Safety Manual Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 1 I.B. Abel, Inc. – Confidential

Safety Manual

The program requirements of this manual are based on the potential safety hazards and operating losses to which the company had a foreseeable exposure on the date of publication of this manual. Due to the constantly changing nature of government regulations, it is impossible to guarantee absolute accuracy of the material contained herein. Periodically, material in this manual will be updated, revised or supplemented in order to keep the manual current and relevant.

It is impossible to effectively deal with all safety concerns or procedures in a single manual. Many safety-related matters involve situation-specific factors, which are difficult to anticipate. Accordingly, this manual is not the definitive statement, or the only statement, on company safety concerns or procedures. This manual is a starting point and a good- faith attempt to create a viable, company-wide, safety program and philosophy. Although the information and recommendations contained in this publication have been compiled from sources believed to be reliable, the company makes no guarantee as to, and assumes no responsibility for, the correctness, sufficiency or completeness of such information or recommendations.

Safety Manual

Table of Contents Safety Policy Statement ...... 4 Human Performance (HuP) ...... 5 Employee Responsibility for Safety ...... 19 Safety Training and Education ...... 23 Incident Reporting and Investigation ...... 26 Transitional Duty ...... 28 Fatigue Management ...... 30 Substance Abuse – Commercial and Non-Commercial Driving ...... 32 Commercial Drug and Alcohol Testing Policy ...... 33 Non-Commercial and General Drug and Alcohol Testing Policy ...... 37 Disciplinary Action ...... 42 Serious Six Violation Corrective Action Process...... 47 Emergency Action Plan (EAP) ...... 49 Pre-Job Briefing ...... 51 Risk Assessment ...... 53 Personal Protective Equipment ...... 55 Electrical ...... 59 Concrete and Masonry ...... 97 Confined Space ...... 99 Cranes and Rigging ...... 107 Cutting and Welding ...... 123 Driving Safety ...... 129 Excavation ...... 135 Tower Climbing and Erection ...... 150 Fall Protection ...... 153 Fire Protection and Prevention ...... 158 Hand and Power Tools ...... 162 Heavy Equipment ...... 164 Load Securement ...... 167 Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 2 I.B. Abel, Inc. – Confidential – All Rights Reserved

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Housekeeping – Material Storage ...... 168 Lock Out/Tag Out ...... 170 Mine Safety ...... 174 Railway Safety ...... 177 Scaffolding and Aerial Lifts ...... 180 Stairs and Ladders ...... 184 Steel Erection ...... 187 Work Zone Safety ...... 190 Asbestos Containing Material ...... 196 Back Injury Prevention ...... 199 Blood Borne Pathogens...... 201 Carbon Monoxide ...... 204 Process Safety Management ...... 206 Hazard Communication Program (HAZCOM) ...... 208 Hearing Conservation Program ...... 215 Lead Awareness ...... 216 Mold Awareness ...... 218 Respiratory Protection ...... 220 Silica Awareness ...... 224 Smoking ...... 226 Temperature Extremes ...... 227 Spill Prevention and Response ...... 229 Erosion and Sedimentation Control...... 231 Radio Frequency (RF) Radiation ...... 233 Environmental Permit Requirements ...... 236 Storm Water Pollution Prevention Plan ...... 238 SAFETY MANUAL RECEIPT ACKNOWLEDGEMENT ...... 240 CERTIFICATE OF RECEIPT ...... 241

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Safety Policy Statement “Zero Incidents”

I.B. Abel, Inc. (IBA) considers the safety and health of its employees our highest priority. No other endeavor is more vital to the successful pursuit of mutual goals and objectives. It is the intent of the company to provide a safe and healthy work environment for all employees and assure that they have the knowledge, skills, tools and equipment to perform their jobs safely.

We will maintain a safety program conforming to the best practices for the industry. To be successful, such a program must embody proper attitudes toward injury and illness prevention on the part of all managers, supervisors and employees. It also requires cooperation in all safety matters, not only between supervisor and employee but also between each employee and his/her co-workers. Only through actively caring for one another can this safety program be in the best interest to all.

This safety program has the complete endorsement and backing of the upper management of this company. It is consistent with our core values: We are responsible for each other’s wellbeing and success. Each person is empowered and accountable to act with integrity and transparency.

Our objective is a safety program that is an integral part of our safety, quality and productivity (SQP) policies and procedures and utilizes Human Performance (HuP) tools to eliminate injuries and illnesses. “Our goal is zero injuries”. The benefits of working together to meet this goal will be reflected upon our company, our customers and, most importantly the health and safety of our employees.

Patrick A Kinsley, President I.B. Abel, Inc.

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Human Performance (HuP) Purpose The expectation of the I.B. Abel, Inc. (IBA) Leadership is for the organization to provide a safe, high quality and productive service to our customers by ensuring each job task is completed without error the first time, every time. Human Performance is simply defined as behaviors plus the results that follow. Human Performance principles focus attention on employee actions and decisions that affect safety, operational, and business results. As such, the personal safety of workers and the integrity of our product are the central focus of human performance at IBA. Each IBA employee is expected to take responsibility for their actions. We are committed to improve our performance by implementing the principles of Human Performance. This Safety Lesson Plan addresses four fundamental Human Performance Tools employees are expected to use when performing work in order to reduce mistakes and improve results. Human Performance = Behavior + Results Behaviors are what we say and do. Results are outcomes of what we say and do. Excellent human performance is achieved by continuously reinforcing the right behaviors. This leads to optimum personnel safety and system reliability. Most serious events are initiated by human actions. IBA had a number of significant events in the past few years that could have been avoided if the proper Human Performance principles were applied. It is important that everyone apply Human Performance principles into the way we do business for the protection and benefit of all employees, customers, and shareholders. Human Performance Principles a. People are fallible, and even the best people make mistakes. b. Error-likely situations are predictable, manageable, and preventable. c. Individual behavior is influenced by organizational processes and values. d. People achieve high levels of performance largely because of the encouragement and reinforcement received from leaders, peers, and subordinates. e. Events can be avoided through an understanding of the reasons mistakes occur and application of the lessons learned from past events (or errors). What is a Critical/Irreversible Step? a. A Critical/Irreversible Step is any action that will trigger immediate, irreversible harm if that step or preceding actions are performed improperly or omitted. i. Critical/Irreversible Steps are also referred to as the “point of no return” or the action we cannot take back. ii. In electrical construction, IBA summarizes Critical/Irreversible Steps as any action(s) that alters current flow or moves a load. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 5 I.B. Abel, Inc. – Confidential – All Rights Reserved

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iii. IBA, Inc. requires that all Critical/Irreversible Steps are mitigated through elimination, substitution, engineering, administrative, work method, or PPE controls. iv. IBA, Inc. policy is that any Critical/Irreversible Step is mitigated through the behavior (Use of IBA Focus 3 – Self-Check, Peer Check, or Stop/Timeout) that each individual uses prior to carrying out the Critical/Irreversible Step. v. IBA, Inc. policy requires all Critical/Irreversible Steps are identified and documented on the Pre-Job Briefing when answering the 4 Key Questions. b. The foundation of the IBA Human Performance program is based on the idea that Critical/Irreversible Steps must be identified and mitigated prior to carrying out that action. What is an error precursor? c. An error precursor is a condition at the job site that increases the risk of errors or mistakes. Think of the TWIN Method for Identifying Error Precursors. i. Task Demands ii. Work environments iii. Individual capabilities iv. Human nature d. Being aware of error precursors (job hazards) is the key to preventing mistakes. Below is a list of the top ten errors traps: i. Time Pressure (in a hurry) ii. Distraction / Interruption iii. Multiple Tasks iv. Overconfidence / complacency v. Vague instructions vi. First Shift / Last Shift (tired and not focused) vii. Peer Pressure viii. Changes / departure from routine work ix. Physical Environment x. Mental Stress (home or work) What is an error-likely situation? e. An error-likely situation is a work situation in which there is a greater chance for error when performing a specific action or task in the presence of error precursors. i. Error = unintentional deviation from preferred behavior or “at risk behavior” ii. Likely = increased probability of an event due to error precursors Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 6 I.B. Abel, Inc. – Confidential – All Rights Reserved

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iii. Situation = job site conditions (error precursors) f. Remember that all events are predictable and preventable. It is important to always identify error-likely situations by recognizing error precursors and when Critical/Irreversible Steps are being performed. Use error prevention tools to stay focused on the task you are performing. Catch and prevent errors before they happen. Remember: Don’t Get Caught in those Error Precursor Traps. Be aware of all job hazards before you begin working. This is the key to preventing injuries and mistakes. g. Once the error likely situation is identified, identify what can be done address error likely situations during performance of the critical tasks. These tools are also strongly related to conduct of operations work practices. Tools that can be used to minimize human errors include: i. Pre-job Briefing/SAFER ii. Post-job Briefing iii. Self-Checking iv. Peer-Checking v. Two-Minute Rule vi. Stop When Unsure vii. Questioning Attitude viii. Situational Awareness ix. Effective Communications x. Procedure Use and Adherence Human Performance Tool Bag h. Pre-job briefs/tailboards/huddles i. After the work is adequately planned, all work activities should have some type of pre-job briefing. A pre-job briefing is a meeting of workers and supervisors conducted before performing a job to discuss the tasks involved, hazards, and related safety precautions/controls. This meeting helps individuals to better understand what to accomplish and what to avoid. Pre-job briefings help participants avoid surprises in the field and reinforce the idea that there are no ―routine activities. ii. A graded approach is used to determine the scope of a pre-job briefing. The scope depends on the job’s risk and complexity and the frequency it is performed by the worker. Simple briefings can be conducted for uncomplicated, repetitive, low-risk tasks, while more detailed briefings are appropriate for complex, infrequently performed, and high-risk tasks. The effectiveness of a pre-job briefing depends greatly on the people attending the pre-job briefing and their understanding of the job to be performed. This Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 7 I.B. Abel, Inc. – Confidential – All Rights Reserved

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promotes a quality dialogue that helps everyone understand what they must accomplish and what to avoid, providing an opportunity to raise everyone’s awareness of critical activities and to mentally rehearse performance of Critical/Irreversible Steps. iii. One of the event prevention tools which can be used during pre- job briefings is a mental framework called SAFER. SAFER should be applied in situations such as pre-job safety meetings and work site walk-downs. 1. Summarize (S) Critical/Irreversible Steps of task. Not all steps of a procedure are equally important, particularly if the job is judged risk-significant. 2. Anticipate (A) error-likely situations. A review of job-site conditions could reveal error-prone steps or activities in the task. 3. Foresee (F) consequences. If a mistake does occur at the Critical/Irreversible Steps, what is the worst that can happen to the physical plant? To people? What is likely to occur? 4. Evaluate (E) defenses. Defenses should prevent, catch, or recover from error. This stage of SAFER is the best time to determine contingencies for potential consequences of error, rather than later during job performance. 5. Review (R) operating experience. The first four elements of the task preview address what might happen. This step addresses what has happened. Operating experience helps dispel the attitude that nothing can go wrong. iv. The pre-job brief helps individuals to better understand what to accomplish and what to avoid. Pre-job briefings help participants avoid surprises in the field and reinforce the idea that there are no “routine” activities. 1. Why: a. Helps personnel to better understand what is to be accomplished and what should be avoided. They help personnel avoid surprises in the field and reinforce the idea that there are no routine tasks. b. Allows an interaction between members of the crew so that there is an understanding of each member’s role c. Designated Challenger 2. What: Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 8 I.B. Abel, Inc. – Confidential – All Rights Reserved

