are to be used in. The required items will be reviewed on an semi-annual bases by the Safety Director and the Service Manager

Where eyes or body of any person may be exposed to injurious chemicals and/or materials, suitable facilities for quick drenching or flushing of the eyes and body are provided, within the work area, for immediate emergency use.

I. FIRST AID PROCEDURES ASGCO has an in house training program for CPR and First Aid. The American Red Cross training program is given to all Service Department employees, and at least two individuals from each department. Only CPR/First Aid qualified individuals may act as attendants where confined space procedures are followed. When on a job site, crew foreman and those trained and qualified are responsible for rendering first aid, this is especially true if medical assistance in not within 3-4 minutes of worksite.

J. UNIFORMS AND GENERAL APPEARANCE Service personnel and selected other personnel are supplied uniforms for everyday wear. Uniforms must be worn, by those that are supplied them, when working, either on site or at a customer’s site. Shirts must be kept tucked in at all times and general appearance must be maintained. 42 K. SAFE LIFTING PRACTICES On premises or on a customer’s site, when considering moving any type of material, it is always preferable to use mechanical means to lift. If mechanical lifting is not able to be utilized, a two man lift should be used.

All employees are instructed on the proper way to lift. This training is done upon hire and again every three years. Additional training is given in the event of a strain to the back or a similar injury.

L. FIRE SAFETY The ASGCO Safety Director is responsible for implementation and training of the fire safety plan. All new employees will be informed of our fire plan and annual training will be completed on fire safety and the use of fire extinguishers. ASGCO conducts annual fire drills. There are no designated personnel who are requested or required to stay behind to help fight a fire. In the event of a fire, employees are to evacuate the building then call 911. All employees are required to immediately leave the premise and go to the designated meeting place.

Each section of our manual, talks about housekeeping in that section of the company. The general housekeeping rules apply to the entire premises. The basic rule is that each area is responsible for the housekeeping in that area. There will be no debris, or clutter in any of the departments. All garbage is to be disposed of in the dumpsters provided. All garbage that would constitute a fire hazard, such as soiled rags, must be kept in the designated covered canisters.

Throughout the facility are emergency radios that are to be used in the event of a fire or other emergency. When alerting other areas of the company, an employee needs to use this means of communication. Next to each radio are the directions for use. They are:

Pick the radio up off of the base Exit the building if needed Push the “push to talk” button three times After the third time, talk slowly into the radio, announcing your emergency. For instance: There is a fire in building 2, evacuate all buildings

The inside receptionist will repeat your emergency, so that it is certain that all locations know your emergency and the steps that they should take. The receptionist will also call 911 to report the emergency.

When evacuation is necessary, the assigned sweeper will perform their duties and all others will evacuate immediately. Designated individuals will be responsible for taking department roll call and any other materials assigned to them. Emergency meeting place is on the southeast corner of Gordon and Third Streets.

In the event that we have individuals who need special assistance in evacuating the building, the department manager will be responsible for implementing that assistance.

Flammables, in quantities, are not stored in any of our buildings that house employees. All flammables in the buildings must only be in quantities of a single day use amount.

43 SECTION 12 HOISTING AND RIGGING

A. HOISTING

The ability to safely move materials from one location to another is a vital part of many activities at ASGCO Manufacturing. Hoists are often used when materials are too heavy or bulky to be safely moved manually.

Because hoists rely upon slings to hold their suspended loads, slings must be inspected prior to each use. This is also true for wire rope. Workers involved in hoisting and rigging must exercise care when selecting and using slings. The selection of slings/wire ropes should be based upon the size, load capacity, type of the load, and the environmental conditions of the workplace. Slings must be visually inspected before each use to ensure their effectiveness. Improper use of hoisting equipment, including slings, may result in overloading, excessive speed or sudden acceleration or deceleration of equipment. Never exceed the sling’s/wire rope’s rated load

If any damage is noted on the rope or slings, they must be destroyed immediately and discarded so as not to be used again.

Each lift must be carefully planned out and inspected so that hazards during the lift are avoided.

Under no circumstances should any individual stand under any item being hoisted, no matter the height or distance of a hoist.

When a piece of equipment with hooks is used, those hooks MUST contain safety latches. These latches must be in proper working order at all times. If the piece of equipment that is being used has faulty safety latches, it must be tagged out, repaired prior to use or given to the tool room for repair. Equipment is not to be used if latches are missing or broken in any way.

When on a jobsite, the foreman must designate a person to be the signaler for the crane operator. A signaler must always be assigned when the operator of a hoist or crane does not have a clear, unobstructed view.

B. RIGGING

Selection of the sling is only the first step in the rigging process. The next step is learning how to safely use it to hold and move a suspended load. There are four primary factors to consider when lifting a load safely. These are:

Load Size, Weight, and Center of Gravity – The center of gravity of an object is that point at which the entire weight may be considered to be concentrated. To make a level lift, the hoist hook must be located directly above this point. If the hook is too far to either side of the center of gravity, dangerous tilting will result, causing unequal stress in the sling legs. Load imbalances must be corrected immediately. Rated loads must never be exceeded.

Number of Legs and Angle with the Horizontal – The smaller the angle between the sling legs and the horizontal, the greater the stress on the individual 44 sling legs. This increased stress effectively decreases the weight that can be safely lifted with any given sling size. Large (heavy) loads can be safely moved by keeping this angle as large as possible and, when necessary, distributing the weight of the load among more sling legs. Rated Capacity of the Sling – The rated capacity of a sling varies depending upon the type of material the sling is made of, the size of the sling, and the type of hitch. Workers must know the capacity of the sling, and can obtain this information through charts or tables available through the manufacturer. The rated capacity of a sling must not be exceeded, under any circumstances. History of Care and Use – Mishandling and misuse of slings are the leading causes of sling failure. Following the manufacturer’s recommendations for proper care and use are essential for maximum sling service life and safety. Rigging a Belt – When on a customers site, whenever possible, there will be two means a securing a belt. Each means must be able to secure a belt by itself, should the other means let go, or disengage.

Slings must be inspected prior to each use, if any damage is found the sling must be destroyed and discarded so as not to be used again.

When rigging any material or equipment, a sling must be used. Under no circumstances should an employee do any hook rigging, unless there is truly no alternative. When hook rigging must be used, only the center of the hook is meant to be used to raise the load. Do not use the tip of the hook at any time.

Plan your hoisting and rigging to be done in the safest possible way. Be certain that all employees are in safe working positions and are alert and aware of what is happening around them. The job foremen will appoint a “signal person”. All signals will be given by the designated signal person according to the accepted standards.

C. CRANES AND OTHER MEANS OF LIFTING.

In the event that a crane or other similar lifting device is required on the jobsite, this equipment must be rented and a operator must be supplied. ASGCO does not allow their employees to operate any piece of equipment that they are not certified and trained on.

45 SECTION 13 INDUSTRIAL TRUCKS/FORKLIFTS

Only trained and competent personnel are allowed to operate any motorized vehicle or industrial truck. Due to current OSHA regulations, no person under the age of 18 may operate our Forklifts/Industrial Trucks. Any and all safety equipment provided with any lift truck or industrial truck will be used at all times. If industrial truck is equipped with seatbelts, they must be worn whenever the truck is in operation. Each industrial truck must have a warning horn, whistle, gong or other device which can be clearly heard above the normal noise in the area where operated. Before using a forklift, check that the brakes on each are capable of bringing the vehicle to a complete and safe stop when fully loaded. The parking brake must effectively prevent the vehicle from moving when unattended. At the start of each shift all operators must complete the daily checklist. If at any time, there is a defect on the truck from the checklist, the truck must be taken out of service until repaired. All inspection and maintenance logs are kept on file in the office of the Safety Director. These records are kept for a one year period.

Each truck must bear a label or some identifying mark indicating approval by the testing laboratory. Only approved trucks may be used in designated areas.

Any battery charging or refueling will only be done in designated areas, with brakes applied at all times.

Refresher training will be done when: 1) The operator has been involved in an accident or near miss. 2) The operator has been observed operating in an unsafe manner. 3) The operator has received an evaluation that reveals that he or she is not operating the truck safely. 4) The operator is assigned to a different type of truck. 5) A condition in the workplace changes in a manner that could affect safe operation of the truck. 6) At least every three years.

At no time shall the forklift or industrial truck carry a passenger.

When left unattended (operator is 25 feet or more away from the vehicle, or whenever the vehicle is not in view of the driver) load engaging means shall be fully lowered, controls shall be neutralized, power shall be shut off and brakes set. Wheels shall be blocked if the truck is parked on an incline.

When motorized hand and hand/rider trucks are operated, and when the operator releases the steering mechanism, make certain that both brakes are applied and power to the motor is shut off.

At no time should the truck be operated at unsafe speeds. If it is necessary for the forklift operator to answer his/her cell phone, the operator must come to a complete stop, answer the phone and take care of any business. Never drive a forklift and talk on a cell phone at the same time.

When at a corner or bend where driver is unsure if anything is approaching from the opposite corner, the driver will sound the horn as a warning for other vehicles or pedestrians who may not be able to see the Industrial truck. 46

Maintenance records are available so that a driver can check on the servicing of the truck in case of questions. Each forklift is equipped with “Daily Checklist”. This checklist must be complete prior to the start of each shift. If any items are noted as not functioning, the Safety Director must be notified immediately. Maintenance, regular inspections and Preventative maintenance of all forklifts is done by an outside company, and is scheduled by the Safety Director. Preventative Maintenance is done on a semi-annual bases and includes air quality testing.

All forklifts are equipped with safety cages, which protects the driver from any falling objects. In no circumstances should those cages be removed or tampered with.

All Industrial truck drivers will follow all instructions, rules and regulations reviewed during training sessions.

Due to the fact that ASGCO’s facility encompasses 2 city blocks there will be times that the operator must cross a city street. It is the operator’s duty to use extreme caution. Always look both ways and sound horn before entering the intersection.

Forklifts are equipped with garage door openers; these should be used when the garage door is within your sight. Using a garage door opener and not knowing if the door is open or closed could result in serious injury or property damage.

MOBILE EQUIPMENT – UNDERGROUND Only mobile equipment approved for underground use may be used. ASGCO does not own such underground mobile equipment, therefore all mobile equipment used in this atmosphere, must be owned and approved by onsite mine owners. All ASGCO employees using customers equipment will first be approved and trained to use this equipment by a qualified onsite person.

47

SECTION 14 LADDERS

Check ladders each and every time before you climb. Never exceed the recommended load capacity for the ladder you are using. Remember that this load capacity includes both you and any equipment that you may be using or carrying up the ladder. Ladders should be maintained in good condition: joints between steps and side rails should be tight, hardware and fittings securely attached, and moveable parts operating freely without binding or undue play. Non-slip safety feet are provided on each ladder and must be attached and in good condition. Ladder rungs and steps should be free of grease and oil. Employees are prohibited from using ladders that are broken, missing steps, rungs or cleats, or that have broken side rails or other faulty equipment or parts. If a ladder is damaged it must be tagged “Out of Service”, separated from usable ladders and destroyed prior to disposing of.

It is prohibited to place ladders in front of door openings except when the door is blocked open, locked or guarded. Placing ladders on boxes, barrels, or other unstable bases to obtain additional height is strictly prohibited. Face the ladder when ascending or descending and use three points of contact when using the ladder.

Be careful when you climb a ladder; do not use the top step of an ordinary ladder as a step. When portable rung ladders are used to gain access to elevated platforms, roofs, etc., the ladder must always extend at least three feet above the elevated surface.

It is required that when portable rung or cleat type ladders are used, the base must be so placed that slipping will not occur, unless it is latched or otherwise held in place.

All portable metal ladders must be legibly marked with a sign reading “CAUTION – Do Not Use Around Electrical Equipment”. Using ladders as guys, skids, gin poles, or anything other than their intended purposes is strictly prohibited. Only adjust ladders while standing at the base (not while standing on the ladder or from a position above the ladder). Metal ladders should be inspected for tears and signs of corrosion. Rungs of ladders should be uniformly spaced at 12 inches center to center.

48

SECTION 15 MACHINE GUARDING

Before operating any machine, each employee must have completed an orientation program on safe methods of machine operation. This orientation is done by a competent person who is familiar with the operation of the machinery being used. There will be quarterly inspections of machinery and equipment, the result of which will be documented. All machinery and equipment must be kept clean and properly maintained. There must be sufficient clearance provided around and between machines to allow for safe operations, set up, servicing, material handling and waste removal. If possible the machines moving parts need to be secured, so that there is no unintentional movement when the machinery is not in use.

All equipment and machinery should be securely placed and anchored when necessary, to prevent tipping, other movement or vibration that could result in personal injury. When warranted, machinery should be bolted to the floor and the electrical cord to the machinery fixed with a breaker or other shut off device to stop power in case of machine movement. The power control should be provided to make it possible for the operator to cut off the power from each machine without leaving his position at the point of operation.

All power shut off switches must be within reach of the operator’s position at each machine. Electrical power to each machine shall be capable of being locked out for maintenance, repair or security. The metal parts of electrical machines must be bonded and grounded.

The machine guarding must be secure and arranged so they do not present a hazard. At no time, except for maintenance and repair, should the guarding be removed from the machine. One or more methods of machine guarding will be provided on each piece of machinery/equipment. Guards will be placed, where possible, on point of operation, ingoing nip points, and rotating parts. Any foot treadle or foot press must be covered with a non-slip pad and the foot treadles guarded against unintended operation.

Assigned PPE must be worn when operating any machine or equipment. Your immediate supervisor will be responsible to see that the employee has the proper training and that safe working practices are being used. It is ASGCO’s policy that employees working with or around machinery must not wear jewelry, have any loose fitting clothing, or have long hair which is not securely tied back.

At no time should a piece of machinery be operated if it is a danger to the operator or to those in the immediate area. If an operator feels that the machinery will pose a danger to any persons, that employee should immediately contact the Safety Director, who will tag the piece of machinery out. As stated throughout this safety manual, if any machinery is defective it should immediately be taken out of service. This is done by tagging the piece of machinery out with a red out of service tag, and making certain that there is no power going to the piece of machinery

A. MISCELLANOUS GUARDING 1. All grinders, saws and similar equipment must be equipped with appropriate safety guards. Guards are not to be removed, except to service the tool. Power tools should not be used without the correct shield, guard or attachment, which has been recommended by the manufacturer.

49 2. Portable saws must be equipped with guards, above and below the base shoe. Guards should be checked periodically and before each use to assure they are not wedged up, thus leaving the lower portion of the blade unguarded. 3. All rotating, or moving parts of equipment should be guarded to prevent physical contact. 4. Effective guards must be in place over belts, pulleys, chains, sprockets, on equipment such air compressors, etc. 5. If portable fans are provided they must be equipped with full guards and screens with openings one half inch or less.

B. CIRCULAR SAWS A guard will be arranged on the saw to prevent accidental contact with the saw, the guard should completely enclose the upper half of the saw, the arbor end and the point of operation. Saws, where possible, will be purchased with a non-start device.

C. RIPSAWS Each hand fed circular ripsaw will be guarded by a hood which will completely enclose the portion of the saw which is above the table and the portion of the saw above the material being cut. Each ripsaw should have a spreader to prevent material from squeezing the saw or being thrown back onto the operator. In addition, non-kick fingers or dogs will be located as to oppose the thrust or tendency of the saw to pick up the material or to throw it back onto the operator

D. RADIAL SAWS All Radial saws must have an upper hood that encloses the upper portion of the blade including the end of the saw arbor. If the saw is used for ripping will have non kick back fingers or dogs located on both sides of the saw.

E. BANDSAWS/MITER BAND SAWS Band saws wheels will be fully encased with a solid cover. The front and back of the band wheels will be either fully encased by a solid or wire mesh material. All portions of the blade will be enclosed except for the working portion of the blade.

F. CHOP SAW Safety guards must be secure and in place at all times. Never cut free hand as this will create a hazard. Be certain that the piece that you are cutting is positioned corrected and clamped securely in place. It is not permitted to cut more than one piece at a time.

G. GRINDERS/ABRASIVE WHEELS A safety guard will cover the spindle end, nut, and flange projections. All grinders must have a work rest, which will be constructed from rigid material and be adjustable with wheel wear. Work rests must be adjusted so that there is no more than a gap of 1/8” between wheel and rest. Clear safety guards must be on the front of the grinder and positioned between the wheel and the operator to prevent objects from striking the operator. Distance between the adjustable tongue guard and the wheel is not to exceed ¼ inch. All abrasive wheels must be ring tested, this is done by tapping around the wheel with a wood handled screwdriver. Good wheels will “ring” like a bell and cracked wheels will sound “dead”. Dead wheels must be discarded immediately.