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a. Task purpose, scope, and nature of work b. Review of procedures, work package documents, drawings, turnover information, prerequisites, permits, etc. that will be used to complete the task c. Task assignments, identifying and understanding roles and responsibilities, qualifications, personal limitations, handoffs, and the controlling authority d. Safety hazards and mitigating methods: i. Identification of safety hazards ii. Work procedures involved iii. Special precautions iv. Control of energy sources, including permits and clearances v. Personal protective equipment (PPE) e. Human performance, addressing HuP Error Prevention tools for each Critical/Irreversible Step relevant to risks with industrial and environmental safety as well as risks to operations/production. f. Special requirements or unusual conditions (as applicable): i. Resources, tools, and material ii. Environmental conditions (Hot, Cold, etc.) iii. Environmental Hazards iv. Foreign material exclusion (FME) and housekeeping v. Interfaces with other organizations vi. Interaction with other activities planned or in progress vii. Communication methods and potential obstacles to their effectiveness g. Operating experience, specifying how similar errors, events, or the causes of similar events will be avoided. h. Stop-work criteria, reviewing contingencies, changes in task conditions or its scope, and person(s) responsible for making critical decisions. i. Oversight, defining the degree of management and supervisory involvement j. Questions and concerns workers may have with the job Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 9 I.B. Abel, Inc. – Confidential – All Rights Reserved

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i. Post-Job Briefs i. Post-Job reviews are the most important feedback organizations receive, but also the least effectively used by most facilities. After the work is completed, there should be some type of post-job briefing. A post-job briefing is a meeting of workers and supervisors conducted after job completion to identify what worked well and what could have been differently. The most important aspect of preventing events is feedback/ operating experience after job performance which includes a Post-Job Review and incorporating lessons learned into future jobs. j. Self-Checking (S.T.A.R) i. Individual attention varies. This technique boosts attention at important points in an activity before a specific act is executed. The performer pauses to focus his or her attention, taking a moment to reflect on the intended action, the component, and its expected outcome. The performer thinks about whether the proposed action is the right action for the situation. In an example of similar equipment switches in close proximity to a switch that must be manipulated, self-checking could be used to verify the correct switch is selected. The common accepted practice for self- checking is the S.T.A.R. process. Self-checking Stop, Think, Act, Review is probably the single most important tool in the Human Performance tool bag. Applying S.T.A.R. is a management technique to help focus attention on intended actions or activities and their expected outcomes before the work is performed. 1. Stop – Pause before performing critical tasks or when distracted or interrupted. 2. Think – Understand what is to be done. Apply a good questioning attitude. 3. Act – Follow procedures and policies. Perform planned actions. 4. Review – Verify the outputs or results match the expected outcome. Notify your supervisor, as needed. k. Peer Check i. Peer-checking allows another individual to observe or check the work of a performer to ensure correct performance of a specific set of actions. Peer-checking involves having a second knowledgeable individual verify that the action planned by the performer is appropriate before execution and occurs according to plan. The purpose of peer-checking is to prevent error. Peer- Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 10 I.B. Abel, Inc. – Confidential – All Rights Reserved

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checking involves two persons (performer and checker) self- checking in parallel on the same action. This technique takes advantage of a fresh set of eyes not trapped by the performer’s task-related mind-set. The checker may ―see hazards or potential consequences the performer does not see. Peer- checking augments self-checking but does not replace it for the performer. Peer checking is not intended to oversee an entire activity or job. Peer checking could be used similar to self- checking in the example of close or identical switches mentioned above to ensure the correct component switch is selected. 1. It is a well-known fact that teams are more successful than individuals. Peer checking provides a “team of two”. 2. Make a habit of asking for a ‘Peer Check’. 3. Determine during the Tailboard whom the ‘Peer’ is going to be if required. 4. Pre-determine when the peer check should apply when the job is Complex, Infrequent, potential for Adverse conditions, Irrecoverable action potential. 5. All employees should become proficient in using the Buddy System and make this tool a normal way of doing work. How to do it: a. Performer explains intended action Prior to taking action b. The peer checker confirms component & action are correct with the directions. c. The peer checker communicates to the performer that the actions are satisfactory with a verbal acknowledgement, such as, SAT or I agree/concur. d. Performer performs the action e. The peer checker confirms the expected results occurred. l. Two-minute rule i. Sometimes referred to as the “Job-Site Review” and “Take Two,” a carefully performed Two-Minute Rule review will take as much time as needed to help the worker develop an accurate understanding of critical indicators, system/equipment condition, the work environment, hazards, and even team members. Taking the time necessary to get acquainted with the immediate work area helps people establish a healthy sense of uneasiness, boosting their questioning attitude and enhancing the accuracy of Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 11 I.B. Abel, Inc. – Confidential – All Rights Reserved

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their situation awareness. In addition to the Two-Minute Rule, the Job Hazard Analysis (JHA) form is the tool used by all personnel to identify and control workplace hazards. The JHA form is to be completed at the worksite and reviewed by all personnel involved in the job prior to performing work. The pre-job brief/tailboard/huddle lists potential hazards as well as potential controls for personnel to implement. 1. What: a. A fundamental HuP tool that helps the worker develop an accurate understanding of the work environment, associated hazards, equipment condition/status, and other critical work site attributes. 2. Why: a. Improves situational awareness of the job site. 3. When: a. Upon arriving at the physical work location. b. Prior to interaction with risk-important equipment. c. During a walk down. d. When a potential safety hazard is present. e. After extended breaks or interruptions, such as lunch. m. Stop/Time-out i. Employees shall conduct a Stop/Time-out when an employee encounters any of the following conditions: a. When uncertainty, doubt, confusion, or questions persist b. If outside of conditions assumed by a technical procedure c. When encountering conditions inconsistent with the procedure d. When outside the bounds of key parameters e. If beyond the scope of the plan or process f. When feeling distrustful of another individual g. When unexpected results or unfamiliar situations are encountered h. When something expected does not happen i. When there is uncertainty regarding compliance with expectations or procedures j. When unfamiliar with an important work situation Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 12 I.B. Abel, Inc. – Confidential – All Rights Reserved

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k. When inexperienced or lacking knowledge with a task l. When someone else expresses doubt or concern ii. Stop/Time-Out involves a stoppage of work to allow workers, a supervisor, or other knowledgeable people to resolve the issue before resuming the task. iii. All employees are empowered and expected to stop work when unsure of a work method or it does not feel safe to complete the task. Work will not resume until all issues and concerns are addressed. iv. No Employee will be reprimanded for performing a Stop/Time-Out. Whenever a question arises and what to do is uncertain, stop and ask! Inaccurate risk perceptions by workers may indicate an error likely situation where clear expectations to stop if certain conditions present themselves could mitigate an error. v. To fully take a Stop/Time-Out, a peer check shall be performed by a person outside the situation. The Stop/Time-Out hotline (Utility - 717- 461-2716, Elec/Comm – 717-419-5507) shall be used to gain an outside peer check. The hotline is monitored by the Safety & Quality Department. vi. IBA trains all employees in their responsibility and authority to STOP work when uncertainty persists, even if it seems simple and straightforward. This training is held during initial On-Boarding and on an on-going basis. Training is documented by date and signature of the trainee. vii. Remember, if in doubt – STOP and take a TIMEOUT! NEVER PROCEED IF YOU ARE UNSURE! viii. Steps of the Stop/Time-Out Process: 1. STOP the activity and establish safe conditions. 2. ALLOW adequate time to understand the situation. Discuss the situation with crew members to determine if uncertainty can be resolved. 3. REVIEW technical data and procedures and call the Stop/Time-out hotline (Utility - 717-461-2716, Elec/Comm – 717-419-5507) 4. PERFORM a revised Pre-Job Brief (PJB) to establish a safe work plan. a. Ensure all team members are comfortable with continuing. b. Discuss changes from original PJB and revised work plan as a result of the Stop/Time-Out Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 13 I.B. Abel, Inc. – Confidential – All Rights Reserved

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5. DOCUMENT the Stop/Time-Out as a “Good Catch” on SharePoint. a. IBA documents Stop/Time-Outs as means to learn from the situation and share with others in the company who may encounter a similar situation. b. Employees are rewarded for submitting Good Catches. c. All Good Catches are reviewed by IBA Management. n. Questioning Attitude i. Use a questioning attitude when your “gut feelings” tell you something is not right. A questioning attitude fosters awareness of uncertainty and hazards. Recognizing hazards or error-likely situations while on the job is greatly dependent on this attitude. Before starting a job at work or at home, always ask yourself the following Four Key questions: 1. Are we working with an error-likely situation? (Review error traps and HuP tools) 2. What are our Critical/Irreversible Steps for this job and tasks? 3. How can we make a mistake at this point? 4. What barriers or defenses are need? ii. A questioning attitude fosters situational awareness, encouraging thought about safety before action is taken. Being mindful of the work situation helps a person maintain an accurate understanding of work conditions at any given time, avoiding blind spots. iii. This tool alerts people to imminent hazards, warning signs, and uncertainties in the work environment or with the work plan and encourages the user to stop and resolve those hazards, warnings, or uncertainties before proceeding with the job. Doubt must be followed up with the discovery of facts, not assumptions, to reveal more knowledge about the situation, which eliminates the doubt. Complacency and lack of knowledge undermine awareness. Most people tend to assume everything is alright and that activities always go as planned. Also, a weak knowledge of fundamental sciences, theory, and equipment design has contributed to unawareness of what is happening. You don’t know what you don’t know. People in general, are reluctant to fear the worst, and a healthy questioning attitude will overcome the temptation to rationalize away gut feelings that something is not right. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 14 I.B. Abel, Inc. – Confidential – All Rights Reserved

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iv. Situational awareness is a type of Questioning Attitude that is the accuracy of a person’s current knowledge and understanding of the task at hand and related working conditions compared to actual conditions at a given time. Accurate knowledge and understanding (mental model) of relevant information from the work environment guides an individual’s decisions and actions. Situational awareness demands the individual to clearly understand the job requirements, the equipment condition, and work environment before acting. If there is any uncertainty or confusion, the work should be stopped, and the situation addressed before workers continue with the task. Setting a tone of uneasiness sensitizes a worker to detect unsafe conditions he or she may not see otherwise. Whenever a question arises, and it is not clear what to do, stop and ask! Every person has the responsibility and authority to STOP work when uncertainty persists, even if it seems simple and straight forward. Things are not always as they seem. o. Effective Communications i. The goal of effective communication is mutual understanding between two or more people, especially communication involving technical information related to operations or personnel safety. Effective communication is likely the most important defense in the prevention of errors and events. However, verbal communication possesses a greater risk of misunderstanding compared to written forms of communication. Misunderstandings are most likely to occur when the individuals involved have different understandings or mental models of the current work situation or use terms that are potentially confusing. Therefore, confirmation of verbal exchanges of operational information between persons must occur to promote understanding and reliability of the communication (3-way communication). If one person is reading a procedure during a critical task from a remote location to another person, this creates an error likely situation if the method of communication is not clear. When communicating, it is important to have a mutual understanding between two or more workers. The person sending the message has the responsibility to ensure the person receiving the message understands it. Using 3-part communication is a way to ensure this happens, especially when communicating critical information. This closed-loop communication process is performed like this: Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 15 I.B. Abel, Inc. – Confidential – All Rights Reserved

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1. The sender initiates the verbal communication. 2. The receiver acknowledges the communication by repeating it back to the sender. 3. The sender acknowledges the repeat-back is correct. 4. Remember, good communications among employees helps keep people safe and maintain the integrity of the transmission and distribution systems. All employees are expected to communicate effectively at all levels of the organization.