H. PLASMA CUTTER Be certain that all guards and covers are in place prior to operating the equipment. Have guards and/or covers replaced if they are damaged or missing. The Cutting Table should NEVER be operated if guards/covers are damaged or missing. It is necessary to periodically check the earth ground to prevent potential shock hazard. Guards are around the cutter itself. 50

I. BRAKE PRESS Guards on the press are in general painted yellow. Guards on in the rear and sides of the machine. At no time should any persons be positioned behind the rear of the Press Brake and there will never be any persons behind the rear guards of the machine. The exception to this rule is when completing the daily checklist or when the machine is locked and tagged out. At no time will any guard be by-passed or removed, unless press is locked out and tagged out for maintenance.

J. DRILL PRESS Safety guards will cover moving gears, pulleys, wheels and other pinch points. Chucks need to be in good condition and not stripped. Stop and start buttons must be within easy reach.

K. SLITTER MACHINES All pinch points must be marked to enhance awareness of potential dangers. Gears must be guarded while machine is in operation. Additional hazards areas must be marked so that operator is aware of the hazard.

L. COMPRESSORS All permanent compressors will have a warning posted on the compressor stating that the machine starts automatically.

M. TOOL PUNCHES/SHEAR When practical, tools need to be designed to prevent access to any dangerous parts. Guards will be in place to prevent access to dangerous areas from any side, but only when the guards themselves do not present a hazard. Shearing workstation should have suitable guards, work piece guides or hold devices to restrict access to tooling and prevent undue movement of the work piece when it is cut. Tooling at the take off side on this station will be guarded to the greatest degree practicable using fixed or adjustable guards. Guards should only allow enough space for the work piece to pass through and gaps should be filled with fixed guards.

N. IRONWORKER Guarding must be in place and secure at all times, be certain that the guard is adjusted down to within ¼ inch from the top of the material to be punched and to the bottom of the guard or stripper.

O. PERFORATION MACHINE At no time should the machine be used without all guards in place and secure. Pinch points will be marked and label will be legible at all times. Never use hand, while machine is operating to adjust belt or material being perforated. In the event that the machine is jammed, be certain that the machine is unplugged and if possible, a tool should be used to clear machine. Follow all safe operating procedures from the manufacturer.

P. PORTABLE FINGER MACHINE Machine should be placed on solid surface when operated. Follow all manufacturers safety recommendations when operating. Pinch points will be marked and label will be legible at all times. Be certain that you are operating machine at the correct psi, according to product being manufactured.

Q. Z-CUTTER/IN HOUSE FINGER OVER FINGER MACHINE

51 Remove any hazards that are near the machine prior to use, this includes tripping hazards as well. Pinch point signs are placed on or near pinch points and will be legible at all times. Follow all manufacturer’s safe operating procedures. Be certain that you are operating machine at the correct psi, according to product being manufactured.

R. PLY SEPERATOR Guard must be in place at all times. Be certain that machine is operated while on a level surface and that all hazards around machine are removed prior to use. Avoid labeled pinch points when operating. Follow any safe operating precautions from owners manual at all times.

S. V GUIDE MACHINE Pinch points are a hazard and special care must be taken to avoid contact with them. Machine has legible labels for pinch point hazards. Never operate machine in an unsafe manner and always follow the safe operating guideline in the owners manual.

52 MACHINERY/EQUIPMENT QUARTERLY INSPECTION MANUFACTURED PRODUCTS DATE:______INSPECTION DATE:______

Machinery/Equipment/Power Safe for Repair Needed Tools use Mitre Band Saw Grinder Radial Saw (Tiger 350) Drill Press used for notching Drill Press Vertical Band Saw Drills

Inspection items: Guards on Point of Operation Machinery Anchored Properly Pinch Points clearly marked Power source is safe condition Guards in place and secure Shut off possible without leaving point of operation Controls easily reached/operator does not need to reach around hazards on equipment Are all parts secure Condition of blades Hood of saws secure not broken or cracked Do saws have non-kick back fingers or dogs Automatic shut off working Grinder – work rest 1/8 “, tongue ¼”

53 MACHINERY/EQUIPMENT QUARTERLY INSPECTION SLITTER ROOM

DATE:______INSPECTION DATE:______

Machinery/Equipment/Power Safe for Repair Needed Tools use Slitter Machine SEE EXCEL WORKSHEET

Inspection items: Guards on Point of Operation Machinery Anchored Properly Pinch Points clearly marked Power source is safe condition Hoses and hydraulic lines in good condition Guards in place and secure Shut off possible without leaving point of operation Controls easily reached/operator does not need to reach around hazards on equipment Are all parts secure

54 MACHINERY/EQUIPMENT QUARTERLY INSPECTION FAB SHOP

DATE:______INSPECTION DATE:______

Machinery/Equipment/Power Safe for Repair Needed Tools use S20A Horizontal Band Saw Dake Hand Press Monarch 16” CW Lathe Victor Power Mill Grinder Blower Kamatsu Plasma Cutter Table Primeline Brake Press Smoke Eater Milling Machine Siouz Power Washer Wagner Powder Coating Gun Sand Blasting Machine with Filter Industrial Drill Press

Inspection items: Guards on Point of Operation Machinery Anchored Properly Pinch Points clearly marked Power source is safe condition Guards in place and secure-Feed side guard/take-off side guard Work piece guides in place Foot pedals are coated with guards over top Shut off possible without leaving point of operation Controls easily reached/operator does not need to reach around hazards on equipment Are all parts secure Condition of blades Hood of saws secure not broken or cracked Do saws have non-kick back fingers or dogs Automatic shut off working Grinder – work rest 1/8 “, tongue ¼”

55

MACHINERY/EQUIPMENT QUARTERLY INSPECTION LIGHTWEIGHT

DATE:______INSPECTION DATE:______

Machinery/Equipment/Power Safe for Repair Needed Tools use Perforation Machine Portable Finger Machine Z Cutter Ply Separator V Guide

Inspection items: Guards on Point of Operation Machinery Anchored Properly Pinch Points clearly marked Power source is safe condition Guards in place and secure Shut off possible without leaving point of operation Controls easily reached/operator does not need to reach around hazards on equipment Are all parts secure Condition of blades Hood of saws secure not broken or cracked Do saws have non-kick back fingers or dogs Automatic shut off working Grinder – work rest 1/8 “, tongue ¼”

56

SECTION 16 OFFICE SAFETY

Accident prevention in the office begins with a positive attitude for learning and following office safety procedures; practicing good housekeeping and using common sense.

A. FLOOR SURFACES Keep floors and stairways clean. Pick up paper clips, paper, pens, pencils and other objects immediately. Watch out for wet floors or recently cleaned floors as well as carpets that are folded or not securely in place.

B. CHAIRS Keep all chair legs on the floor. Tilting results in overbalancing and falls. If your chair is broken, please let your supervisor know, so that it can be fixed. Never use a chair as a ladder.

C. ELECTRICAL Exercise care to prevent electric cords on office machines, telephones and computers from becoming tripping hazards. Avoid stretching cords between desk or across aisles. Never cut off the grounding plug of any machine or equipment. Discard any cord which is frayed or showing signs of wear. Never overload an outlet. All switches must be enclosed and grounded. Panel board doors must be kept closed. OSHA Regulations state that no extension cord should be permanently affixed to the building or used as permanent wiring.

D. STAIRWAYS Use handrails on stairways using step at a time. Report worn carpet or treads and broken or loose stairs to the Safety Director

E. ENTERING AND LEAVING WORK Stay aware of the weather conditions when entering or leaving work. Sidewalks and parking lots may be slippery from ice, snow, sleet or rain. Wear the appropriate footwear for the type of conditions. Always wipe your feet when entering a building.

F. FILE CABINETS If not taking care, file cabinets can pinch, cut, crush or trip users. File cabinets may also tip over if not properly weighted. Take caution in what is stacked on top of the file cabinet. When you open a drawer be certain to close it if you walk away so that no other employee bumps into it or trips over it.

G. SHELVES AND STORAGE Stack objects neatly inside cabinets and on shelves. Keep frequently used items within easy reach. Always store heavy or breakable items on lower shelves.

H. HOUSEKEEPING Everyone benefits from good housekeeping practices. It is something everyone can and should practice with every task during the workday. Good housekeeping means taking care of your area as well as general use areas.

57 Dispose of broken items as soon as possible. Store knives, scissors, pushpins and other sharp objects where they will not be a hazard. Place waste baskets, brief cases, umbrella and similar items where they so not become a tripping hazard.

Clean up spills immediately, so that employees do not slip on wet floors. If a floor has the possibility of being continually wet, a wet floor sign or cone should be placed in the area to call attention to the possibility of a wet floor.

I. ELECTRIC HEATERS Heaters are sometimes needed for the comfort of employees. Any heater used must be of the kind the turns off automatically once it is tipped. Heaters of this kind need to be tested at the beginning of each season to be certain that the tip over device is still functional. Always keep all sides of the heater clear. Do not use heater near any flammable items.

J. FURNITURE Broken furniture can present a safety hazard. Report all damaged furniture (including chairs) immediately to the Safety Director.

K. GENERAL ACCIDENT PREVENTION Don’t run in the office or in the stairwells. Be especially careful when turning corners or other blind spots. Be extremely careful when carrying hot liquids. Always use the correct lifting technique and if an item is too heavy or bulky for you ask for help.

58

SECTION 17 ON SITE SAFETY

It is of concern to ASGCO Manufacturing that safety is a part of every aspect our day and of our company. Since a majority of our work is done at customer’s locations, it is imperative that safety awareness follows employees out in the field. Any worker who exhibits unsafe behaviors, or who present a risk to other members of their crew will be removed from our customer’s site. In the same regard, if an employee feels that fatigue or illness will affect their safety performance, they must immediately notify their supervisor/manager or the Safety Director.

Because of the nature of our work and the inherent dangers of what we do, no employee is permitted to work alone. If there is more than one crew on the customer’s site, there must be a means of communication between the crews.

A. TAILBOARD SAFETY TALKS Prior to beginning the actual work on a customer’s site, foremen are responsible for conducting a Field Service Tailboard Talk and have documentation of that training. A form for this is attached and must be completed for each job. Special attention must be given to the hazards that are present during that job. Remember hazards change as the job progresses, so when hazards are eliminated or created, this must be brought to the attention of each employee.

B. GENERAL ON SITE SAFETY Each employee is responsible for their safety as well as the safety of their fellow workers. It is each employee’s duty to be certain that the proper PPE is worn while on the job site Each employee must always work with Safety in mind. If you see that an employee is not following our safety rules and guidelines point it out to them, or let them know a safer way of doing the job.

When site specific hazards are present, the on-site safety director/contact should notified. If the hazard is not corrected to our employee’s satisfaction, then the ASGCO Safety Director should be notified.

Because we are working on our customer’s property, employees will follow the customer’s safety procedures or the ASGCO safety procedures, whichever is more stringent. In the event that the customer does not have a policy covering what we are doing, employees will then follow the ASGCO Safety Policy. If there are any questions about the ASGCO policy or the customer policy, the on-site safety officer or the ASGCO Safety Director should be contacted.

All Equipment and tools should be inspected for defects prior to the start of each workday. If any tool or equipment is found to be defective, an “Out of Service” tag must be applied to that tool or piece of equipment. The item must then be taken out of service. As soon as possible, the defective item should be brought into the Service area and placed separate from usable tools and equipment, until repairs are made.

It is imperative that while at a customers jobsite, all employees sign in and out of the facility upon entering, leaving for lunch, returning from lunch and leaving at the end of a job. At no time, will an ASGCO employee be on site without the direct knowledge of the customer. All required PPE will be worn on a customers site at all times, PPE is put on prior to the sign in of ASGCO Employees. Remember that safety glasses with side shields must be worn at all times as well as hearing protection 59 worn in all designated areas. No clothing must be loose fitting or baggy and long sleeves and long pants are to be worn on site.

Certain customers have special requirements to PPE. Those requirements are kept on file by the Safety Director. It is the job of the foreman to know and follow those requirements when on the customers site at all times.

Employees shall stay clear of hoisted loads at all times, this includes staying clear and not working or passing under buckets or booms. ASGCO employees do not operate, dippers, buckets, booms or other heavy equipment. In the event that this equipment is on site and operated by the customer remember that loads will never be swung over cabs of vehicles or equipment until the drivers are out of the cabs and in a safe location.

When on a customer’s site, crew must use two means of securing a belt that is being worked on, especially when preparing or working on a belt in order to take it off of a system. Each securing site must be adequate to stop belt movement by itself. In the event that one securing site gives way, the additional site will be adequate to hold the belting.

It is important that we always leave a customer’s site the way we found it. ASGCO strives to minimize any potential impact to the environment therefore all ASGCO generated trash waste or scrap must be taken with you or arranged with the customer for disposal. Arrangements for all disposals of wastes, trash and/or scrap will be made prior to commencement of work. No items must be left at the job site. If special handling is involved, arrangements will be made prior to completing the job for the items disposal. Foreman must inform crew as to the special handling required and the proper method that will be used to dispose of waste. If in doubt as to the proper disposal, contact the Service Manger or Safety Director. If any trash or scrap items are able to be recycled, arrangements must be made to have this completed. ASGCO does have the ability to recycle some items. The Service Manger knows what those items are and will communicate that to the job foreman.

C. SITE SPECIFIC SAFETY/REQUIREMENTS Some of ASGCO customers have specific requirements for safety. This would include special required PPE. Below is a current list of those companies and their requirements:

Upon completion of any job on a customers site, the foreman and crew must walk the conveyor to be certain that no tools or other equipment is left behind. Conveyors must be free of any material that an ASGCO employee has used while on the job. Pay special attention to the return side of the conveyor, where items may not be visible, but also make certain you look on the carry side as well.

CONSOL 1. Hard hat – Only approved hard hats are allowed, they must be in good condition with no cracks. There must 6 square inches of reflective tape on both sides and the back. The reflective tape must be blue to indicate contractors. Employees first and last name in at least ½” letters and ASGCO company name must be on hard hats.

2. Side shields must be on safety glasses at all times. Any safety glasses must be ANSI approved and additional eye protection may be required by specific sites/tasks.

3. Clothing – All contractors must wear appropriately fitting clothing. No clothing is to be excessively baggy or least. Flame retardant clothing is required on specific site.

60 4. High visibility Clothing – at a minimum there must be sufficient reflective and high visibility material to provide visibility from all directions on the outermost layer of clothing on the arms and/or torso. ASGCO standard uniform meets these criteria and must always be worn at a CONSOL job site.

5. Metacarpal Gloves – Metacarpal gloves must be worn at all times by may be replaced with other appropriate gloves, when performing specific task which will be determined by the site manager. Immediately upon completion of the specialty task metacarpal gloves must be worn.

6. Leg Bands – Pant leg bottoms must be secured or bloused at all times. This can be accomplished by making certain that pant legs are secured inside tops of work boots.

7. Metatarsal Boots – Metatarsal boots are required at all times unless a written approved exception has been granted by the Vice President of Operations and Vice President of Safety.

PP&L Due to the standing PP&L procedures for lock out/tag out, ASGCO is has a requirement for all crews that work at PP&L. When on site at any PP&L facility, once the conveyor is tagged out, the entire ASGCO crew must walk the conveyor with a PP&L employee and witness that the conveyor can not be energized. No ASGCO employee must start work on any of PP&L conveyors without verifying that the proper conveyor has been de-energized.

D. UNDERGROUND MINING PRODUCTS/EQUIPMENT Only products or equipment which are approved for use in the environment in which they are to be used may be used by ASGCO employees. If there is a question as to the product/equipment approval, please contact the onsite Safety Director or the ASGCO Safety Director to confirm that the product/equipment may be used.

Regardless of product/equipment approval all products/equipment entering an underground mine must be flame resistant or made of noncombustible material and be tested according to 30 CFR 7.27/7.28 or other applicable regulations, which ever applies.

All battery assemblies and or battery boxes must meet MSHA approval. Minimum thicknesses based on the total weight of a unit must follow MSHA guidelines, posted in 30 CFR, Part 7, Subpart C. Any battery assembly or battery box that does not meet these guidelines may not be used at any time.

Diesel engines and or diesel power packages used in underground mines must meet specific engine performance guidelines as well as exhaust emission requirements which are set by MSHA. Any such engines not meeting the 30 CFR, Part 7, Subpart E and Subpart F guidelines may not be used in any underground mine at any time.

Electric motor assemblies used in underground mines must meet all the requirements of 30 CFR, Part 7, Subpart J prior to being used.

30 CFR, Part 14, Subpart A, states that all conveyor belts used in underground mining must meet flame resistance MSHA requirements. No conveyor belt or conveyor component which does not meet all MSHA requirements may be used. ASGCO Manufacturing, Inc. is responsible for making certain that any belt, component, product or equipment that carries the ASGCO name meets all of the necessary requirements.

61 All conveyor belts used in underground coal mines must be flame resistance and tested in accordance with 14.22 of the 30 CFR or be tested in accordance with an alternate test determined by MSHA to be equivalent under 30 CFR 6.20 and 14.4.