p. Phonetic Alphabet i. Several letters in the English language sound alike and can be confused in stressful or noisy situations. The phonetic alphabet specifies a word for each letter of the English alphabet. By using a word for each letter there is less chance that the person listening will confuse the letters. For example, some letters sound alike when spoken and can easily be confused such as "D" and "B". Using the phonetic alphabet, "Delta" and "Bravo" are more easily differentiated. The effects of noise, weak telephone or radio signals, and an individual’s accent are reduced through the use of the phonetic alphabet. q. Procedure use and adherence i. Procedure adherence means understanding the procedure’s intent and purpose and following its direction. The user performs all actions as written in the sequence specified by the document. However, if it cannot be used as written, then the activity is stopped, and the procedure is corrected before continuing. Following the procedure without question does not guarantee safety because procedures sometimes contain hidden flaws. But, understanding the overall purpose and strategy of the procedure promotes safer outcomes. Ideally, adhering to procedures keeps the plant’s configuration within its safety analyses and licensing requirements. Procedure quality is paramount to safety and reliability. The completeness, accuracy, and internal consistency of the instructions, and its usability (easy to understand and follow) all impact the user. Procedures have been written over the Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 16 I.B. Abel, Inc. – Confidential – All Rights Reserved

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years based on experience and proven uses of equipment. Procedures MUST be followed. Short cuts are often precursors of error. Positive and negative consequences can be used to reinforce desired behaviors which will alter people’s experience and, therefore, their behavior. Ignoring worker’s actions is an automatic positive reinforcement. Not acting on non-adherence to procedures is, by default, acceptance of the bad practice. Negative consequences must immediately follow workers choice not to follow procedure. Management needs to be intrusive (in the field) and intervene from time to time when behaviors are not within expectations. Procedure use expectations must be crystal clear and reinforced every day to influence behaviors. Timely management response to worker proposed revisions/improvements is a key area where workers will view how management values feedback. Tribal/corporate knowledge needs to be reflected in procedures for the new worker. For critical task work, job walk-downs should be performed with the instructions in hand to determine if all hazards are addressed. Qualified Observations r. Qualified Observers – Any assigned individual who has received training on the observation process that includes how to conduct the observation, how to complete the observation form, what do the behaviors mean, feedback training and role play (mentoring and coaching), and employees will be aware they may be observed at any time. i. All assigned observers have received observation training and Introduction to Human Performance, and Human Performance II training. s. Observation Criteria – All observations are collected within the IBA SharePoint Safety Database to perform trend analysis. All observations focus on behaviors within each category that delineate between a behavior that “meets expectations” and those that are “improvement opportunities”. The categories are as follows: Human Performance, Fundamental Safety Standards, Ergonomic Posture, Pre-Job Briefing, Energized Work Methods, Work Area Issues, Switching, Permit and Tag, Vehicle and Equipment Ratings, and Material Handling and Rigging. i. Any “improvement opportunity” deficiencies will result in immediate coaching and further corrective action based on the following criteria: 1. Any Serious Six violation will result in an immediate stand- down of the crew with escalation to the appropriate Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 17 I.B. Abel, Inc. – Confidential – All Rights Reserved

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manager and the Safety & Quality Department. Serious Six infractions include the absence or lack of PPE Infractions, Fall Protection Rules, Insulate and Isolate, Switching and Tagging, Testing and Grounding, and Comprehensive Pre- Job Briefings. 2. Any deficiency that scores less than a 95% in their observed trend will warrant corrective action. a. Corrective actions for trend deficiencies include weekly Safety & Quality Topics, Tool Box Talks, Safety Bulletins, training, or specific corrective action. All assigned action items will be monitored to ensure completion with the Safety & Quality Administrator.

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Employee Responsibility for Safety

1. All Employees (including Short Service Employees): a. Act as the “Competent Person” as defined by OSHA. i. Competent Person – one who is capable of identifying existing and predictable hazards in the surrounding or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has the authority to take prompt corrective action. b. Report any unsafe working condition to immediate supervisor. All employees can report an unsafe condition without fear of reprimand. c. Keep individual work area in a clean, orderly and safe condition. d. Report ALL incidents and/or near misses to supervisor immediately. Cooperate with any necessary incident investigation. e. All employees are trained in first aid, and are required to notify their supervisor if they are fatigued, or otherwise compromised and cannot perform their duties safely f. Treat with an approved panel physician for any work-related injury or illness requiring medical attention. Follow any work restrictions prescribed by the treating physician (see Transitional Duty Program in this section). g. Follow all safety and health rules. h. When in doubt – ask your supervisor i. Maintain a positive attitude toward safety and cooperate fully to ensure a safe, healthful workplace for all employees. j. Utilize Human Performance Tools and Principles. k. Employees are required to provide training documents, recognitions and demonstrate qualification for their role. 2. Supervisors a. Act as the “Competent Person” as defined by OSHA. i. Competent Person – one who is capable of identifying existing and predictable hazards in the surrounding or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has the authority to take prompt corrective action. b. Must ensure that all jobs must have a preconstruction meeting, hazard assessment, and pre-job brief. c. Set a positive example by following all safety and health rules.

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d. Responsible for ensuring the safety of all employees under their management. e. Responsible for on-the-job training for safe work practices and safety regulations. f. Correct all unsafe working conditions immediately upon discovery. g. Conduct frequent and regular inspections of the job site to identify hazardous conditions. h. Notify the Safety & Quality Department immediately of any injury accidents or significant property, equipment or utility damage. Investigate any reported incident immediately and complete the appropriate Incident Report form and turn in to office within 24 hours. i. Accommodate work restrictions of injured/ill employees assigned to the Transitional Duty Program. Supervisors must make sure employees working under doctor-ordered work restrictions do not exceed their restrictions. j. Enforce all safety and health rules with a positive attitude and stress the importance of working safely. k. Issue Corrective Coaching Notices as necessary to discipline employees in non-compliance with safety and health rules. l. Utilize Human Performance Tools and Principles. 3. Short Service Employees (SSE) – All short service employees will be on-boarded prior to working on any jobsite and will abide by all safety rules and expectations as specified in the IBA Safety & Quality Manual. a. A Short Service Employee is an employee with less than six months with the employer b. A short service employee may not work alone c. The host facility must be notified where an SSE will be working at their site. d. All journeymen and foreman will act as mentors for the first six months of employment for the SSE. e. Onboarding - Supervisors will assure that all new, transferred and temporary employees have been through IBA Safety Orientation and have a complete knowledge of the expectations for their job function. ii. All SSE’s will be visually identified with a green and yellow sticker on their hardhats. This sticker will be applied after the employee’s initial onboarding. 1. All stickers will be removed concluding the SSE’s 180 days of service. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 20 I.B. Abel, Inc. – Confidential – All Rights Reserved

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iii. Supervisors will identify all employees and temporary personnel with less than 180 days of service, or those employees they desire to return to a mentoring status for improvement in job and/or safety performance. Any Short Service Employee experiencing an OSHA Recordable injury during the initial 180 days will repeat the mentoring program or shall be dismissed for poor performance. iv. SSE are monitored for compliance with SQP policies and procedures. f. Subcontractors must adhere to the requirements of the SSE program. 4. Safety Committees a. Conduct monthly meeting to discuss incidents, inspections and any other safety or health issues. b. To discuss, develop, and implement new policy. c. Perform monthly job site inspections to ensure compliance with all safety and health rules. d. Utilize Human Performance Tools and Principles. 5. Safety & Quality Department a. Act as the “Competent Person” as defined by OSHA. b. Competent Person – one who is capable of identifying existing and predictable hazards in the surrounding or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has the authority to take prompt corrective action. c. Must ensure that all jobs must have a preconstruction meeting, hazard assessment, and pre-job brief. d. Coordinate all aspects of the Safety & Quality Program. e. Conduct incident investigations to identify root causes and initiate corrective actions to prevent recurrence. f. Inspect job sites to ensure compliance with all safety, quality, and health rules. g. Ensure compliance with all federal, state, local, and customer regulations. h. Act as a resource to all levels of the company regarding matters of worker safety, quality, and health. i. Utilize Human Performance Tools and Principles.

Safety Manual

6. Management (Executive Safety Committee) a. Maintain an organizational chart with job titles and roles established for the company. This is supplemented with job descriptions and identifies minimum qualifications for the jobs. b. Actively support and participate in the company safety program. c. Ensure adequate training and education programs are in place for all levels of employees. d. Set a positive example by following all safety and health rules while on job sites. e. Perform jobsite inspections. f. Utilize Human Performance Tools and Principles. g. Employees are provided all applicable job specific training related to their role at IBA. Employees are assessed for competency by their superior before given the accountability and responsibility of completing tasks.

Safety Manual

Safety Training and Education

1. The following courses are offered throughout the year for employees of I.B. Abel, Inc. (IBA). This list can be expanded at any time as new training is warranted by the work we are performing or at our customer’s request. a. New Hire Orientation (IBA on-boarding process). All field employees receive on-boarding as appropriate for the industry and receive a copy of the Safety Handbook prior to the start of work. This training includes the following: i. IBA Expectations ii. Human Performance – the initial training includes an introduction to Human Performance Principles. The principles are listed below. (See Human Performance Section for more on each principle.) b. OSHA 10 Hour Construction Safety and Health Course or the appropriate Partnership training is offered year-round. The following topics are offered as well: i. Information about OSHA 1. General Duty Clause and General Safety and Health Requirements a. Competent Person requirements b. Personal Protective Equipment and Respiratory Protective Equipment c. Fall Protection i. Fall protection requirements ii. Fall protection systems criteria d. Electrical Hazards i. Requirements of OSHA's Subpart K ii. Safety around power lines iii. Lockout/Tagout e. Excavation f. Scaffolds g. Hazard Communication i. Material Safety Data Sheets ii. Container Labeling methods iii. Common hazardous materials used in construction and protective measures h. Stairways and Ladders i. Permit Required Confined Spaces Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 23 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

j. Fire Protection and Prevention c. Weekly Safety & Quality Topics are communicated via conference call, written agenda, and through group discussions at the jobsites. The discussions are documented, and sign-in-sheets are submitted. d. Weekly “Toolbox Talks”. Toolbox talks are conducted weekly by each field supervisor. Toolbox talks are held to discuss the following: i. The topic provided by the Safety & Quality Department including any discussion questions, ii. Upcoming work on the project and any potential safety or health hazards and their control measures, iii. The results of any safety inspections or incident investigations conducted within the previous week. e. American Red Cross First Aid and CPR as well as Coyne First Aid and CPR. f. NFPA 70E. Standard for Electrical Safety in the Workplace. g. National Safety Council Defensive Driving. All drivers of company owned vehicles attend a defensive driving course based on the National Safety Council curriculum. h. Commercial Motor Vehicle Driver Training. CDL drivers attend additional driver training in addition to the National Safety Council course. The course focuses on DOT compliance in addition to the safety hazards inherent in operating larger vehicles. i. Equipment Operator Training. Heavy Equipment operators attend various levels of equipment operator training with an emphasis on safety. j. Aerial Lift Training. Employees are trained on the use of scissor type and boom type aerial lifts. k. Forklift Training. Forklift operators are trained on rough terrain and industrial forklifts. i. Only trained and certified operators are authorized to operate the equipment. ii. Training programs will be provided by a qualified instructor and shall include formal instruction, practical training and operator evaluation in the workplace. iii. Operators shall be trained to verify all weights and strains of potential loads against specific equipment’s capacity. iv. Operators will receive mandatory refresher training and list the elements when retraining is required. As well as when the following occur: unsafe operations, accident, different vehicle type, and changes in condition. v. All operators shall be re-evaluated at least every three years. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 24 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

vi. Operators shall inspect the equipment daily or before each shift. vii. Operator shall verify trailer chocks, supports and dock plates prior to loading/unloading. l. MSHA Part 46 Training. Employees required to work on mine properties receive training required by MSHA's Part 46 and be kept current. m. Competent Person Training. Specialized courses are offered for trenching and excavation and scaffolding competent persons. n. HAZWOPER. Employees working on uncontrolled hazardous waste sites will attend an appropriate Hazardous Waste Operations and Emergency Response course. o. Powder Actuated Tools. Operators of powder actuated tools (Hilti, Ramset guns) will receive training from an authorized provider. p. Crane Institute of America Certification training is offered year-round. Employees are certified upon completion of the training and passing a test. q. Human Performance Tools, Principles, and awareness training occurs on a quarterly basis as well as through safety correspondences in the form of safety topics, alerts, stand-downs, and Tool Box Talks. r. In the absence of medical assistance that is reasonably accessible in terms of time and distance to worksite there shall be a person trained with valid certification in CPR/First Aid on site. s. A valid certificate in first aid training must be obtained from the U.S. Bureau of Mines, the American Red Cross, COYNE First Aid, or equivalent documented and verifiable training t. First aid kits shall consist of appropriate items determined to be adequate to the environment in which they will be used. u. The contents of first aid shall be periodically assessed to ensure availability of adequate first aid supplies.