Any electric motor-driven mine equipment and accessory must meet all of the MSHA guidelines in 30 CFR, Part 18. ASGCO Manufacturing, Inc. is responsible for those motors or accessories which carries the ASGCO name. If at any time an ASGCO employee is working with other than ASGCO motors or accessories, be certain that the component is MSHA certified. If at any time there is doubt as to the certification, contact the on site Safety Director or the ASGCO Safety Director to be certain that equipment is properly certified.

Motors used must contain fire resistant hydraulic fluids as deemed appropriate by MSHA

E. SURFACE AND UNDERGROUND MINING SITES Any additional or more stringent site specific safety regulations must be followed at all times. Site specific training must be completed prior to entering any surface or underground mine site. It is the responsibility of the individual ASGCO employee to adhere to these and all site specific requirements. Any hazardous conditions at a customers site must be reported immediately to the on site safety personnel.

All ASGCO employees have the right and the obligation to cease working if conditions at the customer’s site are beyond normal inherent dangers.

F. ON SITE EMERGENCY Each foreman is responsible for informing their crew how to proceed in the event of an emergency, while at a customer’s site. Emergency numbers and procedures must be specific and must be noted on the daily tailboard form. If the customer has no specific emergency procedures, ASGCO employees must call 911 in the event of an emergency.

In the event of an ASGOC employee being injured on a customer’s site, if it is a life threatening injury, that employee must be transported to the nearest emergency hospital.

Every crew of 1 foreman and 3crew members will have at least 1 individual who can administer CPR/First Aid. That individual will be trained thru ASGCO with the American Red Cross Standards.

G. SCAFFOLD/TEMPORARY WORK PLATFORMS ASGCO does not employ any persons capable of erecting or inspecting scaffolds and/or temporary work platforms. Therefore, our employees will not erect nor inspect scaffolding, of any kind. Should scaffolding or temporary work platforms be needed to work on a conveyor, our customer must erect and inspect them. Tags will be affixed by the customer, not by ASGCO. Inspections must be done daily, prior to use. If this is not accomplished, our employees cannot use the customer’s scaffold and/or temporary work platforms. Should the event arise where we are working from a temporary platform or scaffolding that has been created for us, be certain that the load limits for the platform or scaffolding are never exceeded. Employees will be trained in the proper PPE and methods to be used when working from an elevated position.

62

FIELD SERVICE TAILBOARD RECORD Date:______Location:______Foremen (print)______Sign______Subjects Covered: _____GENERAL JOB SCOPE _____INTRODUCTION TO WORK ENVIRONMENT

_____HAZARD RECOGNITION _____HEALTH _____ELECTRICAL _____ENVIRONMENT

_____EMERGENCY PROCEDURES _____EVACUATION _____FIRE _____MEDICAL _____RESCUE

_____ACCIDENT PREVENTION _____LOCKOUT/TAGOUT PRECEDURES _____PPE

Assigned Tasks NAME DESCRIPTION OF TASK TRAINED Y / N INITIALS

NOTES:

EMERGENCY CONTACT:

By signing this form the Foremen acknowledges awareness and training has been covered relating to the listed subjects and job scope

63 INSTRUCTIONS FOR TAILBOARD

GENERAL JOB SCOPE – All crew members are made aware of the overall job description and the responsibilities of each crew member.

INTRODUCTION TO WORK ENVIRONMENT – All crew members are made aware of the process of the plant that affects the work area. Crew members know the general layout of the location and any special needs of the job site.

HAZARD RECOGNITION – o HEALTH – Identify any possible health hazards and how those hazards will be eliminated or addressed. Be certain that all necessary PPE is in good condition and available. o ELECTRICAL – Electrical hazards are examined and eliminated where possible. Crew is aware of any hazards that can not be eliminated. Crew understands how to avoid these hazards. Be certain that all necessary PPE is in good condition and available. o ENVIRONMENTAL – Conditions of the work area including physical hazards such as moving equipment or machinery, inadequate machine guarding, improperly maintained catwalks or housekeeping issues, other work being performed in area, hazardous terrain. Special attention should be on weather conditions.

EMERGENCY PROCEDURES – o EVACUATION – Know the facilities evacuation plan and emergency procedures. For FIRE, MEDICAL AND CONFINED SPACE RESCUE. Post emergency phone numbers where crew members can find.

ACCIDENT PREVENTION – Discuss all of the hazards present, make crew aware that hazards change as the job progresses and that new hazards need to be discussed with all crew members. Take necessary steps to prevent accidents.

PERSONAL PROTECTION EQUIPMENT – All PPE should be examined on a daily bases to be certain that it is in useable shape. Additional PPE should be on hand in the event that it is needed. Foremen are responsible for making certain that the proper PPE is worn when needed, not only when required.

TAILBOARD TOPICS

HAZARD COMMUNICATIONS: • MSDS Books need to be in all truck • MSDS Book also by time clock and master copy is in the accounting office • Read MSDS sheet if PPE is in question • All containers must be labeled, even if one time use • See Safety Director is you have any questions

64 ELECTRICAL HAZARDS • Always make sure electric tools are properly grounded or double insulated. The double insulated tool must have an undamaged outer case and be clearly labeled as "double insulated" by the manufacturer. • Always check to be sure the grounding system is complete. Unless they are designated as double insulated, grounded power tools must be attached to a grounded service circuit. If there is any doubt about the grounding, test it! • Use heavy duty grounded extension cords. • Keep cords, tools and working/walking surfaces dry, keep your hands and feet dry as well. If you must work around water, connect to a Ground Fault Circuit Interrupter (GFCI) to automatically shut off the current if there is an abnormal current flow.

VEHICLE SAFETY • When backing up any ASGCO vehicle you must use a spotter. If no spotter is available, then you must first walk around the vehicle to be certain that you have the proper clearance. • Cell phones should not be used while driving a company vehicle. • A pre-trip walk around and checklist is now part of the mileage book. Be certain to complete that portion. • Report all accidents immediately to the Safety Director. • It is your responsibility to let ASGCO know if there is a problem with your license or if you received any type of ticket.

HOISTING/RIGGING/SLINGS • Inspect all come-alongs and slings prior to each use. • All hooks must have safety latches on. If there is not a safety latch, tag as “Out of Service”. • Do not use hooks alone for rigging, slings need to be used at all times. • Always use the middle of the hook, never use the tip for rigging. • Be certain that your come-along or sling is rated for your load.

CONFINED SPACES • Confined spaces can be killers. Know what the risks are and take appropriate measures to control them. • Be sure that air samples are taken before entry, and as frequently as required by the activities being conducted. • Provide ventilation into the space if required. • Use all personal protective equipment in accordance with the manufacturer’s directions. • If at any time, you do not feel that the confined space is safe, you have the right to leave that confined space. • Never attempt to go into the confined space to rescue a fellow employee.

FALL ARREST SYSTEMS Belt and Body Harness • Thoroughly inspect all nylon webbing on belt/body harnesses for frayed edges, broken fibers, burn marks, deterioration or other visible signs of damage. Do the same if the belt or body harness is constructed of other materials. Stitching should be intact and not torn

65 or loose. The belt or harness should be somewhat "soft" and flexible and not stiff from dirt or contaminants. • Check to see that buckles and "D" rings are not distorted or damaged. Look closely at all components for stress cracks, deformity, gouging, corrosion and sharp edges. Inspect connection points where the buckle or "D" ring is attached to the belt or body harness. Insure that no stitching is pulled and that the buckle or "D" ring is securely attached. • Inspect all rivets and grommets to be certain they are not deformed, and are securely fastened to the belt or body harness and cannot be pulled loose. • If you find any of these conditions during the inspection, do not use the equipment.

Lanyards:

• Completely check the entire length of the lanyard. looking for cuts, fraying, deterioration, knots, kinks, burns or visible signs of damage. Stitching should be intact and not torn or loose. Spliced ends must also be carefully examined for damage or deterioration. Check to see that the lanyard is somewhat "soft" and not stiff from dirt or contaminants. • If using a "shock absorber" type of lanyard, look for the "warning tag" which indicates that the lanyard has been exposed to a fall. • Snap hooks and eyes should not be distorted or bent. Inspect them for cracks, sharp edges, gouges or corrosion. Check to be sure the locking mechanism is operating properly and that there is no binding of the mechanism. • If using a self retracting lanyard (SRL), you must inspect the body of the mechanism for flaws to assure that all nuts, screws and rivets are installed and tight. Also check crimped ends or stitching for damage. Inspect the entire length of the SRL for any visible signs of defects. • Test the locking mechanism by pulling sharply on the cable end to be sure it locks immediately and firmly.

SAFETY RESPONSIBILITIES Safety is everyone’s responsibility! As an employee, you: • Learn to work safely and take all rules seriously • Recognize hazards and avoid them • Report all accidents, injuries and illness to your supervisor or the Safety Director immediately • Inspect tools before use to avoid injury • Wear all assigned personal protective equipment.

HAZARD AWARENESS Recognizing hazards and doing something about them s everyone’s responsibility. So when you begin a job ask yourself: • Do I have the right tools/equipment for the job? • Have I inspected my tools and equipment to make sure they are in good condition? • Is the work laid out to provide a safe completion of the job? • Are the materials I am using safe, or do I need additional PPE (safety glasses, gloves, hard hat, respirator) • Is there a safer way to accomplish the task? • Are all necessary equipment guards in place? • Are written procedures like lockout/tagout being followed?

66 SAFE LIFTING Your first lift is a mental lift. Think about the lift prior to actually doing it: Then get a firm grip on the load, keep it close, bend at the knees, use your legs to lift the load, and keep your spine in the natural position (with an arch in your lower back).

NEAR MISSES There is a danger in brushing off accidents that do not hurt, harm, or damage. When these accidents, or near misses, happen we should immediately run the red warning flag up the pole. a non-injury accident is a positive sign or symptom that something is wrong. Report each and every near miss incident to your foreman or Safety Director immediately in order to help prompt investigation and follow up actions that will reduce the potential for future near misses. Foremen rely on you to report these to them as they just can't see everything. If you are involved with or witness a near miss incident, remember that you or your co-worker may not get a second injury free chance. Do your part to help make the workplace safe for everyone involved.

HEARING PROTECTION Everyone needs to know the proper way to insert ear protection. For a reminder, read the packet that the ear protection comes in. To insert, roll ear plug into cylinder. Pull ear up and insert rolled plug. Hold ear up or put finger on plug until the ear plug is done expanding.

SLING SAFETY – INSPECT YOUR SLINGS Slings must be inspected prior to EACH use. Look for obvious abnormalities in the integrity of the material. Run your hands along the fabric and feel for irregularity such as tears, holes, snags and frayed areas. If your sling is exposed to sharp edges, broken and/or worn stitches may be evident. Most slings are made with a red warning string in the core of the material. If the sling is heavily worn, the warning string will show through. Also, check the fittings to make sure they are not distorted out of normal shape. If you find any abnormalities the sling MUST be taken out of service immediately.

LADDER SAFETY • Before using a ladder, inspect it for faults, such as broken rungs or rails. If it is an extension ladder, inspect the pulleys, ropes and locks for excessive wear. Also, check the footings and pads to make sure they still provide a non-skid surface. If any defect is found, the ladder should be tagged unsafe and taken out of service. If it cannot be fixed, make sure it is disposed of properly. • When setting up a ladder, make sure the ground it is set upon is level and stable. Do not set the ladder up on a muddy surface or you may find yourself falling over. Do not use bricks or other material to raise the height of the ladder. If it is not tall enough, you are using the wrong ladder. • The ladder should reach a minimum of three feet above the "point of support" and should be secured at this point. • When using extension ladders, abide by the 1:4 rule. When using a stepladder, make sure the folding cross braces are locked in the proper position before you step onto it. • Always face the ladder when ascending or descending, and have both hands free to grasp it securely. If you need tools, they should be carried in a tool belt or pulled up with a rope once you have reached your destination. • Remember the "3-Point Rule": At least two hands and one foot, or two feet and one hand, should be in contact with the ladder at all times. • Keep your body between the side rails of the ladder.

67 • Do not climb higher than the third rung from the top on straight or extension ladders or the second tread from the top on stepladders.

NEAR MISSES (2) The Same Things That Cause Accidents Cause Near Misses: • Unsafe acts, such as improper lifting; walking under an overhead load; cutting, grinding, or chipping without safety glasses; not using proper Personal Protective Equipment, etc. • Unsafe conditions, such as poorly maintained equipment, oil or grease on floors, welding leads that have been laid in walkways, trash and boxes that have been left in hallways, etc. • Hurrying and taking risks to get a project done faster, or to wrap up a job at quitting time. • Once a near miss occurs, report it immediately to the nearest foreman or supervisor. The potential for such incidents exists all over the workplace, so all employees-not just supervisors-- must help identify them. • If the near miss is a result of an unsafe condition, don't continue to work under that condition until the problem has been corrected and your supervisor gives the okay to proceed. • If the incident is a result of unsafe acts, be certain that everyone involved has been alerted to their actions before they continue with the job. Near Misses Are A Warning: Letting a near miss go unreported provides an opportunity for a serious accident to occur. Correcting these actions or conditions will enhance the safety within your facility and provide a better working environment for everyone involved. Don't let yourself or co- workers become statistics--report near misses to your supervisor.

THE BASICS OF SAFETY 1. Stay Alert 2. Wear the right clothes 3. Use the right tools 4. Learn to Lift 5. Don’t be a Prankster 6. Be Tidy 7. Reporting is important 8. Get First Aid immediately 9. Back your safety program 10. Never take a chance

TEN COMMANDMENTS OF SAFETY 1. Set Your Own Standards. Don't be influenced by others around you who are negative. If you fail to wear safety glasses because others don't, remember the blindness you may suffer will be yours alone to live with. 2. Operate Equipment Only if Qualified. Your supervisor may not realize you have never done the job before. You have the responsibility to let your supervisor know, so the necessary training can be provided. 3. Respect Machinery. If you put something in a machine's way, it will crush it, pinch it or cut it. Make sure all guards are in place. Never hurry beyond your ability to think and act 4. safely. Remember to de-energize the power first before placing your hands in a point of operation.

68 5. Use Your Own Initiative for Safety Protection. You are in the best position to see problems when they arise. Ask for the personal protective equipment or additional guidance you need. 6. Ask Questions. If you are uncertain, ask. Do not accept answers that contain, "I think, I assume, I guess." Be sure. 7. Use Care and Caution When Lifting. Most muscle and spinal injuries are from overstrain. Know your limits. Do not attempt to exceed them. The few minutes it takes to get help will prevent weeks of being off work and in pain. 8. Practice Good Housekeeping. Disorganized work areas are the breeding grounds for accidents. You may not be the only victim. Don't be a cause. 9. Wear Proper and Sensible Work Clothes. Wear sturdy and appropriate footwear. These should enclose the foot fully. Avoid 1oose clothing, dangling jewelry, and be sure that long hair is tied back and cannot become entangled in the machinery. 10. Practice Good Personal Cleanliness. Avoid touching eyes, face, and mouth with gloves or hands that are dirty. Wash well and use barrier creams when necessary. Most industrial rashes are the result of poor hygiene practices. 11. Be a Positive Part of the Safety Team. Willingly accept and follow safety rules. Encourage others to do so. Your attitude can play a major role in the prevention of accidents and injuries.

LIMITATIONS OF RESPIRATORS

1. Never enter a confined space with a cartridge-type respirator unless you know for sure that the space has been tested for oxygen content and toxic air contaminants, and that entry with this type of respirator is allowable and that entry has been approved. 2. Never work in toxic vapors for which the respirator cartridge was not intended. There are many different types and combinations of cartridges--each for a specific type of hazard that is described on the band surrounding the cartridge. Also be sure the cartridges are the type the manufacturer specifies for your respirator. In general, they are not interchangeable from one manufacture to another. Ask your supervisor if you have doubts about these factors. 3. Be sure your respirator fits your face properly. Most manufacturers provide at least three sizes of face pieces and one of them should fit you better than others. Your supervisor will help you select the proper size so that you get a good respirator fit. 4. Be sure to check the respirator seal by performing positive and negative pressure tests immediately prior to entering a contaminated area. Tighten the straps and move the respirator around if you can't get a good seal. Beards, mustaches and long sideburns usually prevent obtaining a good seal. 5. Never enter a confined space with a cartridge-type respirator unless you know for sure that the space has been tested for oxygen content and toxic air contaminants, and that entry with this type of respirator is allowable and that entry has been approved. 6. Never work in toxic vapors for which the respirator cartridge was not intended. There are many different types and combinations of cartridges--each for a specific type of hazard that is described on the band surrounding the cartridge. Also be sure the cartridges are the type the manufacturer specifies for your respirator. In general, they are not interchangeable from one manufacture to another. Ask your supervisor if you have doubts about these factors. 7. Be sure your respirator fits your face properly. Most manufacturers provide at least three sizes of face pieces and one of them should fit you better than others. Your supervisor will help you select the proper size so that you get a good respirator fit.