Safety Manual

Incident Reporting and Investigation

1. Incident Reporting a. Our incident reporting steps are below. Please note that all near misses or good catches should be reported in the same fashion. Any questions should be directed to the IBA Safety & Quality Department.

Root Cause Analysis Contact IBA leadership and then customer Contact Safey & leadership Quality Department and Project Lead Contact Foreman/PM

Make area safe, contact 911, customer rep

Incident Notification Contact List (in order) 1. Call 911for all vehicle incidents on public road or injuries beyond first aid. 2. Contact Customer Representative as per customer procedure 3. IBA Foreman or Project Manager 4. Safety & Quality Department / Project Manager or lead 5. IBA Leadership 6. Customer Leadership 7. Root Cause Analysis

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2. Incident Investigations a. Purpose. A thorough incident investigation is to be completed for every incident to identify root causes and recommend appropriate corrective actions. b. All incidents will be investigated by the specific individual(s) to the appropriate level with regards to the incident severity as soon as possible after the incident occurs.

Safety Manual

Transitional Duty

1. Employees sustaining work-related injuries or illnesses requiring temporary physical limitations will be accommodated with work through the Transitional Duty Program. 2. Benefits of the Transitional Duty Program. a. Speeds up an employee’s return to normal job assignment b. Keeps injured/ill employees productive. c. Employees earn their normal wage during the transitional period. d. Lowers insurance costs, making the company more profitable 3. Definitions a. Transitional Duty. Temporary work performed during the period between a work-related injury/illness and the time that a full release is obtained from the treating physician. Transitional Duty is also referred to as light duty or return-to-work duty. b. Transitional Duty Team. The Transitional Team consists of the injured/ill employee, the employee’s Division Manager, the employee’s immediate supervisor, the Workers Compensation Coordinator, and members of the Safety Department as necessary. c. Work Restrictions. A set of parameters assigned by the treating physician to limit further injury or illness to an employee involved in a work-related incident. Examples of work restrictions include “No lifting more than 25 pounds”, or “No operating heavy equipment”. d. Panel Physician. A designated health care provider approved for work- related injuries and illnesses. Panel Physicians are listed in the Workers Compensation Program. All supervisors should have a complete list. 4. Procedures. e. Employees must immediately notify their supervisor of any work-related injury or illness. Incidents are to be reported as required by this section – Incident Reporting and Investigation f. The supervisor will instruct the employee that if medical attention is necessary, they must treat with a panel physician. Transportation will be arranged if necessary. g. After an examination, and any necessary treatment, the treating physician may assign work restrictions. Work restrictions will be reviewed with the employee by the panel physician. A copy of the work restrictions will be faxed to the Workers Compensation Coordinator. h. Injured or ill employees are responsible for reporting to the Workers Compensation Coordinator with their work restrictions at or before the Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 28 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

start of the next work shift. All Worker’s Compensation updates are to be communicated to the Safety & Quality Risk Manager. i. Members of the Transitional Duty Team will be notified of the injured/ill employee’s restrictions and transitional duty options will be considered. 5. Transitional Duty Options. j. Upon receiving work restrictions, the Transitional Duty Team will determine the best option for Transitional Duty for the injured/ill employee. i. Return to original job assignment. If possible, the injured/ill employee will return to their normal work assignment modified to fit their restrictions. ii. Return to Division. Transitional work within the employee’s division is the next option. If an injured/ill employee cannot return to their normal job assignment, work will be sought elsewhere within that employee’s division. iii. General Light Duty Work. If the injured/ill employee cannot be accommodated at their regularly scheduled job, or within their division, general Light Duty work will be assigned. Light Duty work may involve clerical work such as filing reports; painting in and around the yard area; cleaning, etc. 6. Miscellaneous. k. Transitional duty will be limited to an eight-hour workday, Monday through Friday, unless the treating physician’s work restrictions are more restrictive. An employee who is on Transitional duty may not be assigned “storm” duty for the USD. l. Employees assigned to transitional duty will receive their normal rate of pay. m. Restrictions and transitional duty work options will be re-evaluated after every follow-up doctor appointment and the employee must not miss any follow-up appointments without prior notification to the worker’s compensation coordinator 7. Transitional Duty is only available for employees with temporary restrictions. Transitional Duty will not be used for employees with permanent work restrictions.

Safety Manual

Fatigue Management

1. Fatigue Management a. Fatigue is extreme tiredness resulting from mental or physical exertion or illness. In the workplace, fatigue can impact a person’s ability to perform work safely and effectively. Fatigue can be work related or non-work related or a combination of both. i. Short Term effects 1. Excessive yawning or falling asleep at work 2. Short term memory problems and inability to concentrate 3. Noticeably reduced capacity to engage in effective interpersonal communication 4. Impaired decision-making and judgment 5. Reduced hand-eye coordination or slow reflexes „ 6. Other changes in behavior, for example repeatedly arriving late for work 7. Increased rates of unplanned absence. ii. Long Term effects 1. Heart Disease 2. Diabetes 3. High Blood Pressure 4. Gastrointestinal Disorders 5. Lower Fertility 6. Anxiety 7. Depression iii. Why is fatigue a problem? iv. Fatigue may adversely affect safety within the workplace v. Fatigue reduces alertness which may lead to errors and increase the chance for incidents and injuries. vi. Fatigue Management – why is it important? 2. Managing Fatigue a. Employees are trained in fatigue management and control on an initial and ongoing basis. b. Employees are expected to work no more than 16-hour shifts unless there is an emergent issue and the employee feels they can safely perform the task. c. When employees change from one shift to another shift, the employees should acknowledge this change during their pre-job briefing and discuss how the crew will refocus from the change in shift.

Safety Manual

d. The company addresses potential fatigue issues during the site-specific safety plan, pre-job briefing and risk assessment. In addition, employees are encouraged to take breaks when completing repetitive tasks or during high pressure tasks. e. The company provides ergonomic equipment for employees use. The company encourages employees to suggest new equipment and tools that are make their jobs easier and that are ergonomically friendly. f. Employees are expected to report to their supervisor any employee that does not seem fit for duty. This can include fatigue. g. Supervisors that receive feedback on employees that are not fit for duty due to fatigue are expected to take appropriate action to assist the employee.

Safety Manual

Substance Abuse – Commercial and Non-Commercial Driving

I.B. Abel, Inc. (IBA) has made a strong commitment to provide all of its employees with a safe working environment. In order to fulfill this commitment, IBA requires that every employee report to work in a condition that will allow him/her to be physically and mentally alert and enable the safe performance of the job. Working while under the influence of drugs or alcohol or using or possessing these substances on company premises or on working time is not in keeping with this objective. IBA, therefore, is implementing a policy to address the issue of drug or alcohol abuse in the workplace.

IBA recognizes that alcoholism and drug addiction are medical and behavioral problems that can affect anyone, including IBA employees. Substance abuse can significantly hinder a worker’s job performance, resulting in reduced quality of work and output, impaired decision making, increased accidents and safety problems and absenteeism and tardiness. Therefore, to help ensure a safe and healthful work environment for our employees, IBA will work to create and maintain a workplace free of inappropriate alcohol and drug use.

This policy applies to all current employees and applicants for employment at IBA. Employees who are covered by mandatory federal programs (i.e. Department of Transportation) will be subject to the regulations of the mandatory program as well as IBA’s policy.

Our efforts encompass the following approaches:

Prevention: Using education and drug testing of prospective employees to prevent the occurrence or spread of alcohol and drug abuse among employees,

Rehabilitation: Seeking to identify and offering the opportunity to rehabilitate those employees who are addicted to or dependent upon alcohol or drugs, and

Enforcement: Taking a strong stand against the unauthorized possession, use or sale of alcohol or drugs in the workplace by enforcing IBA corrective action policies and involving appropriate legal authorities.

Safety Manual

Commercial Drug and Alcohol Testing Policy

1. Driver Information a. This material is provided to all employee’s subject to drug and alcohol testing under the federal regulations. The regulations specify that we inform you of various aspects of the government mandated program. All information in this general handout relates to rules imposed by the United States Department of Transportation. In addition to these regulations, you are also subject to all State and local regulations as well as our company policy. Please read our company policy carefully. 2. Person Identified to Answer Questions a. As part of our continuing policy to ensure fair and equal treatment of our drivers, we understand that there may be questions and concerns involving our controlled substance and alcohol testing policies and programs. To assist you in understanding the requirements placed on both you, the driver, and us, the employer, we have designated Director of Safety & Quality to answer your questions regarding alcohol and drug testing programs. 3. Drivers Subject to Alcohol & Drug Testing a. The Federal Highway Administration of the United States Department of Transportation requires certain drivers to undergo drug and alcohol testing. The drivers who must be tested are those required to have a Commercial Driver's License (CDL). b. Any driver who drives a motor vehicle- i. With a gross combination weight rating of 26,001 or more pounds inclusive of a towed unit with a gross vehicle weight of more than 10,000 pounds; ii. With a gross vehicle weight rating of 26,001 or more pounds; iii. Designed to transport 16 or more passengers; or iv. Of any size that is used to transport hazardous material which require the vehicle to be placarded under the hazardous materials regulations. 4. Safety Sensitive Functions a. A driver shall not use alcohol when performing safety-sensitive functions nor perform safety sensitive functions within four hours of using alcohol. Most testing will be done while the driver is performing a safety-sensitive function, just before the driver is to perform a safety sensitive function, or just after the driver has ceased performing such functions. A driver shall not report for duty or remain on-duty when his or her job requires

Safety Manual

performing safety-sensitive functions if he or she has been using drugs or has tested positive for drug use. b. A driver is performing a safety sensitive function when: i. Waiting at a terminal, facility, or other property to be dispatched, unless the driver has been relieved from duty by the motor carrier; ii. Performing pre-trip inspections or servicing the motor vehicle; iii. Driving the motor vehicle; iv. On the vehicle, except when resting in the sleeper berth; v. Loading or unloading the vehicle, supervising the loading or unloading, giving receipts for the load, or remaining in readiness to operate the motor vehicle; vi. Performing duties and services at an accident scene; or, vii. Repairing, obtaining assistance, or remaining in attendance of a disabled vehicle. PROHIBITED CONDUCT A driver shall not: ✓ Report for or remain on duty performing a safety-sensitive function while having a blood alcohol concentration of 0.04 or greater; ✓ Use alcohol while performing safety-sensitive functions; ✓ Abuse controlled substances; ✓ Be on duty or operate a commercial motor vehicle while possessing alcohol unless the alcohol is manifested and transported as part of the shipment; ✓ Perform safety-sensitive functions within four hours of using alcohol (six hours for school bus drivers); ✓ Use alcohol for 8 hours following an accident unless the driver has been given a post-accident test; or ✓ Refuse to submit to a required alcohol and/or drug test involving post-accident, random reasonable suspicion, or follow-up testing.