69 8. Be sure to check the respirator seal by performing positive and negative pressure tests immediately prior to entering a contaminated area. Tighten the straps and move the respirator around if you can't get a good seal. Beards, mustaches and long sideburns usually prevent obtaining a good seal.

GRINDERS

Do not stand directly in front of the grinder during start up, in case the wheel disintegrates as it reaches full speed. Allow the grinder to reach operating speed and then bring the item to be honed slowly and smoothly into contact with the wheel. Gradual application gives the wheel an opportunity to warm up and lessens the chance of breakage due to thermal stress.

Most grinding wheels are designed for face use only. The side of the wheel should not be used for grinding unless it is designed for that purpose.

All employees are required to wear the appropriate PPE when grinding. This includes but is not limited to, Safety glasses, appropriate gloves and grinding shields.

HALF MASK RESPIRATORS

Your respirator provides protection against breathing of airborne contaminants. ASGCO is responsible for our respirator program and will provide your with the proper type for the given exposure. ASGCO and you share the responsibility of making certain that your respirator is functioning as intended. Here are some general rules to help you care for and maintain your respirator:

• The disposable filter cartridges usually contain a chemical absorbent to trap contaminants. The filter cartridge should be replaced immediately if it becomes more difficult to inhale. It should also be changed if you begin to smell or taste the contaminant. • You should thoroughly inspect your respirator on a daily basis or before each usage. Examine the elastic headband(s) to assure it has not lost elasticity. Also check the headband for tears, frays, and loose strands. Take the cartridges off and examine the cartridge housing to make certain it is not cracked. Check the cartridge threads to ensure they are not stripped or damaged in any way. Check the facepiece for tears, cuts, or holes. Inspect the exhaust valves and intake valve to make certain they are not sticking or damaged. • Clean your respirator after each use. The cleaning process usually consists of washing, disinfecting, rinsing, and drying. You should refer to the manufacturer's suggestions for

• specifics. Most facepieces can be washed with warm water. Disinfecting with a disinfectant cleaner or germicidal detergent is a commonly acceptable practice. Rinsing should be done with water. Air drying is usually preferred as towel drying or heated quick drying may cause damage. • It is important to store your respirator properly. Your respirator should be protected from heat, sunlight, dust, and vapor contaminants. Storage in a sealed plastic bag is the preferred practice. Be careful not to cram the respirator in a tight space or store it in an awkward position as both of these practices may warp the respirator permanently and alter the fit.

70 • Do a "fit-check" often to make certain that you have a good seal. This can be done by covering the exhalation valve with your hand and gently exhaling into the facepiece. If air leaks out during gentle exhaling, the seal and facepiece should be checked by the Safety Director

EMPLOYEE RESPONSIBIITY TO SAFETY

• Listen and learn from any training. Be an active participant in learning a job skill or safety issue. • Ask for assistance if the training or instruction is not clear or you don't feel comfortable in performing the task correctly and safely. • Report unsafe acts and near misses immediately. Especially if the unsafe act is on going. This will help keep the workplace safe for everyone. • Address problems with the supervisor ASAP. BUT always try to give solutions to every problem. (You may understand more than the supervisor about the problem and how to fix it.) • Re-address issues with the supervisor on un-resolved topics discussed in the past. (The supervisor may have forgotten about those topics.) • Be an active member in the safety of the workplace. Participate in Safety Committee Meetings, Safety Meetings, and when trained on a safety issue.

HAND TOOL SAFETY

1. Use the right tool for the job. 2. Don’t use broken or damaged tools, dull cutting tools or screwdrivers with worn tips. 3. Cut in a direction away from your body. 4. Make sure your grip and footing are secure when using large tools. 5. Carry tools securely in a tool belt or box. Use a hoist to carry tools up a ladder. 6. Keep close track of tools when working at heights, falling tools are dangerous. 7. Pass tool to another person by the handle, never toss it. 8. Use the right PPE for the job. 9. Never carry sharp or pointed tools in your pocket. 10. When possible, select ergonomic tools. 11. Be on the lookout for signs of repetitive stress. 12. Always keep your tools in top condition. 13. Store tools properly when you are done working.

PREVENTING HEAT STRESS

• Drink plenty of fluids – 5-7 ounces every 20 minutes • Give your body time to adjust to the heat (takes most workers 3-5 days) • Choose proper clothing – wear light colors that are made from a lightweight breathable material • Try to perform your most strenuous activities in the early morning/early evening • Use work/rest cycles when possible to give your body time to recover • Eat properly, saving biggest meal until evening

71 HOW LOUD IS LOUD

20db a faint whisper 30-40db quiet pleasant sounds, a bird chirping 40-50db quiet to normal office sounds 50-60db normal conversation heavy machinery, electric motors, garbage disposal, city 70-90db traffic jack hammer, power saw, motorcycle, lawn mower, rock 100-120db music 140+db nearly jet engine, gun shot (this level causes pain)

Hearing protection is needed for any db over 85

SLING SAFETY

Each day before being used, all slings, fastenings and attachments must be inspected for damage or defects. Any damaged or defective sling must be immediately removed from service. Some general safe operating practices for slings of all types are:

• Slings, which are damaged or defective, shall not be used. • Slings shall not be shortened with knots, bolts or other makeshift devices. • Sling legs shall not be kinked. • Slings shall not be loaded in excess of their rated capacities. • Slings used in a basket hitch shall have the load balanced to prevent slippage. • Slings shall be securely attached to their loads. • Slings shall be padded or protected from all sharp edges of their loads. • Suspended loads shall be kept clear of all obstructions. • All persons shall be kept clear of suspended loads or those about to be lifted. • Hands or fingers shall not be placed between the sling and its load while the sling is being tightened around the load. • Shock loading is prohibited. • A sling shall not be pulled from under a load when the load is resting on the sling.

Synthetic web slings shall be removed from service if one or more of the following conditions are present:

• Acid or caustic burns; melting or charring of any part of the sling surface. • Snags, punctures, tears or cuts. • Broken or worn stitches. • Distortion of fittings.

LOCKOUT/TAGOUT 72 Six steps for Lockout/Tagout

1. Notify all "affected employees" that the equipment will be shut down.

2. Shut down the equipment by normal stopping procedures.

3. "Isolate" all the equipment's energy sources.

4. Lock out and/or tag out the energy isolating devices with assigned, individual locks.

5. Release or restrain any stored energy by grounding, blocking, bleeding down, etc.

6. Assure that no personnel are exposed, then test the equipment to assure that it will not operate.

Four steps to re-energize

1. Check to Assure that all employees have been safely positioned or removed from the area.

2. Verify that equipment controls are in neutral.

3. Remove lockout devices and/or tags and re-energize the machine or equipment.

4. Notify affected employees that servicing is complete and the equipment is ready for use.

PREVENTING WELDING FLASHBACK

There are several things you can do to help prevent flashbacks, fires and explosions:

1. If using acetylene, keep the pressure below 15 pounds.

2. Purge your hoses before lighting the torch.

3. Never light your torch with a mixture of fuel and oxygen. After purging the lines, light the torch with only the fuel gas valve open.

4. Check valves should be installed on both torch inlets and operating properly. Check valves can stop the reverse flow of gases, but will not prevent flashbacks.

5. To prevent flashbacks, flashback arrestors must be installed on the outlets of both regulators, and/or torch inlets.

RESPIRATOR FIT TEST

Negative Pressure Test:

• Don the respirator according to the manufacturer's instructions. • Cover and seal the filter cartridge(s) using the palm of your hand(s). • Gently inhale through the respirator and hold your breath approximately 10 seconds. • The respirator should collapse slightly. Check, feel and listen for leaks around the face piece. 73 • If there are no leaks, it can be reasonably assumed that there is a good seal and the respirator is not leaking.

Positive Pressure Test:

• Cover the exhalation valve with the palm of your hand. • Gently exhale but do not break the seal around the face piece. • The respirator should expand slightly with a slight positive pressure increase in the face piece. • If there are no leaks and no loss of pressure, it can be reasonably assumed that there is a good seal.

The only way to take full advantage of any negative pressure respirator you use is to be sure that you have a good facial seal. Conducting a fit check prior to entering a contaminated atmosphere provides that assurance. It only takes a minute, and it can save your life.

CONFINED SPACE (2)

Some numbers:

Fifty four % of the people exposed to oxygen deficient conditions died.

• For every fire within a confined space, one person died.

• Fire at the point of entry caused multiple fatalities in a single event.

• Cave-ins left 100 % of the victims dead.

74 SECTION 18 OVERHEAD CRANES

Overhead cranes may not be modified and re-rated unless the modifications and the supporting structure are checked thoroughly for the new rated load by a qualified engineer or the equipment manufacturer.

The rated loads of the crane must be plainly marked on each side of the crane. If the crane has more than one hoisting unit, each hoisting unit must have its rated load marked on it or on its load block. Always know the rated capacity of the crane prior to using it.

Only employees selected by the employer as being qualified to operate a crane are permitted to operate the crane.

Guards on overhead cranes must be inspected closely to make certain that they do not run near enough to other parts to make fouling or chafing possible. If they do, guards must be installed to prevent this condition.

All wiring and equipment on overhead cranes shall comply with OSHA standards. All hoisting equipment, cables, chains, ropes, and hooks must be inspected prior to use for wear and taken out of service if any condition exists that would render the equipment unsafe. Personnel designated by ASGCO or the Lightweight Supervisor must do Pre-use Inspection, prior to that day’s usage. Inspections will be documented with date of inspection, and name of person who performed the inspection, and kept on file for a period of 5 years.

If during the pre-use inspection any portion of the crane has a deficiency, it must be reported to the Supervisor immediately. Continued use may be permitted if authorized by the supervisor in notes on the pre-use inspection form.

75 ASGCO Manufacturing Inc. Pre-use Inspection Overhead Crane - Lightweights

Inspected By:

Date:

Requirements

A. Operators must perform a pre-use inspection prior to use.

B. Any equipment found to be unsatisfactory must be removed from service.

C. Operators must notify the Lightweight Supervisor, of any deficiencies. Supervisor will submit service request. Continued use may be permitted if authorized by the supervisor in notes/comments.

D. Completed checklists must be kept on file for a minimum of 5 years.

# Equipment Description and Inspection Criteria Check if Satisfactory/Comment if Unsatisfactory Operating mechanism – Check for proper operation and adjustment and note any unusual 1 sounds or noise due to chain binding or bearing squeal Limit switch – Test upper-limit switch. If the hoist has a lower-limit switch, test it with 2 no load before lowering any load that could bring the lower-limit switch into operation. 3 General Wear and Tear – Check for signs of general wear and tear 4 Hoist braking – Confirm that the brakes are functioning Hooks & hook latches – Check for: excessive throat opening, bent or twisted elements, and 5 sticky swivel or rough surfaces. Check latches (if present) for damaged spring, bent or missing hardware. Check self-locking hooks (if present) for proper operation and locking. Hoist ropes & end connections – Check for rope distortions such as kinking, crushing, 6 upstanding, birdcaging, main strand displacement or core protrusion; corrosion, broken or cut strands. Note number, distribution, and type of visible broken wires.

7 Spooling – Check ropes for proper spooling on drum(s) and sheave(s) 8 Festoon or trolley wiring – When applicable, ensure wire collects and moves freely

9 Bridge – Look for loose items or obstructions (visual inspection from floor level only)

Notes/comments:

76

SECTION 19 PERSONAL PROTECTIVE EQUIPMENT

A. INTRODUCTION Personal protective equipment should not be used as a substitute for engineering, work practices or administrative controls. All required PPE will be provided to each employee at no cost to the employee. It should be used in conjunction with these controls to provide for employee safety and health in the workplace. Personal protective equipment includes all clothing and other work accessories designed to create a barrier against workplace hazards. The basic element of our PPE program is an in-depth signed, dated and documented evaluation of the equipment and the hazards (Hazard Assessment)of a particular job to set standard operating procedures for personnel, and then train employees on the protective limitations of PPE and its proper use and maintenance. Employees must be aware that the equipment does not eliminate the hazard. ASGCO Manufacturing is responsible for re-evaluating all hazards on at least an annual bases. If exposures do change then the company is responsible for providing different Personal Protective Equipment to all employees. All PPE must be properly fitted and maintained in a clean and serviceable condition. Job Safety Analysis will be completed on each task that requires PPE. ASGCO is responsible for purchasing every employees PPE, but if at any time an employee purchases their own PPE, it must be inspected by the Safety Director to assure its adequacy, maintenance and sanitation. In addition, service personnel and selected other personnel are supplied uniforms for everyday wear. Uniforms must be worn, by those that are supplied them, when working, either on site or at a customer’s site. Shirts must be kept tucked in at all times and general appearance must be maintained. All training documentation will be kept on file in the Safety Director’s Office. When an employee completes training it becomes their responsibility to ask questions or get clarification if the employee is not clear on any issue.

ASGCO Manufacturing will maintain records for all employee exposure and all environmental readings done according to OSHA regulations.

If any PPE is found to be defective in any manner, it must be taken out of service immediately. Defective PPE must either be tagged out of service if it repairable or destroyed and discarded at once. Under no circumstances should defective PPE be used.

B. TRAINING Before doing work requiring use of personal protective equipment, employees must be trained to know when personal protective equipment is necessary; what type is necessary; how it is to be worn; and what its limitations are, as well as know its proper care, maintenance, useful life and disposal. Training will be done on initial hire and annually thereafter, or if there are changes in PPE or work processes. Re-training will occur when deficiencies in any PPE training are noted, either in an individual or in a process.

Each employee using PPE will be certified in writing that training has been carried out and that the employee understands it. Each certification will contain the name of the employee trained, the date(s) of training and identify the subject certified. (APPENDIX H-PPE Certification).

C. EYE AND FACE PROTECTION Eye and face protection equipment is required where there is a reasonable probability of preventing injury when such equipment is used. We will provide a type of protector suitable for

77 the work that you are doing. All PPE must be worn while engaging in that task. This also applies to any visitors that may be exposed.

We will provide your PPE in any position that there is potential for injury to the eyes or face from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, potentially injurious light radiation or a combination of these. All PPE of this type will meet the following requirements:

1) Provide adequate protection against the particular hazard. 2) Be reasonably comfortable when worn under designated conditions. 3) Fit snugly without interfering with the movements or vision of the wearer. 4) Be durable. 5) Be capable of being disinfected. 6) Be easily cleanable and kept clean and in good repair.

Each protector will be distinctly marked to facilitate identification only of the manufacturer.

It is essential that the lenses of eye protectors be kept clean. Continuous vision through dirty lenses can cause eye strain. Daily inspection and cleaning of the eye protection with soap and hot water or with a cleaning solution and tissue is recommended.

Pitted lenses can also be a source of reduced vision. They should be replaced. All eye protection needs to be cleaned and disinfected regularly. If you need assistance with this procedure, please see your supervisor.

Whenever grinding is done, on the job site or on premises, employees are required to wear safety glasses, appropriate gloves and grinding shields.

D. HEAD PROTECTION Where conditions exist that the hazards can not be control, it will be required of our employees to wear head protection. These areas will have signage posted stating “HARD HAT AREA”.

All head protection will be ANSI approved and will either be class A, B or C, whichever is appropriate for the hazard it is to protect against. Each hard hat wearer should get appropriate direction on how to adjust and replace portion of the hat.

When the headband is adjusted to the right size, it provides sufficient clearance between the shell and headband. The removable or replaceable sweatband should cover at least the forehead portion of the headband. Any portion that comes into contact with the wearer’s head must not be irritating to normal skin. The manufacturer of the hard hat should be consulted with regard to paint or cleaning materials for their helmets.

All components, shells, suspensions, headbands, sweatband and any accessories should be inspected daily for signs of dents, cracks, penetration or any other damage that might reduce the degree of safety originally provided. If damage is suspected, helmets should be replaced immediately. Each helmet will be marked, inside the shell, with the type. Helmets should be replaced as indicated by the manufacturer.

At no time, is your hard hat to be stored or carried on the rear-window shelf of an automobile, since sunlight and extreme heat may adversely affect the degree of protection.

78 Hard hats are marked with the month and year that they were manufactured, and the effectiveness of the hard hat is compromised 5 years from the date stamped in the inside of the hard hat. It is the employees’ responsibility to be certain that their hard hats are still viable.

When you need to exchange your hard hat for one that has a more current expiration date, please see you supervisor.

If working in the underground mining environment, hard hats colors are determined by the amount of experience of that particular employee and set by the state in which they are working. All employees with one year or less experience in an underground mine will wear hard hats distinctively different in color.

E. FOOT PROTECTION Certain areas will require the use of safety shoes, these areas include but are not limited to Fab Shop, Lightweight Division, Service Division, Manufactured parts, Shipping and Receiving. These shoes must be sturdy and have an impact-resistant toe. If safety shoes are required, they must be worn at all times in the work place.

F. ELECTRICAL PROTECTIVE DEVICES These devices include insulation blankets, matting, covers, line hose, and gloves. All of these items need to be cleaned and maintained per the manufacturer instructions. If you have any questions or concerns, please see your supervisor.

G. HAND PROTECTION If your position exposes you to hazards such as skin absorption of harmful substances, severe cuts or lacerations, severe abrasions, punctures, chemical burns, thermal burns or harmful temperature extremes, you will be required to wear hand protection. The company, along with your help will determine what type of protection you require. Before any glove is purchased documentation will be reviewed to determine if that specific glove will protect you from the hazards anticipated. Gloves will be selected to fit the job and the individual, but all employees should know the limitations of the gloves worn. Proper footwear must be worn correctly, at all times, they must fit properly and be correctly laced.

H. HEARING PROTECTION Noise levels are measured using a sound level meter and records of levels measured are kept in the Office of the Safety Director. Engineering controls will be used to reduce excessive noise levels. When engineering controls are not feasible, administrative controls (i.e. worker rotation) will be used to minimize individual employee exposure to excessive noise level. An ongoing prevention health program will be utilized to educate employees on safe levels of noise, exposure, effects of noise on their health and use of personal protective equipment. Approved hearing protection equipment (noise attenuating devised) will be available to every employee working in the areas, at no cost to the employee, where continuous noise levels exceed 85 decibels (dBa). Annual and random noise monitoring will be done by the Safety Director and noise levels will be recorded. Noise exposure monitoring is available to all employees whose exposures equal or exceed an 8 hour time weighted average of 85 decibels or more. Any results are available to all employees at any time. Results are kept in the office of the Safety Director.

To be effective ear protection must be properly fitted and employees will be instructed in their use and care. The Safety Director will be responsible for evaluating the type of hearing protection used for the specific environment in which it is used. Depending on the type of noise encountered, you may be required to wear hearing protection. If any level is above 85dbA, 79 hearing protection will be required. If the type of protection that is chosen is to be preformed or molded, this will be done by a professional. Each employee will be instructed as to how to wear their hearing protection and its limitations.

Upon hiring, each employee is required, as part of the pre-employment physical to have a baseline audiogram completed. Testing for the baseline audiogram will be done after at least 14 hours without exposure to workplace noise. If this is not possible, employee may use hearing protection to meet this requirement, and will be notified to avoid all high level noise areas. Results of that test will be shared with the employee and be kept in a secure cabinet in the personnel office, as required by regulation.

Annually, after obtaining the above baseline audiogram, each employee who is exposed at or above an 8 hour time weighted average of 85 decibels will have an audiogram completed. The new audiogram will be compared to the employee’s baseline audiogram to determine if the audiogram is valid and if a standard threshold shift has occurred. If a comparison of the annual audiogram to the baseline indicates a shift, the employee will be informed of this in writing at least 21 days after this determination. All comparison will be done by a certified person.

In addition to the above, if a shift has occurred, the use of hearing protection will be re-evaluated and if necessary the employee will be refitted with adequate hearing protection. If necessary, a medical evaluation will be completed.

I. FALL ARREST SYSTEMS All ASGCO Employees will tie off when working at a height of 4 feet or more, or if there is a danger of falling onto machinery or other dangerous objects. There are no exception to this rule. We do not use nor do we supply safety belts. Harnesses are what we use as our fall protection PPE.

Different types of personal fall arrest systems are chosen depending of the nature of the work and the specific conditions present in the area where the work will take place.

ASGCO employees will not work in a controlled access zone. If conventional fall protection can not be used, our employees are required to notify the Safety Director immediately.

Basic types of personal fall arrest systems that ASGCO uses include:

1. Personal Fall Arrest system – A system used to stop a fall once it has begun. This system shall include an anchorage, full body harness, lanyard, locking snaphooks, lifeline and anchorage connector, and it may include a descent control device. 2. Personal Fall Protection Systems for Climbing Activities – A system that protects the employee while he/she is climbing. This system anchors at a point that usually adjusts and moves with the climber.

Equipment anchorage, tie off and use.

Anchoring your fall arrest system is critical. The selection of the anchoring point should be made carefully and when the employee is uncertain about the anchoring point he/she is expected to consult with a supervisor. Anchoring points must be permanent, fixed objects that are rated to hold at least 5,000 lbs of force. There are other criteria necessary for an adequate anchorage point that shall be covered in training.

80

When tying off, the employee shall tie off at such a location where there are no obstacles in the potential path of a fall and shall allow no more than 4 feet of free-falling distance. In addition to the free falling distance, the employee shall know and account for the additional deceleration distance of the fall arrest system they are using. The employee shall complete the anchoring tie off and equipment tie off procedures that are specified by the fall arrest system manufacturer PRIOR to getting into a position where he/she could fall.

Body Belts and Harnesses

Only full-body harnesses that meet or exceed OSHA regulations may be use, if you are in doubt as to the OSHA regulations or job requirements, ask your supervisor. All equipment manufacturer’s procedures shall be met. The employee must use the following procedure to put their full-body harness on: 1. Inspect your full-body harness before putting it on 2. Hold the harness by the back D-ring and shake the straps into place. 3. Release buckled straps and slip them over your shoulders with the D-ring in back. 4. Pull the leg strap between your legs and connect it to the opposite end. 5. Waist strap should be tight but not binding. 6. Connect chest strap and position it in the middle of your chest. 7. Check that the harness is snug but allows full movement.

Equipment Care and Inspection

Keeping equipment in good working order is essential. Follow manufacturer’s instructions and training protocols for equipment maintenance, cleaning and storage. Equipment that has been subject to a fall must be discarded. Body harnesses must be carefully inspected prior to each use. Any defective equipment must be identified, taken out of service and replaced at once.

Rescue After a Fall

In the event that a person falls and their fall arrest system engages, call 911. After any type of fall your harness is required to be replaced

J. ELECTRIC CAP LAMPS Only electric cap lamps which meet the following requirements are permitted to be used in underground mining. a. Cap lamps that were fabricated, assembled, or built under an approval, or any extension thereof, issued by the Bureau of Mines or MSHA and maintained in a permissible condition. b. Those lamps on an approved list which is available in the office of the Safety Director, on the MSHA web site or at any MSHA district office. c. Any unmodified cap lamp bearing the Bureau of Mines approval number.

All cap lamps will be complete units, durable in construction, practical in operation and suitable for the conditions of underground service. They must be approved for use by MSHA, kept in permissible condition and not altered in any way.

K. RESPIRATORY EQUIPMENT In the event that the dust concentration or any other airborne contaminant is above permissible levels, recorded by the customer (mine owner), ASGCO employees must use the required 81 respiratory equipment supplied to that employee. If a question arises about the dust concentration, other airborne contaminant, or proper PPE to be used, the onsite Safety Director will be notified as well as the ASGCO Safety Director. At any time, an ASGCO employee may request to see the record of sampling done by the customer.

Self Contained Self Rescuer: A Self Contained Self Rescuer (SCSR) is a required piece of PPE when working in an underground mine. ASGCO will issue to each employee that is required to work underground an approved SCSR. This piece of PPE, must be worn at all times while underground, must be a wearable self rescuer and positioned where it is within arms reach at all times. The unit must be designed to be used for escape purposes and must be MSHA/NIOSH certified as a 1 hour and 10 minute SCSR when tested according to a regulated workload schedule. Individual issued a SCSR must maintain the SCSR is operable condition

Each employee must receive training on the SCSR that they are issued.

Where the wearing or carrying of the SCSR is hazardous to the employee, it will be placed in a readily accessible location not more than 25 feet from the employee.

After each time a SCSR is worn or carried by an employee the device will be inspected for damage and for the integrity of its seal. Any SCSR which has a broken seal or is damaged in any way will be removed from service immediately. This device must be tested every 90 days by a trained employee. Testing will be done by weighing each device on a certified scale. Any device that weighs more than 10 grams over its original weight will be removed from service immediately. All SCSRs will be tested according the MSHA/NIOSH standards and if test requirements are not met will be removed from service. Testers will sign and date the proper sheet after each test and notes of any corrective action will be included. Signed sheet will be kept by the owner of the SCSR for at least 6 months or until the device is replaced, whichever comes first.

All SCSR’s that are removed from service following an inspection may only be repaired by a person trained to perform this task.

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SELF CONTAINED SELF RESCUE INSPECTIONS TYPE OF SCSR:______SERIAL NUMBER: ______

Inspected by and date Pass(P) Repair Needed or comments Include initials and signature Fail(F)

L. PORTABLE GAS DETECTORS Any ASGCO employee which works in an environment which a hazardous gas may be present will have with them a portable gas detector which has the capability of monitoring the atmosphere for the hazardous gas. Each detector must be maintained according to the owner’s manual of that detector. Each employee will be trained on the monitor that they are using. Monitors must meet MSHA, OSHA or ANSI standards, which ever applies; must be bumped prior to use and calibrated as directed by the manufacturer, but no less than every 30 days. Only monitors approved for use in the atmosphere in which they are being used may be used. If there are any questions or concerns about a monitor, ask your supervisor, the Service Manager or the Safety Director. When working in underground mines employees will have gas detectors appropriate for each type of gas that may be encountered at the mines served. These gas detectors must measure concentrations of methane from 0.0 percent to 100 percent of volume, oxygen from 0.0 percent to at least 20 percent of volume, and carbon monoxide from 0.0 parts per million to at least 9,999 parts per million. For underground mining purposes, any gas detection system approved by MSHA will contain a certification plate or label. Only those devices with this plate/label are approved for use by any ASGCO Manufacturing, Inc. employee.

All gas detection systems will: 1. Be rugged in design 2. Where applicable be OSHA/ANSI/MSHA approved 3. Have enclosures equipped with a lock or seal which has been approved by MSHA. 4. Have components of the system that are readily exchangeable. 5. Be “fail safe” 6. Be capable of continuous sampling. 7. Contain an automatic warning device. 8. Have filters the prevent dust and moisture from entering. 83

SECTION 20 POWER TOOLS

Any employee using a power tool must be properly trained on the specific tool. This is the job of the Service Vice President, Service Manager and Job Foreman. Prior to use each tool must be inspected for obstructions or defects. It is the responsible of the operator to be certain that the tool is safe to use. At no time should a tool be used if the cord is in any way damaged. Any defective or damaged tool must be tagged, “OUT OF SERVICE” and taken out of service immediately. It must then be placed in a separate area from usable tools. When using a power tool any necessary Personal Protective Equipment must be worn while operating that tool.

These rules apply to all power tools, but especially important when handling portable saws, drills and power screw drivers.

1. Check your equipment before you use it. 2. All grinders, saws and similar equipment must be equipped with appropriate safety guards. Guards are not to be removed, except to service the tool. Power tools should not be used without the correct shield, guard or attachment, which has been recommended by the manufacturer. 3. Portable saws must be equipped with guards, above and below the base shoe. Guards should be checked periodically and before each use to assure they are not wedged up, thus leaving the lower portion of the blade unguarded. 4. All rotating, or moving parts of equipment should be guarded to prevent physical contact. 5. All cord connected, electrical operated tools and equipment must be grounded, and where appropriate be equipped with GFCIs. 6. Effective guards must be in place over belts, pulleys, chains, sprockets, on equipment such air compressors, etc. 7. If portable fans are provided they must be equipped with full guards and screens with openings one half inch or less. 8. Power tools are either battery operated or wired. If battery operated, do not under estimate their power. Remember that a battery pack contains toxic chemicals and emits a low voltage electric current. Never drop or incinerate the battery pack or a tool with a self contained power source. 9. Hard wired equipment can be portable or fixed. Typically used with extension cords, the more powerful hard wired equipment presents s double safety problem: the actual equipment plus its electrical power source. 10. Pneumatic and hydraulic hoses on power rated tools should be checked regularly for deterioration or damage. 11. All power tools should be stored properly, either on site or in vehicles. 12. When grinding an employee is required to wear, a face shield, safety glasses and hearing protection. An employee may wear protective gloves but only if they do not interfere with the grinding process or if they do not make the work of grinding more hazardous.

HAND HELD TOOLS – MINING INDUSTRY

84 Any hand held tool used underground must have controls that require constant hand or finger pressure to operate. If any tools used by ASGCO employees has a trigger lock – it is not to be engaged while underground.

SECTION 21 RESPIRATORY PROTECTION PROGRAM

A. INTRODUCTION The object of this chapter is to establish a procedure that ensures employee protection from respiratory hazards through the proper use of respirators and engineering control. When on the job site, employees need to be certain that proper respirators are used and rules of the job site adhered to at all times. If in doubt about the respirator or the environmental hazards, contact the customers/on-site Safety Director. Requirements set forth by this policy and any PPE required under this policy are supplied by ASGCO and are at no cost to the employee.

The Service Manger, on-site foreman and Safety Director are all responsible for respiratory protection program compliance and the purchase of proper equipment to ensure respiratory safety. Work sites will be re-evaluated on ongoing bases to determine if current protection is adequate. Spot checks of respirator and cartridges will be done on site and on ASGCO property by the Safety Director and Crew Foremen. If at any time an employee detects or breakthrough or resistance, that employee is to lease the area immediately, wash and change cartridges as needed.

ASGCO employees will not work in IDLH atmospheres at any time. If the employees believes that they are in an atmosphere that is highly dangerous, their foreman and the Safety Director must be notified immediately.

B. PROCEDURES Respirators will be selected by the Service Manager, on-site foreman or Safety Director based on hazards to which the employee is exposed. The respirators and filters must be NIOSH approved and meet all government requirements.

Specific customer work sites require the use of respirators. When work orders are received by crew, if a respirator is required, the type of respirator and type of filter needed will be noted on the work order. If there is a question as to requirements, the Safety Director will contact the customer to receive updated information as to the use and type of respirator required. These are mandatory requirements and must NEVER be overlooked or ignored. The Safety Director is responsible for contacting all customers that have a respirator requirement on an annual base, for the purpose of obtaining updated information on requirements. . OSHA regulations state that respirators should NOT be worn when conditions prevent a good face seal. These conditions include: beards, sideburns and skull cap that projects under the face piece. Mustaches and sideburns should be trimmed in such a manner as not to touch the internal or external sealing edge of the respirator. Respirators will be assigned to individual workers.

Employee Responsibilities 1. Attend annual training on ASGCO procedures for respirators 2. Properly clean and store respirators. Respirators must be cleaned after each use by the employee.

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3. Inspect respirator prior to each use. If there are missing, defective, or worn parts immediate let foreman, Service Manager, or Safety Director know, so that situation can be corrected immediately. 4. Keep respirator PFT and fit test up to date. 5. Changing or requesting additional cartridges. 6. Immediately informing your foreman if you detect a break-through or resistance.

C. TRAINING Each employee will be trained on an annual base and must demonstrate knowledge of at least the following:

1. Why respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator. 2. What the limitations and capabilities of the respirator are. 3. How to use the respirator effectively in an emergency situation, including situations in which the respirator malfunctions. 4. How to inspect, put on and remove, use and check the seals of the respirator. 5. What the procedures are for maintenance and storage of the respirator. 6. How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators.

Training is done on initial hire, if type of Respirator changes and at least annually for all employees. Retraining will also occur if employee is noted in incorrect use, lack of use, lack of understanding, lack of skill or if for any other reason noted by foreman, managers or Safety director. Each employee will have a PFT and fit test (Qualitative or Quantitative) done by a medically qualified individual. Testing is done upon initial hire, annually thereafter or if type of respirator is changed. Testing will be done on ASGCO time and during normal business hours, will be convenient, understandable and confidential. Results will be discussed in a confidential manner with the employee being able to ask questions and discuss results in a private atmosphere. ASGCO is required to establish and retain all written information regarding the medical evaluation and fit testing. These medical records are kept in a separate, locked file cabinet in the office of the Safety Director, as required by OSHA regulations. Training is always done at no cost to the employee and will be done on company time.

No employee is permitted to work on a site that requires the use of a respirator or wear a respirator prior to the above testing being done and being medically cleared to wear that specific respirator.

D. EMPLOYEE INPUT Due to the fact that ASGCO is requiring the employee to use a respirator, your input as to fit, selection, use and maintenance is important. In addition to this, your input is important in order for ASGCO to verify our written program effectiveness. If any employee has any comments or concerns, the Safety Director needs to know about them as soon as possible. ASGCO has an open door policy and employees are encouraged to use it.

E. RESPIRATORY EQUIPMENT UNDERGROUND MINING In the event that the dust concentration or any other airborne contaminant is above permissible levels, recorded by the customer (mine owner), ASGCO employees must use the required respiratory equipment supplied to that employee. If a question arises about the dust concentration, other airborne contaminant, or proper PPE to be used, the onsite Safety Director 86 will be notified as well as the ASGCO Safety Director. At any time, an ASGCO employee may request to see the record of sampling done by the customer.