5. When a Driver Must Be Tested a. The Federal Motor Carrier Safety Regulations are very specific regarding when a driver must submit for a drug and an alcohol test. Pre- employment and return to duty tests may be conducted at any time prior to the employee's performance of the first safety-sensitive function. Other tests may be conducted during working hours either just before or just after the performance of a safety-sensitive function. b. Types of Tests: Pre-employment, Random, Reasonable Suspicion, Post-Accident, Return to Duty and Follow-Up (if required by a substance abuse professional). Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 34 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

6. Refusal to Submit to a Test a. The Federal Motor Carrier Safety Regulations provide that a driver shall not refuse to submit to a post-accident test, reasonable suspicion test, random selection test, or follow-up test. No motor carrier shall permit a driver who refuses to submit to a required test to perform or continue to perform safety-sensitive functions. b. In alcohol testing, the refusal to sign the certification in Step 2 on the form is regarded as a refusal to take the test. Not providing an adequate amount of breath may, under certain conditions, be regarded as a refusal to take a test. In drug testing, failure to provide sufficient urine may constitute a refusal. c. Persons not producing an adequate specimen may be referred to a physician to determine the problem. d. Not reporting to a test site or taking an unreasonably long time to report to the site may also be regarded as a refusal. 7. Consequence of a Positive Test a. The penalties listed below represent the minimum penalties required by law. If you test positive, you will be subject to penalties according to the employer's policy which may include suspension or termination. Furthermore, the federal regulations do not require the employer to take back a driver who has completed rehabilitation. A driver who tests 0.04 or above: i. Cannot perform a safety-sensitive function, ii. Will be made aware of resources for solving alcohol and drug problems, iii. Must be evaluated by a substance abuse professional (SAP), iv. Comply with treatment recommendations, and v. Must undergo a return to duty alcohol test with a negative test result. b. The positive tested driver will also be subject to unannounced follow-up alcohol tests for up to 5 years depending on the evaluation of the substance abuse professional. 8. CONSEQUENCES OF A TEST OVER 0.02 BAC BUT LESS THAN 0.04 BAC a. No driver who is found to have a BAC of 0.02 or greater but less than 0.04 shall perform safety sensitive functions for at least 24 hours following the test. 9. CONSEQUENCES OF A POSITIVE DRUG TEST a. A driver who tests positive for drugs i. Cannot perform a safety-sensitive function, ii. Must be evaluated by a Substance Abuse Professional (SAP), Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 35 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

iii. Comply with treatment recommendations, and iv. Must undergo a return-to-duty drug test with a negative test result. b. The positive tested driver will also be subject to unannounced follow-up drug tests for up to 5 years as recommended by the evaluation of the substance abuse professional. c. For information on where to find treatment for alcohol and other drug problems, consult your union or employers Employee Assistance Program.

Safety Manual

Non-Commercial and General Drug and Alcohol Testing Policy

1. Education a. I.B. Abel, Inc. (IBA) will provide employees and their families with information about the dangers of substance abuse, its impact on home and work life, the Company’s substance abuse policy, the counseling and rehabilitation services the Company makes available to employees and the workplace penalties that may be imposed on individuals who fail to successfully deal with their substance abuse problems. 2. Self-Identification a. The key to successful intervention and treatment of substance abuse is early and voluntary efforts to seek help. IBA encourages employees who are addicted to or dependent upon alcohol or drugs to voluntarily seek assistance before problems arise on the job or at home. The resources of our Employee Assistance Program (EAP) are available to help employees who self-identify. b. All employees shall inform their superior when they are taking prescription or over the counter medication that could impair their ability to work safely. c. Substance abuse is a treatable illness. IBA is concerned for the welfare of any individual who is addicted to or dependent upon alcohol or drugs, and is committed to providing opportunities to help employees with a substance abuse problem to correct the problem and to achieve a meaningful and productive life at work, at home and in the community. d. Substance abuse is not easily resolved by personal effort and may require professional assistance and treatment. With that in mind, IBA provides its employees with the assistance of our EAP and other resources to assist in the evaluation and treatment of substance abuse. e. All employees are encouraged to notify their superior in the event that there is behavior and/or activity changes that occur with an employee immediately to prevent incidents and injuries. Management will then determine if the employee should be removed from the work site. 3. Substance Abuse Testing a. All employees will be subject to drug and alcohol testing regardless of whether or not they are covered by our Department of Transportation Drug Testing Program. IBA will conduct drug and/or alcohol testing under the following circumstances: i. Pre-Employment Screening

Safety Manual

1. IBA will not employ a person who fails a pre-employment drug or alcohol screen. a. No job offer will be considered final until negative drug and alcohol test results have been received. b. Should an applicant elect not to undergo a pre- employment drug or alcohol test or if the applicants test is confirmed positive, he/she will be ineligible for a period of one year. 2. All job applicants will be informed at time of application of the Company’s substance abuse policy and informed that any offer of employment will be conditioned on successful completion of a pre-employment drug and alcohol test. 3. Pre-employment drug and alcohol testing will be carried out in accordance with the procedures outlined in the IBA Employee Handbook. All CDL drug and alcohol testing will be carried out according to the Federal Motor Carrier Safety Administration guidelines contained in 49 CFR Part 382. Drivers cannot perform any safety sensitive functions (as defined by the Federal Motor Carrier Safety Administration) until negative testing results are received. 4. In the event that the results of an applicant’s initial drug or alcohol test are positive, additional confirmation testing will be performed. If a positive test is confirmed, the Human Resource Department will be notified, and the offer of employment will be revoked. 5. Should an applicant elect not to undergo a pre- employment drug or alcohol test or if the applicant’s confirmed test is positive, he/she will be ineligible for employment based upon failure to satisfactorily complete the pre-employment drug or alcohol test. ii. Post-Incident Testing 1. When a driver or employee is in an incident where: a. A human fatality is involved. b. The driver has been issued a citation and bodily injury with immediate medical treatment away from the scene has occurred as a result of the incident. c. The driver has been issued a citation and disabling damage to any motor vehicle requiring tow-away has occurred as a result of the incident, the driver

Safety Manual

or employee must submit to the appropriate drug and alcohol test. d. Requires the employee or another to receive professional care at an off-site medical facility (injuries beyond first aid). e. Results in property damage that is expected to exceed $1,000, all employees involved must submit to a drug and alcohol test. f. Employees may also be subjected to customer specific post-incident requirements. g. Any ESE requires an immediate drug and alcohol test. h. The test shall be administered at an approved IBA testing facility or an IBA representative shall administer an oral drug and alcohol screening test. 2. Following any incident, employees must immediately contact the Company. The driver shall follow the instructions given by Company representatives. 3. Post-incident testing will be performed as soon as possible after an incident. In the event that federal, state, or local officials, following an incident, conduct breath or blood tests for the use of alcohol and/or urine tests for the use of drugs, these tests may be considered to meet the requirements of this policy. In such instances, the employee must allow the Company to obtain the test results. iii. “Reasonable Cause” or Fitness for Duty Testing 1. If a supervisor who has the required training suspects that an employee may be working under the influence of alcohol or drugs, he/she should refer the employee to Occupational Health Services for reasonable cause substance abuse testing and/or a Fitness-for-Duty Evaluation. The suspicion should be based on objective observations, the employee’s job performance or personal conduct at work, and documented as witnessed on the Substance Abuse Reasonable Cause Form provided by Human Resources. 2. IBA assesses the physical capacity of all employees upon offer of employment to ensure that they are capable of performing their job functions. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 39 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

iv. Random Testing 1. Random testing of non-CDL employees will only be conducted as provided for in the most recent labor agreement. 2. Random selection of CDL drivers shall be conducted throughout the year through the Work First Consortium or through the Local Union Random Pool. The minimum annual percentage rates for random drug and alcohol testing for drivers are subject to change pursuant to regulations issued by the Federal Motor Carrier Safety Administration. 3. Random selection, by its very nature, may result in employees being tested in successive random selections or more than once a calendar year. Alternatively, some employees may not be selected in a calendar year. 4. Individuals selected for random testing will be notified by the Company. If a randomly selected individual engages in conduct that does not lead to a collection, such conduct may be considered a refusal to test. v. Return to work 1. If an employee has entered a rehabilitation program, upon completion of the prescribed treatment and recommendation from the treating agency/provider, the employee will be permitted to return to work with the understanding that he/she will be subject to periodic, random drug and/or alcohol follow-up testing. 2. Should a third future random follow-up, post-injury, or “reasonable cause” drug or alcohol test be confirmed positive, the employee will be terminated immediately and will not be eligible for rehire. 3. As a condition of employment, employees going through or having completed a rehabilitation program are required to achieve and maintain a satisfactory level of job performance, personal conduct and attendance. Failure to do so can result in corrective action up to and including termination of employment. 4. Enforcement a. The unauthorized use or possession of alcohol or illegal drugs on company property or while on company business is prohibited and

Safety Manual

subjects the employee to corrective action up to and including termination of employment. b. An employee reporting to work with a detectable level of illegal drugs in his/her system or with a blood alcohol content (BAC) of .02 or greater will be subject to corrective action, up to termination. c. The sale, trade or delivery of an illegal drug on company property or while on company business is prohibited and cause for immediate termination of employment. IBA will, at its discretion, refer instances of sale, trade or delivery of illegal drugs to the proper legal authorities. d. IBA will notify and cooperate with law enforcement, private investigation or security firms should reasonable information indicate the presence of illegal drugs on company property or the involvement of an employee in illegal drug activity. e. Where the Company has reason to believe that an employee is in violation of the Company’s Substance Abuse policy, he or she may be asked to submit immediately to a search of his or her person and/or to make his or her toolbox, lunch box, packages, personal belongings, vehicles or any other receptacle he or she uses or has access to, available for inspection. Such search or inspection shall always be conducted in the presence of at least one witness other than the Company representative performing the search or inspection, and the contents resulting from such search or inspection shall be inventoried. Entry onto Company or customer premises (including parking lots) to perform work for the Company constitutes consent to search and inspection. Refusal to consent to search or inspection shall be considered grounds for which an employee may be disciplined, up to and including termination. f. Please note that employees who use drugs or alcohol are required to meet the same standards of performance and conduct that are set for other employees. Volunteering to submit to a rehabilitation program after violating company rules or polices may not preclude the Company from taking disciplinary action, including termination, against the employee for misconduct.

Safety Manual

Disciplinary Action

1. Typical Progression of Disciplinary Action. a. This is a typical progression of the disciplinary progress. However, the Company reserves the right to initiate the disciplinary process at any point in the sequence depending on the seriousness of the issue(s) concerned. This also includes the use of suspension of an employee’s work status until a thorough investigation is completed. i. Informal Coaching ii. Written Coaching iii. Last Chance Agreement iv. Final Coaching v. Suspension or termination

Use Culpability Matrix to tie to specific corrective action. Each corrective action will need to tie a time frame to the escalation of that issue.