Self Contained Self Rescuer: A Self Contained Self Rescuer (SCSR) is a required piece of PPE when working in an underground mine. ASGCO will issue to each employee that is required to work underground an approved SCSR. This piece of PPE, must be worn at all times while underground, must be a wearable self rescuer and positioned where it is within arms reach at all times. The unit must be designed to be used for escape purposes and must be MSHA/NIOSH certified as a 1 hour and 10 minute SCSR when tested according to a regulated workload schedule. Individual issued a SCSR must maintain the SCSR is operable condition

Each employee must receive training on the SCSR that they are issued.

Where the wearing or carrying of the SCSR is hazardous to the employee, it will be placed in a readily accessible location not more than 25 feet from the employee.

After each time a SCSR is worn or carried by an employee the device will be inspected for damage and for the integrity of its seal. Any SCSR which has a broken seal or is damaged in any way will be removed from service immediately. This device must be tested every 90 days by a trained employee. Testing will be done by weighing each device on a certified scale. Any device that weighs more than 10 grams over its original weight will be removed from service immediately. All SCSRs will be tested according the MSHA/NIOSH standards and if test requirements are not met will be removed from service. Testers will sign and date the proper sheet after each test and notes of any corrective action will be included. Signed sheet will be kept by the owner of the SCSR for at least 6 months or until the device is replaced, whichever comes first.

All SCSR’s that are removed from service following an inspection may only be repaired by a person trained to perform this task.

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SECTION 22 SAFETY TRAINING

A. INTRODUCTION We require that all employees, participating guests (subcontractors) and visitors follow appropriate health and safety practices. Supervisors and managers are responsible for ensuring that employees and guests under their supervision follow these practices or receive training so they are fully informed about possible occupational health hazards and know how to work safely.

All employees shall receive training about safe work practices. A separate training program is in place for our on premises Fabrication Shop. Training will include a health and safety orientation for new employees plus any additional training specific to the nature of hazards on the job. Employees must complete this training before they can work unsupervised. All new employees must attend the new employee orientation within the first month of employment.

OSHA and other federal regulations spell out several specific health and safety training requirements for special hazards. These include but are not limited to: Hazard Communication, Personal Protective Equipment, Respirator use (were applicable), confined space hazards, Lockout/Tagout, Bloodborne Pathogens, Hazard Communication, Emergency Procedures, Machine Guarding, and certification for using material in moving equipment such as forklifts. Employees who do hazardous work, such as working with high voltage power supplies or work in confined spaces are required to have CPR and First Aid Certification.

Managers and supervisors should identify needs to the job classifications for which they are responsible.

On the job training is the responsibility of the job foreman. This includes information on procedural changes or system modifications that impact safety.

On an annual basis, the Safety Director will develop a schedule that will consist of recognized needs (as defined by foreman and managers) and mandatory (regulatory) topics. The training will be consistent between all locations.

The Safety Director will provide scheduled health and safety training courses, technical assistance on training needs, and resources to help supervisors fulfill their training responsibilities. Educational resources such as fact sheets, hazard summaries and other written material, as well as, videos and slide shows, are available from the from the Safety Director

In addition all employees will be trained on how to recognize a hazard, how to do a risk assessment on the job site and how to minimize a hazard using engineering control, exposure controls or what PPE is necessary.

Foreman will be responsible for doing any additional training should the conditions at a work site change or if there is new equipment or new PPE on the job that the crew has not been trained on. Foreman will then pass this information onto the Safety Director so that this can be incorporated into the annual training.

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All health and safety training must be documented. Participants must “sign-in”(APPENDIX N- Training sign in sheet). A copy of this information should be kept in the individuals training file and on file with the Safety director

ADDITIONAL TRAINING REQUIREMENTS:

Lockout/Tagout training subjects:

• Recognition of hazardous energy source • Steps for isolation and control • Effected personnel • Authorized personnel • Limitations of Tagout • Retraining requirements • Annual certification • Types of energy (electrical, hydraulic, tension, gravity, etc) • Types of equipment needing lockout/tagout • OSHA Compliant DVD with quiz • ASGCO Lockout/Tagout Devices

When training needs change due to change in exposure or environment, new training will be conducted. Any employee who is noted for lack of use, improper use, lack of skill or lack of understanding in any area, including use of PPE, will be retrained immediately. Safety Director must be notified of any of these items listed above immediately.

B. TRAINING FOR SURFACE MINE SITE All new miners must receive at least 24 hours of new miner training. This will be done by an independent party off site. This training will be done prior to visiting any mine site. All employees must receive all customers onsite (site specific) training prior to entering that worksite. After the initial new miners training of 24 hours, all employees who work on or visit a mine site must receive 8 hours of training, done annually.

C. TRAINING FOR UNDERGROUND MINE SITE Until the time when ASGCO Manufacturing, Inc, is in the position to conduct either new underground miner training for annual refresher for underground miner training, all ASGCO employees must receive this training from a qualified MSHA trainer. The ASGCO Safety Director must approve the trainer being used, and must receive a copy of all training documentation. New miner training must be done prior to entering any underground mine. Annual refresher training must be completed prior to the last day of the month of the expiration date entered on the individual’s 5000-23.

Part 48 Training will consist of: 1. Hazard communication 2. Rights and duties of miners 3. Self rescue and respiratory devices 4. Entering and leaving mine 89 5. Work environment 6. Escaping/evacuating mine 7. Barricading 8. Roof/ground controls 9. Health 10. Hazard Recognition 11. Electrical hazards 12. First aid 13. Safe operating procedures 14. Haulage instruction/awareness 15. Communication systems 16. Explosives 17. Mine gases/Atmospheric Hazards 18. Site specific training, as required by MSHA and Customers site

90 SECTION 23 URETHANE BLADE POURING PROCESS

A. INTRODUCTION The equipment used in creating our own urethane scalper blades is from Trico Poly Systems and is highly specialized equipment. No employee, who has not been fully trained, is permitted to participate in making blades. Any and all servicing of this equipment will only be done by authorized personnel. Each employee operating this equipment must read and understand the manual for all of the components of the machine. The machinery used is a three part machinery, that consist of MOCA Melter, Dispenser and the Slinger Degasser.

B. PERSONNEL PROTECTIVE EQUIPMENT Personnel Protective Equipment (PPE) is required whenever operating any portion of the machine. Specific PPE is: • Safety Glasses with side shields at all times. • When using a bonding agent, especially Chemlock – until further test are run and results are determined a respirator with yellow vapor canisters must be worn. • When transferring any chemicals from their original container to the machine, dust mask must be worn. • Thick rubber gloves must be worn when using any type of cleaning chemical. • Everyday rubber gloves must be worn when handling all other chemicals. • Long sleeves or other type of arm protection must be worn. • Whenever machine is running, ventilation system must be on.

If at any time you believe that a hazard is present that you are not properly protected against, contact the Safety Director, who will determine if additional PPE is required.

Food is never to be consumed in the area where blades are manufactured.

C. ADDITIONAL SAFETY PRECAUTIONS Equipment involving heaters, motors, gears, pumps, hoses, powered by air and or fluids, must all be operated following all safety precautions. Employees must follow all safety directions for each material and or chemical used. Avoid skin contact with all chemicals and always wear the proper PPE. Avoid contact with vapors by wearing the proper breathing respirators. Be certain that the building ventilation is on and working properly. Never use flammable solvents for cleaning the head or any part of the machine. Always keep flammable solvents away from the machine as sparks from the motor could ignite them. When working on any part of the machine use proper lock out/tag out procedures and remove all pressure on tank lines. Chemicals in a liquid form may not be disposed of through normal channels. These chemicals must be properly stored and properly disposed of. ASGCO has a company who will dispose of these chemicals. The Safety Director must be notified when there is an accumulation of liquid chemicals; arrangements will then be made for their disposal. If chemicals can be combined so that the result is in a solid form, the solid can then be disposed of. When cleaning the machine, any chemicals used must be deposited into a drum which must be labeled as used. ASGCO will dispose of this used chemical through proper channels.

MOCA Melter The purpose of the MOCA Melter is to melt the Curative to a temperature that allows it to be poured into the mold. There is a burn risk and a pressure build-up risk when using this machine. It is imperative that the written start-up procedures be followed for all parts of the machine. 91 MOCA violently decomposes when exposed to excessive temperatures. In no case should MOCA ever be allowed to heat above 260 degrees. Make certain that when working near any burn risk, proper hand protection is always used as well as proper safety glasses.

When loading pellets into the melter, the exposure must be kept to a minimum. Long sleeves or other type of skin protection must be worn. Employees must avoid contact with skin. Whenever possible lids on the drum must be kept sealed. When putting nitrogen into any container, extreme caution should be used.

Never operate the melter when an alarm is sounding, if you do not understand the nature of the alarm. If you have any questions, ask your supervisor.

Slinger Degasser The purpose of the Degasser is to eliminate any air in the final blade solution and to bring the material up to optimum processing temperature. This portion of the machine is under negative pressure. Be certain that when nitrogen is used, the correct psi is set and used. Positive pressure should never be applied to the degasser.

Curing Ovens Ovens will run 24 hours a day and remain hot. Proper personal protection from the heat must be used whenever working in or near either oven. In the event that something is dropped/rolls under either of the ovens, it is imperative that prior to retrieving any item, the power to the oven is turned off. Take special precautions when going into the oven as there are tripping hazards that must be addressed. At no time is an employee to spend more time in the oven then necessary. If an employee knows that there will be a length of time spent in the ovens, all power must be turned off, prior to entering.

LOCKOUT/TAGOUT PROCEDURES To De-Energize Urethane blade making equipment 1. Notify Shop Manager/Supervisor that you will be taking equipment down. Obtain necessary LOTO kit. 2. Notify all shop personnel that machine will be locked out. 3. Turn all breakers and switches to the office position. 4. De-energize the appropriate electrical box(s) 5. Apply lock and tag to the appropriate electrical box (s) 6. Release stored energy 7. Verify that machine has been de-energized by attempting to turn on.

When re-energizing Urethane Blade making equipment 1. Notify everyone in the area that the machine will be re-energized 2. Do a detailed search of the immediate area, making certain that all tools and equipment is cleaned up and put in its proper place. 3. Make certain that anything taken off the machine is put back on and secured correctly 3. Notify Shop Manager/Supervisor that you will re-energize the Press 4. Removed lock from electrical box (s) 5. Turn power source on 6. Energize equipment, listen and look to be certain machine is running properly

92 SECTION 24 WELDING AND CUTTING

Welding operation will only be performed by authorized and trained employees. When welding hazards exist that cannot be eliminated, then engineering practices, administrative practices, safe work practices, Personal Protective Equipment (PPE), and proper training regarding welding will be implemented. These measures will be implemented to minimize those hazards to ensure the safety of employees and the public.

A. GENERAL RESPONSIBILITIES It is the responsibility of the Fabrication Shop Foreman to review this portion of the Safety Manual and to annually review the effectiveness of this program. He will be responsible for recommending the proper PPE that will be required to be worn while working in the fabrication shop. It is also the responsibility of each ASGCO Manufacturing employee to report immediately any unsafe act or condition to his or her supervisor. Where ever possible these procedures and practices will comply with all OSHA requirements and will comply with accepted practices as outlined in nationally recognized standards. When welding, cutting, or soldering with arc or flame near combustible materials, suitable precautions shall be taken to insure that smoldering metal or sparks do not result in a fire.

B. TRAINING Employees who perform welding operations will be trained to:

• Recognize the hazards associated with various welding operations. • Know the safe work practices for welding operations. • Understand the importance and requirements of Hot Work Permits. • Use the appropriate personal protective equipment (PPE) for the job. • Recognize confined spaces and the requirements associated with them. • Understand the importance of regular inspections of welding equipment, attachments, and accessories.

This training shall be made available upon initial employment or job re-assignment, and will be done by the Safety Director, immediate supervisor and foreman. Refresher training shall be provided upon the discretion of the Fabrication Shop Foreman, with some form of training being done annually.

No employee will use the machinery at the Fabrication Shop unless prior training by the Fabrication Shop Manager is given.

C. WELDING HAZARDS The hazards associated with welding include health and safety hazards. Health hazards are primarily respiratory hazards due to the generation of fumes and gases. Safety hazards are generally physical hazards due to the work site and conditions and materials associated with the work site.

Health hazards associated with the generation of fumes and gases depend upon the welding process, the base material, the filler material, and the shielding gas if any. Health hazards include exposure to: 93 • Toxic gases • Primary pulmonary gases • Non-pulmonary gases • Particulate matter • Irritants and toxic inhalants Air sampling may be required to identify the fumes and gases emitted from a specific operation. ASGCO Fabrication shop has a portable ventilation system that must be used when health hazards are present.

Safety hazards associated with welding operations include: • Fire. • Proximity to combustible materials. • Hazardous locations (rooms containing flammable or combustible vapors). • Closed containers that have held flammable liquids or other combustibles. • Electric shock (arc welding). • Infrared and ultraviolet eye damage.

D. SAFE WORK PRACTICES Safe work practices for all welding operations include:

1. Placing work at an optimal height to avoid back strain or shoulder fatigue. 2. Using fall protection equipment for work on elevated surfaces more than 4 feet above the floor or ground surface. 3. Wearing personal protective equipment (PPE) as applicable for the work conditions. 4. Following special precautions when welding or cutting in a confined space. 5. Following safe housekeeping principles. 6. Using equipment as directed by the manufacturer instructions or practices. 7. Removing any butane lighters, matches, or other combustibles from pockets prior to performing work. 8. Not performing welding work with oily clothing (Leathers may need to be worn over clothing). 9. Following fire protection and prevention practices during the welding operation. 10. Using proper ventilation techniques during welding operation. 11. Employees will inspect areas where welding or torch cutting is to take place and take proper measures to ensure fire hazards are eliminated or protected against. If combustibles are within 35 feet of the welding area, welders will use guards or shields to contain sparks and slag. 12. Appropriate fire extinguishers or other water sources must be immediately available and accessible at the welding operation. All areas must be wet down prior to commencing welding operations. 13. No welding, torch cutting or heating shall be done where flammable paints, the presence of other flammable compounds, or heavy dust concentrations exist. 14. When on a jobsite a Hot Work Permit must be completed and followed where torch cutting and welding operations are conducted in close proximity to flammables, combustibles, hazardous materials or processes, and in confined spaces. This is the responsibility of the on site designated person or persons. Job Foreman are responsible for making certain that on site policies and procedures are followed. 15. Cylinder valves must be in the off position whenever cylinder is not in use. 16. When an employee is welding on site in an “other than designated welding area”, a fire watch must be enforced with an individual on fire watch while cutting and welding is being performed and for at least one-half hour after work has been completed. 94

• When on a customers site, before welding, cutting or soldering is to be performed in areas likely to contain methane, a qualified person, from on site, will perform a test for • the presence of methane using an approved device. These examinations for methane will be made immediately before and periodically during all welding, cutting and soldering.

E. OPERATING PROCEDURES Welding, cutting, or soldering work shall not be permitted to commence or continue in air which contains 1.0 volume per centum or more of methane. Unless connected to a manifold, always attach a regulator to the compressed gas cylinder before use. Make certain that the regulator is proper for the particular gas and service pressure. Make sure the regular is clean and has a clean filter installed in its inlet nipple. Before attaching the regulator, remove the protective cap from the cylinder. Stand to one side of the cylinder. Open the cylinder valve slightly for an instant, then close it. This “cracking” of the cylinder valve will clean the valve of dust or dirt which may have accumulated during storage. Dirt can damage critical parts of a regulator, and may cause a fire or explosion. Before a regulator is removed from a cylinder valve, the valve shall be closed and the gas released from the regulator.

The operator must use the proper hose. Fuel gas hose is usually red, and sometimes black, and has a left handed threaded nut for connecting to the torch. Oxygen hose is green and has a right- hand thread nut for connecting to the torch. Hose and hose connection are to be clamped or otherwise securely fastened in a manner that will withstand, without leakage, twice the pressure to which they are normally subjected to while in service. But in no case less than 300 psi. Hose showing leaks, burns, worn places or other defects rendering it unfit for service shall be repaired or replaced. When inspecting hoses, look for charred section close to the torch. These may have been caused by flash back. Also check that hoses are not taped up to cover leaks. Regulators must be in the off position when cylinders are not in use.

Pressure reducing regulators will be used only for the gas and pressures for which they are intended. When repairs are needed on the regulators it will only be done by skilled mechanics who have been properly instructed. Gages on oxygen regulators will be marked “USE NO OIL”.

F. ON SITE WELDING Remember that each customer may have special procedures for welding, cutting and Braising on their site. Special requirements may be needed if work is to be performed in customer’s restricted areas. Restricted areas may include, but are not limited to, surface fans, chutes, storage areas and shafts. Wherever practical, alternatives to cutting and welding, which provide greater measures of safety, should be utilized at restricted locations. Regulators must be taken off of all cylinders when traveling and or job is complete. No regulators are to be kept on cylinders when transporting in a vehicle.