Safety Manual

2. Corrective Action Process and Definitions a. Intentional acts – any action that was intended and where the consequences were intended. i. Written warning up to termination. This includes time off without pay, additional training, coaching, or any other management directed corrective action ii. Employee history will dictate severity of the corrective action. b. Possible Reckless – any action that the employee knowingly violated a reasonable, workable, intelligible, available, and correct expectation. i. Written warning up to termination. This includes time off without pay, additional training, coaching, or any other management directed corrective action ii. Employee history will dictate severity of the corrective action. c. Possible Negligent – any action that other employees may not have made the same error; and were not due to deficiencies in training, selection, or inexperience. i. Verbal warning up to written based on the severity of incident. ii. Employee history will dictate severity of the corrective action. d. Corrective Training or other intervention – events where an employee has a history of human performance problems or where the employee did not self-report the incident. i. Rigging incidents result in rigging training. ii. Driving result in… iii. Transformer results in… iv. Incident specific training… e. LSW: Organizational processes and management/supervisory methods that induced the error. f. These events are investigated and require a root cause analysis, lessons learned, and corrective actions completed by the S&Q Department. 3. Progressive Discipline/Corrective Action Checklist. The following checklist outlines the supervisor’s responsibility for taking disciplinary/corrective action. a. Before the meeting i. Ensure that there is a valid job-related reason for the disciplinary action. ii. Investigate the facts and review them objectively. iii. Ensure consistency with any prior disciplinary actions and consistency with Company policy. iv. Arrange to meet with the employee privately. Do not discipline the employee in public or in front of other workers.

Safety Manual

v. Prepare by reviewing your notes about the specific incident/problem and any past discipline you have taken, either verbal or written. vi. Consult with your supervisor/and or the Human Resources Department for guidance in addressing the issue(s) with the employee, or for the clarification of any Company policies or procedures. b. During the meeting i. Meet with the employee in a non-confrontational manner. ii. Explain to the employee why you’ve called the meeting. iii. Review the Company’s policy with the employee and explain what steps (if any) have been taken already and what the next step is. iv. State the specific problem in terms of actual conduct and desired conduct. v. Clearly explain future expectations and consequences. vi. Give the employee a chance to respond, explain or defend his or her actions. vii. Acknowledge the employee’s response and include it in your notes of the discipline session. viii. Tell the employee that you expect his or her behavior to change. Give specific examples and suggestions. ix. Indicate your confidence in the employee’s ability and willingness to change the behavior. x. Have the employee repeat back to you or otherwise confirm that he or she understands the problem and is clear on what changes are expected. Try to get a commitment from the employee to resolve the problem. xi. Complete the corrective action form (if needed) and be sure that both you and the employee sign it. Give the employee a copy of the form. xii. Reassure the employee that you value his or her work and that you want to work with the employee to make sure he or she can continue to work for the Company. c. After the meeting i. Forward the corrective action form to the appropriate party. ii. Monitor the employee’s behavior and performance to be sure that the problem has been corrected. d. Dismissal & Disciplinary Action (see Attachment 08-1) i. If an employee engages in any of the following practices, he/she will be subject to disciplinary action. When violations occur, it becomes necessary to consider the facts and circumstances of the individual case, the employee’s length of service and employment record to determine what discipline is warranted.

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ii. The following is a partial list of the kind of improper conduct which, when engaged in, shall constitute grounds for disciplinary action, up to and including discharge. 1. Dishonesty, including any falsification or misrepresentation, proving incomplete, misleading or incorrect information in connection with the preparation of any Company records, including an application for employment. 2. Stealing or sabotage of equipment, tools and/or other property belonging to any customer, employee or the Company. 3. Removal from the Company premises any Company property or the property of others. 4. Willful damage, abuse, or destruction of Company property or the property of others. 5. Absence from Company for three consecutive days without authorization or acceptable excuse. 6. Possession, sale or use of intoxicating beverages or drugs on Company property or reporting to work under the influence of intoxicating beverages or drugs, or other violations of the drug and alcohol policy. 7. Unauthorized use, possession, conveyance or storage of any firearms, explosives or other dangerous weapons on Company premises. 8. Insubordination, including refusal to perform work required by a supervisor. 9. The use of profane, abusive, or threatening language toward fellow employees, customers, guests or supervisors. 10. Fighting, coercing, interfering with or threatening bodily injury to other employees, customers, guests or supervisors. 11. Gambling of any kind, including but not limited to bookmaking or numbers writing. 12. Immoral conduct or indecency. 13. Any act which might endanger the safety or life of others, including horseplay. 14. Willful, deliberate or repeated violation of Company safety rules. 15. Deliberate delaying or restricting services or work effort, or inciting others to delay or restrict time.

Safety Manual

16. Failure to report to work upon expiration of a vacation, holiday or leave of absence or upon being called back after a layoff. 17. Disclosure of confidential Company information to unauthorized persons. 18. Any other conduct which is of serious nature and which, in the sole opinion of the Company, makes the employee unfit for further service or warrants discharge.

Safety Manual

Serious Six Violation Corrective Action Process

The intent of each corrective action is to develop the employee’s behaviors to work error free. Errors that result in violations require corrective action to address behaviours. Wilful violations will result in more extensive corrective action. The corrective action process is to change unsafe behaviours and to identify latent organizational weaknesses that create violations. To assist in this process, I.B. Abel, Inc. (IBA) will utilize the Culpability Matrix to identify the type of violation or error and corrective action. All asterisks require management to evaluate organizational processes and supervisory methodologies to correct deficiencies that contribute to errors. 1. Intentional act – not an error 2. Possible reckless violation 3. Organization induced violation* 4. Possible negligent violation* 5. System induced violation* 6. Corrective training or other intervention* 7. Blameless error* Any employee who witnesses errors and does not speak out to identify and/or correct the error will receive a minimum of a verbal warning up to termination if the error could have resulted in a life-threatening situation. If anyone is aware or is observed in the act of observing inappropriate behaviors or errors, it is their responsibility to report the issue. Wilful violations –A violation involves a deliberate deviation from an expected behavior (management expectations). A violation is an intentional circumvention of known rules, practices or policies. Errors (mistakes) - is a human action that unintentionally departs from an expected behavior Observation and infraction expectations - Minor infractions are left up to the observer as to whether they want to report, coach or create a written corrective action plan. All Serious Six violations result in a mandatory, documented and written corrective action. Some examples of our serious six are below. 1. PPE Infractions a. Lack of insulating gloves and sleeves = termination i. Lack of work gloves when conducting normal work = coaching b. Lack of eye protection when conducting normal work = written corrective action

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c. Lack of face shield use as required = written corrective action and time off for wilful d. Lack of testing confined space = time off or termination e. Lack of blast blankets or barricades in enclosed or confined spaces = written corrective action if unaware or time off if wilful f. Lack of harness use in enclosed or confined spaces = written corrective action g. Lack of 100% FR when working with electrical potential = written corrective action 2. Fall Protection Rules a. Lack of 100% fall protection = termination b. Not being tethered in while working aloft = coaching, verbal, or written based on intent (forgot). If intentional, refer to lack of fall protection. c. Misuse of a ladder = up to termination 3. Insulate and Isolate and NFPA 70E rules a. Lack of rubber used in the zone while breaking minimum approach distance (MAD) = termination b. Lazy use of rubber such as not covering a neutral outside of MAD = written and time off c. NFPA 70E – lack of barricading as required; Lack of PPE as required; working energized when not testing or without hot work permit as required = up to termination 4. LOTO/switching and tagging a. Any Permit and Tag (PTAG) violation = Written, time off or termination b. Any LOTO violation that includes energizing a tagged or locked circuit = termination 5. Testing and Grounding a. Lack of Equi-Potential Zone (EPZ) use = termination b. Lack of understanding (method was attempted but incorrect) = written and training 6. Comprehensive Pre-Job Briefing and Hazard Analysis and Work Method a. Use an unapproved work method = time-off or termination b. Using material as a replacement of a tool c. Lack of PJB by responsible person = termination i. Any member on the crew who worked without a PJB = time-off or termination d. Poorly documented PJB (Pencil whipped) = written and/or time-off e. Lack of understanding = written corrective action or training f. Lack of documented PJB for a change in condition = Written, time-off or termination Violating industry and company best practice to mitigate a hazard = Termination

Safety Manual

Emergency Action Plan (EAP)

Purpose I.B. Abel, Inc. (IBA) is dedicated to the protection of its employees from emergencies such as severe weather, fire, personal injury and workplace violence. When emergencies do occur, our Emergency Action Plan (EAP) is initiated. This EAP is in place to ensure employee safety from emergencies during regular hours and after hours. It provides a written document detailing and organizing the actions and procedures to be followed by employees in case of a workplace emergency.

OSHA's Emergency Action Plan requirements, found at 29 CFR 1926.35, require IBA to have a written Emergency Action Plan (EAP). This EAP addresses emergencies that our company expects may reasonably occur at our office.

The EAP communicates to employees, policies, and procedures to follow in emergencies. This written plan is available to all employees on SharePoint, upon request, to employees, their designated representatives, and any OSHA officials who ask to see it.

Administrative Duties

The Plan Administrator has overall responsibility for the plan. This responsibility includes the following:

1. Developing and maintaining a written Emergency Action Plan for regular and after hours work conditions; 2. Notifying the proper rescue and law enforcement authorities, and the building owner/superintendent in the event of an emergency affecting the facility; 3. Taking security measures to protect employees; 4. Distributing procedures for reporting emergencies, the location of safe exits, evacuation routes to each employee, and to account for all employees after evacuation; 5. Conducting drills to acquaint employees with emergency procedures and to judge the effectiveness of the plan; 6. Training designated employees in emergency response such as the use of fire extinguishers and the application of first aid; 7. Deciding which emergency response to initiate (evacuate or not); 8. Ensuring that equipment is placed and locked in storage rooms or desks for protection; 9. Maintaining records and property as necessary; 10. Ensuring that our facility meets all local fire codes, building codes, and regulations, and;

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11. Identify the alarm system that shall be distinctive and recognizable as a signal to evacuate the work area.

The Executive Safety Committee is responsible for reviewing and updating the plan as necessary. Copies of this plan may be obtained at the York Office, Norristown Office, Plainfield Office, and the Frederick Office.

Any company official, safety committee member, or manager of the company has full authority to decide to implement the EAP if he/she believes an emergency might threaten human health. The following potential emergencies might reasonably be expected at this facility and thus call for the implementation of this EAP:

Emergency examples include fires and explosions; hazardous releases (chemical or biological); radiological accidents; natural disasters such as flood, tornado, earthquake, hurricane, or blizzard; power outage; civil disturbance; or criminal/terrorist threats such as bomb threats, arson, robbery, shootings, or other violence.

Safety Manual

Pre-Job Briefing

1. Introduction – Pre-Job Briefings - OSHA 1910.269, NFPA 70E, and your Safety Manual require that a “job briefing” be conducted with employees prior to the start of each job. A minimum of two pre-job briefings are to be performed each day AND whenever the task changes. 2. If the work performed during the workday/shift is repetitive and similar, at least one job briefing must be conducted before the start of the first job of each day/shift. If significant changes occur during the day that would affect employee safety, additional job briefings must be held. 3. If the work is complicated or particularly hazardous, or if the employee cannot be expected to recognize and avoid the hazards involved, a more extensive discussion should be conducted. 4. During the pre-job briefing meeting, it is important to get employees to recognize the potential hazards of the job or project. The following are some examples of topics to be addressed. The briefing must cover at least the following topics: a. Hazards associated with the job to be performed b. Defenses i. Work near energized electrical? Voltage levels involved? ii. Secondary (foreign) voltage sources or back feed possible? iii. Unusual work conditions (adverse weather conditions)? iv. Shock protection boundaries? v. Potential for arc flash (flash-hazard analysis)? vi. Flash protection boundaries? vii. Confined space? Excavation/trench? viii. Traffic control? ix. Hazardous materials (asbestos, lead, chemicals)? c. Work procedures involved i. De-energization? ii. Standby person needed? First aid/CPR certified? iii. Job plans, diagrams, blueprints, vendor information? iv. Notification of others? v. Who is in charge? vi. Who is the Qualified Watchman? vii. Voltage testing? viii. Grounding? ix. Line clearing/tree trimming? x. Barriers and barricades? Aerial work zone identified? xi. Boom truck or aerial lift? d. Human Performance i. Discuss Four Key Questions 1. Are we working with an error-likely situation? Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 51 I.B. Abel, Inc. – Confidential – All Rights Reserved

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2. What are our critical/irreversible steps for this job or task? 3. What bad things can happen? 4. How are we mitigating our hazards? ii. Discuss Critical/Irreversible Steps 1. Are we using Focus 3 – Self-check, Peer check, and Stop/Timeout for all critical/irreversible steps iii. Are all Error Precursors identified? iv. Encourage employees to speak up to their supervisor or to the qualified person if they feel they lack the knowledge, training, or experience to do the job, or if they have other concerns v. What is the worst thing that could happen? e. Special precautions that need to be taken i. Communication equipment ii. Insulated tools and equipment iii. Other f. Energy source controls i. Lock ii. Tag iii. Clearance procedures g. Personal protective equipment requirements i. Fall protection ii. Hard hat with chin strap iii. Gloves/sleeves (voltage-rated, leather, chemical, thermal, etc.) iv. Steel-toed/safety toed footwear v. Hearing protection vi. Respirator vii. Reflectorized vest (flagging traffic) viii. Safety glasses or goggles ix. Face shield and safety glasses x. Cut-resistant chaps (chainsaws) xi. Arc flash protective equipment 5. General – be sure to consider the SAFE method when discussing amongst the crew. a. S: See and say all of the hazards. b. A: Ask what did I miss? c. F: Follow all rules. d. E: Pay attention to energy source controls. 6. NO JOB IS TOO IMPORTANT THAT IT CANNOT BE DONE SAFELY!

Safety Manual

Risk Assessment

1. Introduction – Risk Assessments a. This Risk Assessment is to be used for assessing all types of risks and hazards associated with our business. Hazards must have appropriate risk assigned along with identifying proper defenses that bring the hazard or risk to an acceptable working level as seen in Risk Assessment Matrix. b. Risk assessments must at a minimum be done on a paper form, on Word documents or to the electronic SharePoint form. 2. Overview – a. When identifying risks, we must consider the following: i. Consequence of the failure. Worker injury or public safety ii. Effect on other equipment iii. Effect on system or facility iv. Hazards class - high, moderate, low. v. Probability of failure or harm. vi. Defenses or ways to mitigate provision/remarks. b. Risks identified during the Site-Specific Safety Plan will be discussed during the preconstruction process and assigned to the project manager or general foreman responsible for the job. All Site-Specific Safety Plans must be Peer Checked and approved by the Safety & Quality Department prior to work starting. Each risk “Medium” or greater will be sent to a Safety & Quality Coordinator who will make recommendations to the appropriate project manager or general foreman who will be responsible for coordinating appropriate actions for the risk. c. Risks identified at a crew level should be discussed amongst the crew before being carried out. All crews are required to perform a minimum of 1 risk assessment daily that captures the tasks being performed that day. Both employees and subcontractor’s crews are expected to be actively involved in the risk identification process. d. It is expected that managers will coordinate the submissions of risks assessments within their team area. e. If a risk is too high, as specified in Risk Assessment Matrix, the crew must perform a Stop/Timeout and contact the Safety & Quality Department for a Peer Check. f. The Safety & Quality Department then must approve the work method prior to the crew performing the work. Risk Assessment Matrix Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 53 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

HAZARD PROBABILITY

FREQUENT LIKELY OCCASIONAL SELDOM UNLIKELY A B C D E S EXTREMELY HIGH I EH EH EH H M E V HIGH II EH EH H M L E R MODERATE III EH M M L L I

T LOW Y IV M L L L L L EFFECT 1. EXTREMELY HIGH - Death or permanent total disability, system loss, major property damage. 2. HIGH - Permanent partial disability, temporary total disability, major system damage, major property damage. 3. MODERATE - Minor injury, lost workdays, compensable injury/illness, minor system damage, minor property damage. 4. LOW - First aid or minor supportive medical treatment, minor RISK LEVELS system impairment. Extremely High – Loss of PROBABILITY ability to accomplish the job/task A. FREQUENT - Occurs often - resources are continuously exposed. B. LIKELY - Occurs frequently - resources are exposed frequently High – Significantly and/or several times. degrades job/task capability C. OCCASIONAL - Occurs sometimes - resources are exposed sporadically. Moderate – Degrades job/task capability D. SELDOM - Remote occurrence - resources are possibly exposed. Low - E. UNLIKELY - Rare occurrence of exposure Low – little or no impact to job/task capability Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 54 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

Personal Protective Equipment 1. Scope a. Personal protective equipment (PPE) for body, eyes, face, head, and extremities, protective clothing and respiratory protection shall be provided, used and maintained in a sanitary and reliable condition whenever it is necessary to protect employees from the hazards presented by processes or environment, chemical hazards, radiological hazards, or mechanical hazards encountered on the various job sites. b. A hazard assessment will be completed for each job tasks. The hazard assessment must indicate a determination if hazards are present or are likely to be present, which necessitate the use of PPE. c. Hazard assessments must be certified, signed, and noted upon completion. d. I.B. Abel, Inc. (IBA) shall provide all necessary PPE at no cost to employees with the exception of safety toed boots. e. Where employees provide their own protective equipment, IBA shall assure the adequacy of the equipment including proper maintenance and sanitation of the equipment. f. Training shall be provided on the proper use, maintenance, inspection, and limitations of all required PPE. g. Retraining shall take place if the workplace changes, creating obsolete training; the type of PPE changes; or when the employee demonstrates lack of use, improper use, or insufficient skill or understanding. h. Each employee will be shown the proper way to use the PPE effectively including donning, doffing cleaning and maintenance procedures. i. All defective and/or damaged PPE shall not be used. Damaged PPE shall be disposed of; defective PPE shall be returned to the Warehouse. 2. Head Protection. a. Hard hats must meet the specifications contained in American National Standards Institute Z89.1-2009 Safety Requirements for Industrial Head Protection. b. Hard hats shall be kept in good repair and worn in accordance with the manufacturer’s recommendations. c. Hardhats shall be worn whenever on a jobsite unless requested by the customer. When such a request is made, we must document the reason on the pre-job briefing and ensure that there are no situations where: i. There is a possible danger of head injury from impact, or from falling or flying objects. ii. When there is the possibility of shock or electrical burns. d. Welding and Cutting Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 55 I.B. Abel, Inc. – Confidential – All Rights Reserved

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i. To protect eyes, face and body during welding and cutting, the operator shall wear an approved helmet and proper protective gloves and clothing. 3. Eye and Face Protection a. Employees are required to wear eye protection 100% while on the jobsite. i. Certain situations require the use of face shields in addition to eye protection, such as but not limited to: 1. Cutting or grinding of metal 2. Handling corrosive liquids 3. Chainsaw use ii. Goggles are required when using a jig saw or any cutting above shoulders iii. Eye and face protection shall meet the specifications contained in American National Standards Institute Z87.1-2010 Practice for Occupational and Educational Eye and Face Protection. iv. Employees whose vision requires the use of corrective lenses shall be supplied with goggles or glasses that can be worn over the corrective lenses. b. Welding and Cutting i. Proper eye protection shall be worn to guard against flying particles when the helmet is raised. ii. Welding screen shall be used whenever other persons could be exposed to the arc of the welding operation. iii. Eye protection ratings shall follow the below chart: Welding operation Shade number Shielded metal arc welding 1/16, 3/32, 1/8, 10 5/32 inch diameter electrode Gas shielded arc welding (non-ferrous) 1/16, 11 3/32, 1/8, 5/32 inch diameter electrode Gas shielded arc welding (non-ferrous) 1/16, 12 3/32, 1/8, 5/32 inch diameter electrode Shielded metal arc welding 3/16, 7/32, 1/4 inch 12 diameter electrode Shielded metal arc welding 5/16, 3/8 inch 14 diameter electrode Atomic hydrogen welding 10-14 Carbon-arc welding 14 Soldering 2 Torch brazing 3 or 4 Light cutting, up to 1” 3 or 4 Medium cutting, 1” to 6” 4 or 5 Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 56 I.B. Abel, Inc. – Confidential – All Rights Reserved

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Welding operation Shade number Heavy cutting, over 6” 5 or 6 Gas welding, light up to 1/8” 4 or 5 Gas welding, medium 1/8” to ½” 5 or 6 Gas welding, heavy over ½” 6 or 8

4. Foot Protection a. Employees are required to wear leather over-the-ankle work boots at all times. b. All boots shall have a safety toe. Safety-Toe Boots shall comply with the American National Standard for Men’s Safety-Toe Footwear, Z41.1-1991 or ASTM F2413-11. c. Some specific job tasks may be required to wear additional protective devices. d. Anti-slip footwear –is required PPE for all field based or assigned employees when temperatures provide for the potential of slippery conditions or when the effects of previous inclement weather allow for incidental slips, trips, and falls. A commonsense approach must be used when wearing such PPE and must consider the creation of hazards due to wearing anti-slip footwear: do not wear on metal surfaces, on equipment (trucks), while driving, or when slippery conditions do not exist. In addition, anti-slip footwear is also not required if the hazard has been mitigated through other means and documented on the Pre-Job Briefing. 5. Hearing Protection a. Employees are required to use hearing protection devices when they are exposed to excessive noise levels. b. When cutting or welding, wear approved ear protection. 6. Hand Protection a. Employees are required to wear hand protection whenever working with or around equipment, tools, or materials that present a burn, cut, puncture, electrical, or chemical hazard. i. In cases where a hazard can be eliminated through engineering or work practice controls the worker may elect to not wear gloves. b. Cutting and welding i. Approved hand protection must be worn. 7. Body protection a. Employees are required to wear appropriate body protection when, but not limited to, using a chain saw, cutting, welding. b. Employees are required to wear protective chaps when operating a chain saw on the ground. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 57 I.B. Abel, Inc. – Confidential – All Rights Reserved

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c. Employees are required to where a welding jacket when welding. d. Employees shall use a welding blanket when the situation calls for one. This includes flammable materials/chemicals, finished products, pedestrian area, or customer requirements. 8. Clothing a. Employees are required to wear full length work pants and shirts with at least a three-inch sleeve. Half or three-quarter length shirts are not permitted. b. Excessively loose or baggy clothing is not permitted. c. Excessively worn or ragged clothing or clothing with large holes is not permitted. 9. FR Clothing a. OSHA states: Paragraph (g)(5) of § 1926.960 requires that arc-rated protection cover the employee's entire body, with limited exceptions for the employee's hands, feet, face, and head. i. These limited exceptions are due to hard hat use, work glove or rubber glove use, work boot use, and safety glass and/or face shield use. ii. There is no place on a utility job that wearing short sleeved arc- rated shirts is adequate EXCLUDING when being used as an undergarment for layering protection. b. Arc-rated clothing shall be worn at all times by all crewmembers while working on any job that has arc flash potential. This includes working on all de-energized overhead lines.