G. ARC WELDING The following limits will not be exceeded: Manual AC 80 Volts DC 100 Volts Automatic AC 100 Volts DC 100 Volts

H. CYLINDERS 95 All cylinders used in the welding process must be visually inspection prior to each use. If a cylinder is found to be leaking, is bulging, has defective valves or safety devices, bears evidence of physical abuse, fire or heat damage, or detrimental rusting or corrosion, it MUST be taken out of service immediately. The cylinder may only be used if it is properly repaired and re-qualified by an authorized person.

I. OXYGEN-FUEL WELDING AND CUTTING Under not conditions will acetylene be generated or utilized at a pressure in excess of 15 psig. This does not apply to storage of acetylene dissolved in a suitable solvent in cylinders manufactured and maintained according to USDOT.

J. HOT WORK PERMIT PROGRAM A Hot work permit must be issued prior to initiating any hot work outside of a designated Hot Work Area. The site will be evaluated for potential fire and safety hazards by the on site personnel accompanied by the ASGCO job Foreman. Permits remain active for the duration of that work shift. When practical, all flammable and combustible materials shall be relocated at least 35 feet from the work area. When relation is impractical, combustible and flammables shall be protected with flame proof covering or otherwise shielded with metal or flameproof curtains. A suitable fire extinguisher must be present and accessible at all times. Concentrations of flammable or combustible vapors or gasses must be determined before work begins and it is the responsibility of the on site personnel and the job foreman to determine if the vapors or gases are at a safe concentration. Concentration measurements will be recorded. Hot work SHALL NOT be permitted if the concentration reaches 5% of the lower explosive limit (LEL). If combustible gas meter indicates any concentration of flammable vapor, the hot work permit shall not be approved until the person approving the permit a) understand the source of the flammable- combustible vapors and b) can assure that concentration will not increase to a dangerous level while work is underway. Fire watch policy and procedure is determined by the on site person in charge but is necessary when:

• Work is performed in buildings and storage sheds • An appreciable amount of combustible material in construction, contents or insulation is closer than 35 feet to the point of operation. • An appreciable amount of combustible materials are more than 35 feet away from work but can easily be reached by sparks, embers, etc. • Wall or floor openings are within 35 feet of work, including concealed spaces in walls or floors • Combustible materials are adjacent to the opposite side of metal partitions, walls, ceilings or roofs and are likely to be ignited by conduction or radiation of heat.

During any hot work all employees are required to wear the proper personal protective equipment, such as coveralls, safety goggles, face shield, welding hood, welding jacket, etc, as demanded by the type of work completed and required by the Foreman and the on site Hot Work Coordinator.

K. PLASMA CUTTING TABLE – See Fabrication Shop Safety.

96 SECTION 25 WORKERS COMPENSATION

By law our company is required to obtain workers compensation insurance. ASGCO pays for this insurance and the premiums are not government funded in any way. Because workers compensation is a substantial cost of doing business, our goal is to prevent and manage accidents. This is why all accidents and near misses must be reported immediately to the Safety Director.

When an employee is injured during the course of business, workers compensation insurance provides payment to the injured workers or the treating physician for medial treatment, disfigurement, death benefits and indemnity (lost wages). The scope and amount of these payments are determined by state law. Attorneys are not needed for you to get what you are entitled to. Attorneys, when hired, typically earn one third of your benefits, thus reducing what you will receive. If you report injuries immediately to your supervisor or Safety Director and cooperate with your treating physician and the insurance company, the system will work with you to get you healthy and back to work.

Workers compensation payments may be denied if: 10 the employee tests positive for drugs or alcohol following an accident, 2) a pre-existing injury or non-work related injury was the cause of the accident, or 3) fraud exists.

Filing a false workers compensation claim is punishable with a substantial fine and imprisonment. Any employee who knows of a coworker who is abusing the workers compensation system or has filed a false workers compensation claim should inform their immediate supervisor or other proper authority.

The insurance company has many red flags to identifying workers compensation fraud and will investigate any accident they suspect may be fraudulent. They can deny or reduce benefits whenever they suspect a fraudulent claim was filed or an employee is abusing the workers compensation system.

The following is considered workers compensation fraud or abuse:

1. Faking an accident or injury. 2. Exaggerating the seriousness of an accident or injury. 3. Taking more time off than is really needed to recover. 4. Attempting to collect benefits for an injury that is not job-related. 5. Submitting false or exaggerated medical bills for payment. 6. Working at another, equally demanding job while collecting workers compensation benefits. 7. Conspiring with, or being persuaded by, another person to do any of the above.

When people abuse workers compensation benefits, we all pay. ASGCO is charged higher insurance premiums, which increases our expenses and lowers profitability. The best way to safeguard against fraud is to prevent accidents from happening in the first place. If you are aware of fraud, speak up.

97 SECTION 26 FABRICATION SHOP SAFETY

A. INTRODUCTION The ASGCO Fabrication Shop presents unique hazards that must be addressed in its own chapter. Fabrication in and of itself has extreme hazards. Those hazards include but are not limited to: air quality, Plasma, MIG and TIG welding hazards, housekeeping, material handling and machinery hazards. These hazards require special Personal Protective Equipment.

ALL employees who are not permanently assigned to the Fabrication Shop must report to the person in charge of the Fabrication Shop. All jobs must be approved by the Manager/Supervisor prior to being started.

At no time should a person, other than a competent and/or qualified person attempt repairs on any machinery.

B. PERSONEL PROTECTIVE EQUIPMENT 1. Welding Helmets. ASGCO Manufacturing provides each employee with a welding helmet that is suitable for the required jobs. If the employee wishes to buy their own welding helmet, it must first be approved for use by the Safety Director.

2. Welding Gloves and Clothing. Welding gloves, welding jackets and any necessary additional welding clothing that ASGCO requires to be used will be supplied to you by the Safety Director. If there are any special requirements for these items, they will be approved and purchased by the Safety Director.

3. Safety Glasses. Safety Glasses are required to be worn whenever in the fabrication shop. There are no exceptions to this rule.

4. Welder caps are recommended and will be supplied to you by the Supervisor/Foreman.

5. Metatarsal Safety Boots. Employees working in the Fabrication Shop must either wear metatarsal boots or Metaguards, which fit over a safety shoe. Employees will receive their own pair of Metaguards, should they require them, upon completion of training.

6. Ear Protection. Ear Protection is required when grinding or using any Fabrication Shop machinery.

7. Face/Eye protection – Safety Glasses and a Grinding shield is required to be worn when grinding any materials.

C. WELDING Work areas must be cleared of all flammable and or combustible material prior to any welding being done. The welder must make certain that a usable fire extinguisher is within reach at all times. The section on Welding applies. Proper ventilation must be used when welding occurs. It is important that each welder know to turn off regulators/gauges to each cylinder when not in use.

98 D. MATERIALS HANDLING Any steel that needs to be moved will only be moved by Fabrication Shop personnel. No employee who is not assigned to the Fabrication Shop full time is permitted to move steel. When moving steel, the proper method, of using mechanical means is to be used. Only those individuals who are authorized and have their Forklift Cards in their possession can drive the any ASGCO Forklift.

E. PAINTING Painting is done in the Fabrication Shop ONLY when necessary and is not part of the daily routine. Paints must be properly stored when not in use. Proper ventilation must be approved by the Foreman/Supervisor of the shop and maintained the entire time painting is being done. There are no exceptions to this rule. If proper ventilation can not be achieved then painting can not be done. PPE is required to be used by any individual that is to paint. This PPE consists of a respirator with the proper filters, eye protection, Disposable Bodysuit, and a means of ventilating any fumes/particles which are emitted when painting. Our preferred method of painting is to send this work out to a qualified company to be completed.

F. PRESS BRAKE Only authorized and trained individuals may use the Press Brake. The Fab Shop Manager or Foreman must train the individuals that are permitted to use the brake. Because Press Brakes are extremely difficult to guard, the operator must take extreme caution when operating, setting up the brake, paying particular attention to all pinch points and point of operation.

It is the responsibility of the operator to observe the following points: 1. The press and designated work area adjacent to the press must be kept clean, orderly and free of excessive accumulation of oil, grease and material scrap. 2. Point-of-operation will be used and safe distance will be adhered to when operating the press. Point-of-operation foot pedals or hand controls must be used as intended at all times. 3. The operator will use proper work supports, mechanical assistance or helpers when loading or unloading large heavy piece parts or sheets of material. Proper handling and lifting of the material will be followed. Get help if the job requires it. 4. Additional PPE required for operation of the press is proper gloves for handling materials and safety glasses. 5. If Press Brake should jam during operation, Supervisor must be notified and steps taken to ensure safe procedures when correcting machine jam. This may include locking out of the machine. (refer to Electrical Section) 6. Operator must stand a safe distance from Press and in front of computer when programming Press. 7. At no time should any persons be positioned behind the rear of the Press Brake and there will never be any persons behind the rear guards of the machine. The exception to this rule is when completing the daily checklist or when the machine is locked and tagged out. 8. Point of operation will only be operated from a standing position. 9. At no time will any guard be by-passed or removed, unless press is locked out and tagged out for maintenance. 10. Operator will make the machine inoperable by the means provided when he is not actively cycling the machine. 11. Never place hands or other parts of the body in the machine. 12. Never operate the machine if it is not working properly. 13. Never tamper with, rewire or bypass any control or component of the machine 14. Immediately report any unsafe conditions to the Fab Shop Manager. Only qualified personnel will perform maintenance and or repair work. 99 15. Be certain that the work is held securely in place before engaging ram. 16. Never use damaged or incorrect dies. 17. The use of hand tools is highly recommended for freeing and removing stuck work or scrap pieces. 18. Any injuries sustained from the Press Brake must be reported immediately to your supervisor and to the in house Safety Director. The Safety Director is then responsible for reporting the injury to the appropriate OSHA office. 19. Training must be done on an annual base and documented. Documentation will then be forwarded to the Safety Director.

MACHINE MAINTENANCE Maintenance on the Press Break may only be done by a qualified person. The definition of a qualified person is: one who, by possession of a recognized degree, certificate or professional standing, or who by extensive knowledge, training and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.

Daily checks and/or routine upkeep of the Press Brake may be done by a competent person. The definition of a competent person is: one who is capable of identifying existing and predictable hazards in the surroundings or working conditions, which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.

1. Daily check. Prior to the beginning of each shift, a check of the Press Brake must be done, by a competent person. A Daily checklist must be initials. This check will consist of inspection of all hydraulic systems and a verification that the hydraulic oils are at the correct level. A visual inspection of the machinery itself. A pre-shift start up, listening for odd or incorrect sounds. A check of the rear floor of the Press Brake to be certain that no oil has leaked. If there is any area that has not passed the daily inspection, the Press Brake must not be used until repairs are made.

LOCKOUT/TAGOUT PROCEDURES To De-Energize Press Brake 1. Notify Shop Manager/Supervisor that you will be taking equipment down, Shop Manager/Supervisor has a LOTO kit. 2. Notify all shop personnel that machine will be locked out 3. Insert 2 blocking devices with wedges to both outer most sides of press. 4. De-energize electrical box #1. 5. Apply lock and tag to electrical box #1. 6. Release stored energy of press by depressing start buttons or foot pedal. 7. Verify that machine has been de-engerized.

When re-energizing the Press Brake 1. Notify everyone in the area that the machine will be re-energized 2. Do a detailed search of the immediate area, making certain that all tools and equipment is cleaned up and put in its proper place. 3. Make certain that all guards are on and secured correctly 3. Notify Shop Manager/Supervisor that you will re-energize the Press 4. Remove 2 blocking devices with wedges from outer most sides of press. 5. Removed lock from electrical box #1 6. Turn power source on

100 7. Energize Press by using computer station and start buttons or foot pedals from appropriate distance. 8. Look and listen to machine to verify that equipment is running properly.

Daily Checklist is on file in the Safety Director’s office.

G. PLASMA CUTTING TABLE Only trained and authorized employees are permitted to operate, maintain and repair this machine. Fabrication Shop Manager or his designated person must train any employee authorized to use the Plasma Cutting Table.

Working at the Plasma Table can cause serious accidents if the operation is not performed in a manner described in the Operations Manual. The Operations Manual must be readily accessible to individuals who are authorized to use this equipment. An additional copy of the Operations Manual is kept on file in the Safety Directors Office.

Be certain that all guards and covers are in place prior to operating the equipment. Have guards and/or covers replaced if they are damaged or missing. The Cutting Table should NEVER be operated if guards/covers are damaged or missing. It is necessary to periodically check the earth ground to prevent potential shock hazard.

PPE 1. Avoid any loose clothing, ASGCO jewelry policy must be adhered to and the operator must be certain that any long unrestrained hair is not a hazard. 2. Leather gloves must be worn whenever working at the Plasma Table. 3. Metatarsals must be worn at all times, when working in the Fabrication Shop. 4. Shade 5 welding glasses must be worn when working with or near the Plasma Table. 5. Ear Protection must be worn as sound levels may reach 105db 6. Be certain that a welding curtain is put in place to protect the workers who are working near the table. Position the welding curtain as best as possible to protect those employees.

GASES The Plasma Cutting Table uses Oxygen and Nitrogen. The machine is never to be operated if there are suspected leaks with the cylinders or hoses. Be certain to read the MSDS sheets for all gases that are used. If you have any questions about the gases, ask the Fabrication Shop Foreman or the Safety Director. It is important that when Plasma table is not in use and prior to shutting down for maintenance that you turn the feeds for the gas cylinders off.

VENTILATION The specific combinations and concentrations of by-product smoke, gasses and particulate contamination will depend on the material being cute, the cutting arc current, arc voltage, and the speed at which the material is being cute. ASGCO will periodically do air testing, and results are available to any individual who requests them. At no time should the Plasma cutting table be used without the ventilation system being on and correctly working.

At no time should material that has already been painted be cut. Painted materials may release highly toxic fumes and gases, that we are not prepared to eliminate or lesson. When galvanized or Stainless steel is being worked on, the proper PPE must be worn. This PPE consist of proper mask that can lessen or eliminate the particular fumes given off by these products.

101 Prior to Servicing the Plasma Cutting Table, be certain that the capacitors are allowed to discharge a minimum of 15 minutes prior to servicing machine

DAILY START UP/MAINTENANCE 1. Perform all daily maintenance prior to daily start up. 2. Ensure that the CAM workstation is powered up and has finished booting. 3. Ensure that there is no coolant leaks at the Fine Plasma Cooling Unit or at the torch 4. Check coolant level in the Fine Plasma Cooling Unit and add coolant as required. 5. Ensure that all gas hoses are free of physical damage or leaks. 6. Open the valve at the oxygen tank and set line pressure to 100 psi. 7. Turn on the shop air and verify machine air supply pressure is set to 80 psi. 8. Verify that the Plasma Gas and Assist Gas pressures are properly set.

ELECTRICAL SHOCK/LOCKOUT TAG OUT PROCEDURES Plasma cutting used high voltage and direct current. Electrical shock may cause serious injury or death. When maintenance is being done to the Plasma Cutting Table the following Lockout/Tagout procedures must be followed.

LOCKOUT/TAGOUT PROCEDURES To De-Energized Plasma Cutting Table 1. Notify Shop Manager/Supervisor that you will be taking equipment down, Shop Manager/Supervisor has a LOTO kit. 2. Notify all shop personnel that machine will be locked out. 3. Close pressured air valves for cutter (3A) and air purifier (3B) 4. Released stored air energy by opening regulators on both cutter (4A) and air purifier (4B) 5. Lockout/Tagout red dial on right side of control by turning to the off position and applying lock and tag. 6. Turn off disconnect box 6A and 6B and apply locks and tags to both. 7. Turn Torit control panel off with knob on rear of purifier. Apply lock and tag. 8. Lock out Breakers on panel P-1. Breakers to be locked out are 20, 22, 24 (for air purifier) and 25, 27, 29 (for plasma table).

To Re-energize Plasma Cutting Table 1. Notify Shop Manager/Supervisor that maintenance is complete and Plasma Cutting table will be re-energized. 2. Notify all shop personnel that machine will be re-energized. Make certain that there are not tools or other items used in maintenance near table. 3. Take locks and tags off of breakers 20, 22, 24 and 25, 27, 29 in panel P-1. Turn Breakers on. 4. Take lock and tag off of air purifier (Torit). Turn air purifier on. 5. Take locks and tags off of disconnects (6A) and (6B). Turn both disconnects on. 6. Take lock and tag off of red dial on right side of control box. Turn control box to the on position. 7. Close air regulators to both cutter (4A) and air purifier (4B) 8. Turn air valves for cutter (3A) and air purifier (3B) to the open position.

GENERAL SAFETY RULES FOR PLASMA CUTTING TABLE 1. Be certain that the proper PPE is always worn. 2. Prior to cutting, always adjust the welding curtain to protect those in the shop area. 3. Never touch or hold the material being cut. 4. Never touch or hold the torch while the system is cutting or firing 5. All cables, power circuits and work areas near and around the machine should be kept dry. 102 6. Extreme care must be taken when filling or topping off the cooling system. Do not overfill or spill coolant inside the unit. 7. Periodically inspect all connections and grounds. 8. Keep all combustibles at least 20 feet away from the cutting area. 9. Always be certain that the machine can handle what is being cut. Refer to the owner’s manual for maximum thickness. 10. Periodically inspect all safety and hazard warning labels. Notify the Safety Director should these labels need replaced. 11. If at any time, you have any questions or concerns, please ask with the Shop Manager/Supervisor or the ASGCO Safety Director.

H. PRO-FINISH CABINET SYSTEM Only trained and authorized employees are permitted to operate, maintain and repair this machine. Fabrication Shop Manager or his designated person must train any employee authorized to use the Pro-Finish Cabinet.

The Operations Manual must be readily accessible to individuals who are authorized to use this equipment. An additional copy of the Operations Manual is kept on file in the Safety Directors Office.

PPE Proper PPE is required when operating this machine. PPE consist of Safety Glasses, and steel tip boots with metatarsals. When cleaning the recovery system , emptying the blasting material or disposing of the blasting material, a dust mask must be worn.

GENERAL OPERATING When operating the cabinet, all doors, vents and any additional parts of the machine must be closed and/or sealed. The finisher should never be operated where the material used to blast the parts is allowed to escape into the atmosphere. The finisher is equipped with an air hose. PSI should always be between 100 and 120 psi.

DAILY START UP/MAINTENANCE 1. Check the condition of the media. If the media is contaminated or broken down into dust, thoroughly clean the inside of the cabinet and recovery system and reload with new media. 2. Adjust the reclaimer tuning bank if you observe a dusty condition. (See Owner’s Manual) 3. Clean the discharge box and/or filter bag or shake the dust collector bags after every 2-3 hours of operation. 4. Check light bulbs and gloves. 5. Remove any debris from the reclaimer screen 6. Open the manual drain on the general purpose filter in the cabinet pipe string and drain any accumulated moisture and oil. 7. Check the media level. The media level should not drop below one-half the recommended capacity. 8. All quick coupling connections MUST be equipped (according to Owner’s Manual) with safety pins. Inspect all couplings and blast hoses daily for splits, bubbles, soft spots, etc. Screws should be flush with coupling surfaces. Tighten screws if necessary.

WEEKLY MAINTENANCE 1. Repeat the daily maintenance procedures. 2. Inspect all media carrying hoses for wear by feeling along the length of the hose for soft spots. Replace if needed. 103 3. Check the nozzle for wear. The nozzle should not be worn more than 1/8”. 4. Check the suction system air jet for wear. 5. If the system contains a gun body and remove the air jet. 6. If the air jet shows wear, rotate it 90 degrees and reinsert it into the gun 7. RE-tighten the set screws 8. Check the nozzle adapter and gun for wear and replace if necessary. 9. Check the window gaskets for leaks and replace if necessary. 10. Check your spare parts inventory.

ELECTRICAL SHOCK/LOCKOUT TAG OUT PROCEDURES Electrical shock may cause serious injury or death. When maintenance is being done to the the Pro-finish cabinet the following Lockout/Tagout procedures must be followed.

LOCKOUT/TAGOUT PROCEDURES To De-Energized the cabinet 1. Notify Shop Manager/Supervisor that you will be taking equipment down, Shop Manager/Supervisor has a LOTO kit. 2. Notify all shop personnel that machine will be locked out. 3. Unplug machine and insert plug into lockout box, apply lock. 4. Use the disconnect to stop air pressure from entering machine. 5. Verify that machine does not start by turning machine on.

To Re-energize the cabinet 1. Notify Shop Manager/Supervisor that maintenance is complete and cabinet will be re- energized. 2. Notify all shop personnel that machine will be re-energized. Clean up any tools or materials left behind during maintenance. 3. After making certain that cabinet controls are in the off position, remove lock from lockbox and plug machine into outlet. 4. Reconnect the air supply to the cabinet, making certain that PSI is correct. 5. Verify that the machine is now ready to operate by turning the cabinet on and listening for any incorrect noises.

GENERAL SAFETY RULES FOR PRO-FINISH CABINET SYSTEM 1. Make certain that the floor around the blast cabinet is free of loose abrasives. 2. Check the viewing window in the blast cabinet frequently for excess pitting and cracks, 3. Check and replace gloves on a scheduled basis. 4. Watch for loose or worn media hose and fittings. 5. NEVER operate above 125 PSI 6. Be certain proper PPE is worn. 7. If the cabinet operator experiences static electrical shocks while blasting, stop immediately and check the path to ground.

I. MILLING MACHINE AND LATHE Only trained and authorized employees are permitted to operate, maintain and repair both of these machines. Fabrication Shop Manager or his designated person must train any employee prior to authorizing that employee to run or program the machines.

The Operations Manual must be readily accessible to individuals who are authorized to use this equipment. An additional copy of the Operations Manual is kept on file in the Safety Directors Office. 104 PPE Personal Protective equipment is the last line of defense in keeping our employees safe. It is imperative that all safety rules are followed at all times. When using the Milling or Lathe, safety glasses and steel tip boots must always be worn. Gloves must NOT be worn when operating these machines, as this will create an additional hazard.

GENERAL SAFETY Employees operating the machines must always stand clean of moving parts during machine operations. Main operator is responsible for making certain that others are warned of the dangers of being too close to the machine while in operation.

DO • Never reach into the machine while the machines are running. • Always avoid contact with cutting edges when handling tools or changing tools by hand. • Keep long hair covered and away from moving parts of the machines • Only operate machines with doors closed. • When deburring, or removing excess chips from pieces make certain you use a hand tool to avoid being cut

DON’T • Wear loose clothing • Wear gloves • Place hands near revolving spindle • Never leave the machine so that someone else is able to start it by pressing the start buttons • Open the doors of the machine while the machine is in operation

TOOLING SAFETY Never load a tool magazine while the machine is operating and only load tools that are in good condition. Make certain that the tool studs are tight and that the tool is set correctly. Testing tool prior to use is required. Tools must be used within their specifications, never using blunt, chipped, cracked or tools with damaged tips. These tools must be red tagged out and put out of service immediately.

PREVENTIVE MAINTENANCE On a weekly bases operation must: Check fluid levels Clean excess chips from machine Check and tighten all tool studs Do a general cleaning of the machines

LOCK OUT/TAG OUT PROCEDURES To De-Energized the milling machine and lathe 1. Notify Shop Manager/Supervisor that you will be taking equipment down. 2. Notify all shop personnel that machine will be locked out. 3. Turn handle on breaker box to the off position, apply lock. 4. Use the disconnect to stop air pressure from entering machine. 5. Verify that machine does not start by turning machine on.

To Re-energize the milling machine and lathe 105

1. Notify Shop Manager/Supervisor that maintenance is complete and cabinet will be re- energized. 2. Notify all shop personnel that machine will be re-energized. Clean up any tools or materials left behind during maintenance. 3. After making certain that controls are in the off position, remove lock. 4. Reconnect the air supply to the machine, making certain that PSI is correct. 5. Verify that the machine is now ready to operate by turning the machine on and listening for any incorrect noises.

J. POWDER COATING PROCESS Only trained and authorized employees are permitted to operate, maintain or repair any machine that is associated with the powder coating process. Fabrication Shop Manager or his designated person must train any employee authorized to powder coat.

PPE Personal protective equipment is our last line of protection for our employees. PPE required for powder coating is as follows:

Using Chemicals -This is the process of using or transferring any chemicals used in the powder coating process. Safety glasses, face shield, chemical apron, and appropriate chemical gloves. In addition long sleeves must also be worn.

Prep Process – Chemical apron, safety glasses, face shield and appropriate chemical gloves. Long sleeves are also required.

Painting process - respirator with VOC/P100 canisters, booties, appropriate gloves and safety glasses are required. If the employee chooses to wear Tyvek clothing he is permitted to do so.

Oven – The oven used in this process is at a very high temperature, therefore an employee must protect himself from exposure to this heat. It is imperative that when removing items from the oven, both doors are to remain in the open position. Appropriate heat resistance gloves are to be used whenever handling any hot piece.

If in the process of powder coating, an employee feels that additional PPE is necessary, that employee may request that equipment from the Safety Director. The safety director will work with the employee to obtain that Protective Equipment.

K. HOUSEKEEPING Housekeeping throughout ASGCO is an ongoing concern, especially when there is an area where work is always being done. To keep the Fabrication Shop clean, it is required that housekeeping be attended to on a daily basis. Work areas must be kept as neat as possible, with no broken or unused tools laying on working surfaces. All soiled rags must be deposited in the covered rag bin and the lid must remain on the bin at all times. At the end of the day, each person working in the Fabrication shop must take time to attend to any and all housekeeping issues.

L. TRAINING Any employee who is not permanently assigned to the Fabrication Shop MUST go through individual training PRIOR to doing any work in the Fabrication Shop. This training must be 106 documented when completed and can only be conducted by the Supervisor or Foreman. No individual is permitted to use any piece of machinery that they are not properly trained on. The completed training checklist must be returned to the Safety Director and will be kept on file.

J. DISCIPLINARY ACTION If any misconduct and or misuse of any of the machinery occurs, it must be documented by the Fabrication Shop Supervisor/Foreman and given to the Safety Director as soon as possible. Depending on the severity of the misuse or misconduct, disciplinary action will be taken. Individuals who do not follow the rules and training instruction, misuse machinery, or participate in any misconduct will no longer be allowed to be in the Fabrication Shop.

107 SECTION 27 SERVICE SHOP AREA SAFETY

GENERAL SAFETY

A. PPE Proper PPE must be worn at all times when working in the Service Shop area. This PPE includes but is not limited to: safety glasses and steal tip boots. Additional PPE must be worn for job specific tasks. When grinding, additional PPE is required, which includes a grinding shield worn over safety glasses, proper gloves and hearing protection. When there is a questions about what PPE is required for a specific job, please see the Shop Foreman or the Safety Director. Cut gloves are required to be worn when cutting belting, whether in the shop or in the field.

B. IMPACT RAIL MANUFACTURING A process has been determined for assembling impact rails while in the Service Shop. This process includes the use of sand blasting machinery. When sand blasting is being done and the machine is running, all occupants of the Service Shop must wear the proper dust masks, if at any point the ppm require. The individuals who are feeding the sand blasting machine must be certain to wear the appropriate eye protection, which may include goggles or tight fitting eye protection and ear protection. Those making the rails must wear ear protection when sanding the rubber portion of the rail. Gloves must also be worn when working on any portion of making the impact rails. The MSDS Sheet for the material being used in the machine is available in the MSDS book in the service department.

ASGCO is responsible for doing periodic air quality checks. The air sampling will be done by an outside consultant who is qualified to determine the allowable ppm. Periodic decibel readings will also be taken. Both reports are available for viewing in the Safety Directors office.

MACHINE MAINTENANCE/SANDBLASTING MACHINE

Only qualified individuals may do electrical maintenance on the sand blasting machine.

DAILY MAINTENANCE Daily upkeep is the responsibility of the person or persons running the machine. Daily upkeep includes but is not limited to: 1. Check condition of the media. If media is contaminated or broken down into dust, thoroughly clean the inside of the cabinet and recovery system and reload with new media. 2. Adjust the reclaimer (see operators manual) tuning bank if you observe dusty conditions. 3. Clean filter bag/shake dust collector after every 2-3 hours of operation. This is done by turning off power switch and removing the dust from the bags by pressing the bag shake button 15 to 20 times. 4. Check light bulbs. 5. Remove any debris from reclaimer screen. 6. Open manual drain on the general purpose filter on the general purpose filter cabinet and drain any accumulated moisture and oil. Close the drain. 7. Check the media level. For best performance, the media should not drop below one-half the recommended capacity. 8. Inspect all quick coupling connections which must be equipped with safety pins. Also inspect all couplings, the blast hoses, and screws. 108 When maintenance is being done the Manufacturers maintenance procedures must be followed. An extra copy of the operating Instructions and Maintenance information is available in the Safety Director’s Office

MONTHLY MAINTENANCE 1. Repeat the daily maintenance procedures 2. Inspect all media carrying hoses for wear by feeling along the length of the hose for soft spots. Replace hoses if necessary. 3. Check the nozzle for wear. When the nozzle is worn 1/8” oversize, replace it. Insert a drill bit into the nozzle to check for size. 4. Check the air jet on the suction systems for wear. 5. Loosen set screw in the side of the gun body and remove the air jet, if the jet shows wear, rotate it 90 degrees and reinsert it into the gun. 6. Re-tighten the set screw. 7. Check the nozzle adapter and gun for body wear and replace if necessary. 8. Check the window gasket for leaks and replace if necessary.

TEMPORARY NON USE PROCEDURES If the sand blaster will not be used for several days, follow these steps to remove media and prevent media from caking inside the system: 1. Empty media from cabinet and storage hopper. To remove from hopper remove rubber plug from the bottom of the regulator. 2. Drain the general purpose filter. Close the drain valve.

LOCKOUT/TAGOUT PROCEDURES To De-energize 1. Notify Service Shop Foreman that you will be taking equipment down. The Tool Room has a LOTO kit. 2. Notify all shop personnel that machine will be locked out. 3. Turn off main source of air pressure using the turn off valve overhead and to the left. 4. Release stored air pressure energy by turning blast to on allowing air to purge the system. 5. Carefully unplug machine. 6. Insert plug into appropriate plug lockout box and apply your lock and tag to the plug lockout box 7. Apply your lock and tag to the main red switch on side where material comes out of blaster. If lock and tag does not fit into main red switch, apply appropriate means to tag out, then apply your lock to that means. 8. Verify that the machine has been de-energized.

When re-energizing the Sand Blaster 1. Notify everyone in the area that the machine will be re-energized. 2. Do a detailed search of the immediate area, making certain that all tools and equipment is cleaned up and put in its proper place. 3. Be certain all guards and other parts are on the machine prior to taking locks off. 4. Remove locks from machine and plug from plug lockout box 5. Plug unit into designated socket 6. Turn the sand blaster on looking and listening to the machine to verify that equipment is running properly.

109 A copy of the Maintenance and Warranty Information, parts guide and Operating Instructions are on file in the Safety Director’s Office. If at any time, you are unsure of policy and procedures for any machinery, ask your foreman, manager or Safety Director.

MACHINE MAINTENANCE/TIMESAVER SANDER

An additional part of the process for making rails includes the use of the Timesaver belt sander machinery. When sanding is being done and the machine is running, all occupants of the Service Shop must wear the proper dust masks, if at any point the ppm require. The individuals who are feeding the sander machine must be certain to wear the appropriate eye protection, which may include goggles or tight fitting eye protection and ear protection.

ASGCO is responsible for doing periodic air quality checks. The air sampling will be done by an outside consultant who is qualified to determine the allowable ppm. Periodic decibel readings will also be taken. Both reports are available for viewing in the Safety Directors office.

Only trained and authorized employees can operate the machine. Only qualified individuals may do electrical maintenance on the sander machine. Please refer to the operator’s manual for any routine maintenance, including changing or tracking the abrasive belt. A copy of the manual is available in the Safety Directors office.

The Timesaver must never be operated with any of the doors open or slightly ajar. All doors must be securely fastened prior to turning the machine on.

LOCKOUT/TAGOUT PROCEDURES To De-energize Timesaver 1. Notify Service Shop Foreman that you will be taking equipment down. The Tool Room has a LOTO kit. 2. Notify all shop personnel that machine will be locked out. 3. Turn off main source of air pressure and release any stored energy which may be in the air hoses. 4. Turn breakers off in the appropriate panel and lock/out the breakers. 5. Verify that the machine has been de-energized.

When re-energizing the Timesaver 1. Notify everyone in the area that the machine will be re-energized. 2. Do a detailed search of the immediate area, making certain that all tools and equipment is cleaned up and put in its proper place. 3. Be certain all guards and other parts are on the machine prior to taking locks off. 4. Remove locks from appropriate breaker 5. Turn the Timesaver sander on looking and listening to the machine to verify that equipment is running properly.

C. HOUSEKEEPING Housekeeping throughout ASGCO is an ongoing concern, especially when there is an area where work is always being done. To keep the service area clean, it is required that housekeeping be attended to on a daily basis. Work areas must be kept as neat as possible, with no broken or unused tools laying on working surfaces. All soiled rags must be deposited in the covered rag bin and the lid must remain on the bin at all times. At the end of the day, each person working in the Fabrication shop must take time to attend to any and all housekeeping issues. 110

SECTION 28 AGREEMENT TO PARTICIPATE

I, ______, have read and fully understand all aspects of the ASGCO Manufacturing, Inc. Safety manual. I further agree to report all unsafe practices to my foreman, supervisor, manager or Safety director immediately. I know that if I have any additional questions or comments that I can, at anytime, talk to the Safety Director or any current member of the Safety Committee.

______Employee Signature

______Date

111