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Electrical

1. Definitions a. Electrically Safe Work Condition. A state in which the circuit or conductor part to be worked on or near has been disconnected from energized parts, locked and tagged, tested to ensure the absence of voltage, and grounded if determined necessary. b. Qualified Person. One who has skills and knowledge related to the construction and operation of the electrical equipment and installations and has received safety training on the hazards involved. 2. General Requirements a. Employees who face a risk of electric shock but who are not qualified persons shall be trained and familiar with electrically related safety practices. All employees shall be trained in safety related work practices and clearance distances that pertain to their respective job assignments. b. All electrical conductors and equipment shall be free from recognized hazards that are likely to cause death or serious physical harm to employees. c. A daily visual inspection shall be made of the following to determine any external defects or indications of internal damage prior to use: Cord sets, attachment cap, plug & receptacle of cord sets & any other equipment connected by cord & plug (except for cord sets & receptacles which are fixed & not exposed to damage) such as deformed or missing plug, insulation damage. Damaged items shall be tagged 'DO NOT USE', removed from service until repaired and tested. d. Listed, labeled, or certified equipment shall be installed and used in accordance with instructions included in the listing, labeling, or certification. e. Guarding Live Parts. Live parts of electric equipment operating at 50V or more shall be guarded f. Insulate & Isolate - Three Insulate & Isolate Questions to Consider: i. Are there one or more objects of different potential within reaching distance of the object I am working on? ii. Are those objects adequately covered with approved rubber protective equipment? 1. If insulating would create more of a hazard (i.e. weighing down conductors) you must document your alternative work method on your pre-job briefing and communicate effectively. Please utilize Stop/Timeout Hotline when this condition exists. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 59 I.B. Abel, Inc. – Confidential – All Rights Reserved

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iii. Am I complying with the minimum approach distance regulations? 1. If you answered “Yes” to all of the above questions, then you are abiding by recommendations for minimum insulate & isolate precautions. 2. This should not be used as the sole indicator of how much rubber or other protective devices are applied to our potential hazards. This should be used simply as a guide with the intent to be ready for hazards that may arise. g. Ground Fault Protection. All 120V single phase, 15A and 20A receptacle outlets which are not a part of the permanent wiring of the building or structure and are in use by employees shall have approved ground fault circuit interrupters. 3. Temporary Wiring a. Branch circuits shall originate in a power outlet or panel board. i. Branch circuit conductors shall be located where they are not subject to physical damage. ii. Branch circuit conductors shall not be laid on the floor. iii. Branch circuit conductors shall be fastened at intervals not exceeding ten feet. b. Receptacles shall be the grounding type. c. Receptacles for uses other than temporary lighting shall not be installed on branch circuits that supply temporary lighting. d. Extension cords shall be the three-wire type and be designed for hard or extra-hard usage. e. Cords for temporary lighting shall be designed for hard or extra-hard usage. f. Acceptable flexible cord designations include S, ST, SO, STO, SJ, SJO, SJT, SJTO. g. Flexible cords and cables shall be protected from damage. Sharp corners and edges are to be avoided. Where cords pass through windows or doorways, they must be protected. h. Temporary lighting shall not be suspended by the cord unless specifically designed to be fastened that way. i. Light bulbs must be protected from accidental contact or breakage. 4. Working On or Near Exposed Electrical Conductors a. Safe Work Condition. Live parts to which an employee may be exposed shall be put into an electrically safe work condition before an employee works on or near them. b. Unsafe Work Condition. No employee shall be permitted to work on any exposed parts or circuits that have not been put into an electrically safe Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 60 I.B. Abel, Inc. – Confidential – All Rights Reserved

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work condition, unless they are a Qualified Person that is permitted to work on energized electrical equipment. c. Employees shall not be permitted inside any established Shock Protection Boundary, unless they are a Qualified Person that is permitted to work on energized electrical equipment. d. Any work shall comply with NFPA 70E, 2018 edition or most recent edition. i. Before starting each job, the employee in charge shall conduct a job briefing with the employees involved. The briefing shall cover: 1. Hazards associated with the job, 2. Work procedures involved, 3. Special precautions, 4. Information on the energized electrical work permit, if required. 5. Energy source controls, 6. PPE requirements. 7. Work area barricades and signage requirements. ii. An incident energy analysis shall be required for the following (tables cannot be used): 1. Tasks not listed in NFPA 70E 2. Power systems with greater than the estimated maximum available short-circuit current 3. Power systems with longer than the maximum fault clearing times 4. Tasks with less than the minimum working distance iii. Field work shall be audited to verify the requirements contained in the procedures of the Electrical Safety Plan are being followed (ESP). 1. When the auditing determines that the procedures of the ESP are not being followed, the appropriate revisions to the training program or revisions to the procedures shall be made. 2. The audit shall be documented. 3. The frequency of the field audit shall not exceed 1 year.

e. Employees may not enter spaces containing exposed energized parts unless illumination is provided that enables the employees to work safely. f. When working in confined or enclosed work spaces where electrical hazards may exist, protective shields, protective barriers or insulating materials as necessary shall be used. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 61 I.B. Abel, Inc. – Confidential – All Rights Reserved

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g. Conductive apparel shall not be worn unless the items are rendered non- conductive by covering, wrapping or other insulating means. h. All qualified employees must adhere to the approach distances in Table 3-2 when working in the vicinity of exposed energized conductors or equipment. i. Vehicular and mechanical equipment capable of having parts of its structure elevated near energized overhead lines shall be operated so that a clearance of 10 feet or greater is maintained. If the voltage is higher than 50KV, the clearance shall be increased 4 inches for every 10KV over that voltage. 5. Outside Line Construction – General a. Electrical equipment and lines shall always be considered as energized unless they are positively proven to be de- energized and properly grounded. b. IF IT ISN’T GROUNDED - IT ISN’T DEAD! c. Only qualified employees shall work on or near energized lines or equipment. Unqualified employees shall not approach or bring any conductive object within 10 feet of exposed energized facilities up to 50KV plus an additional 4 inches for every 10KV above 50KV. d. No employee shall approach any exposed ungrounded line wire or apparatus unless he is insulated from other conducting surfaces or uses adequate protective devices. e. Employees shall report immediately to their nearest foreman or supervisor any defective line, or tool or other condition which in their judgment may be dangerous either to persons or property or likely to interrupt or delay service. f. Anytime work is being performed on overhead lines while working aloft requires the use of a Qualified Watch (QW). i. Qualified Watch Responsibilities: QW are to always prioritize any Critical/Irreversible Step when observing workers aloft. The expectation is that the QW utilize Stop/Timeout and Effective Communication whenever an aerial worker is about to perform an act that will potentially create a hazard. The aerial worker is to maintain Situational Awareness and do a Self-Check prior to conducting any Critical/Irreversible Step. The QW shall also always have the ability to communicate issues with his voice, whistle, air horn, radio or other device to establish clear communication. Our additional focus should be as follows: ii. General Expectations 1. Whenever working aloft there should always be a QW.

Safety Manual

2. All crews must plan their work so that all prefabrication occurs prior to working aloft whenever possible. 3. All crews MUST have a hand line whenever working aloft. 4. The QW is to utilize Stop/Timeout when required to perform other duties. Workers should be instructed to move out of the primary zone and remain in the clear until the QW returns. 5. All Critical/Irreversible Steps are to be identified, mitigated and documented on the Pre-Job Briefing. QW are to be documented on the Pre-Job Briefing. Any deviation from the work plan requires a Stop/Timeout to be performed by the QW to revisit the pre-job brief. iii. Primary Priorities - all Critical/Irreversible Steps should be communicated prior to conducting with the QW 1. All rigging activities 2. Boom movements 3. Energizing a line, cutting a conductor, making a tap, making a phase, or any action altering current. iv. Secondary Priorities 1. Boom position 2. Minimum Approach Distance 3. Insulate & Isolate 4. Communicate whenever QW cannot watch so workers can leave the energized zone g. Anytime rigging work is being performed on transmission overhead lines, while working aloft, requires the use of rigging safeties. Rigging safeties such as “picky ropes”, rope slings, “collar” ropes, shackle/clevis, or otherwise termed, are to be used to hold up all rigging to prevent the tools from falling. h. All equipment including reel handling equipment, including pulling and tensioning devices shall be in safe operating condition and shall be leveled and aligned. i. Load ratings of stringing lines, pulling lines, conductor grips, load-bearing hardware and accessories, rigging, and hoists may not be exceeded. j. Portable ladders shall have nonconductive siderails if they are used where the employee or the ladder could contact exposed energized parts. k. Electrical equipment and lines shall always be considered as “live” unless they are positively known to be dead and grounded. Before starting to work, preliminary inspection or test shall be made to determine what conditions exist. Extreme care shall be exercised when handling common neutral conductors as high voltage may be encountered. Any

Safety Manual

line or circuit to be worked on as de-energized, must be Identified, Isolated and Tested before grounding can take place. l. Secondary windings of current or series transformers shall be short circuited before any instrument or other device connected in the circuit is removed or disconnected. m. No work shall be performed in inclement weather on high voltage equipment or lines when conditions are such as to materially increase the hazards of the operations being performed, excepting emergency work necessary to restore service or demanded by the public interest. n. Insulate & Isolate - Three Insulate & Isolate Questions to Consider: i. Are there one or more objects of different potential within reaching distance of the object I am working on? ii. Are those objects adequately covered with approved rubber protective equipment? 1. If insulating would create more of a hazard (i.e. weighing down conductors) you must document your alternative work method on your pre-job briefing and communicate effectively. Please utilize Stop/Timeout Hotline when this condition exists. iii. Am I complying with the minimum approach distance regulations? iv. If you answered “Yes” to all the above questions, then you are abiding by recommendations for minimum insulate & isolate precautions. v. This should not be used as the sole indicator of how much rubber or other protective devices are applied to our potential hazards. This should be used simply as a guide with the intent to be ready for hazards that may arise. 6. Flexible Protective Equipment (Rubber, Synthetics, Etc.) a. Employees shall not touch or work on any exposed energized lines or apparatus except when wearing Protective equipment approved for the voltage to be contacted. b. When work is to be done on or near energized lines or equipment, all energized and grounded conductors, guy wires or equipment within reach of any part of the body shall be covered with protective equipment, except that part of the conductor on which the employee is working. c. When working on energized lines or apparatus, including the installation of protective devices, work should be done from below, if possible. d. In applying flexible protective equipment, an employee shall always protect the nearest and lowest wires first, protecting himself as he Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 64 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

progresses. In removing rubber protective equipment, the reverse order shall be maintained. e. Flexible blankets shall not be used on the ground without protecting them from physical damage and moisture by means of a tarpaulin, canvas, or protective mat. f. Protective equipment shall be put on before entering the work area within which energized lines or apparatus may be reached, and the protective equipment shall not be removed until the employee is completely out of reach of this area. g. To avoid corona and ozone damage, rubber protective equipment shall not be allowed to remain in place on energized lines or apparatus overnight or for more than one twelve-hour period, unless approved by the supervisor in charge. h. Line hose, hoods, blankets, line guards, etc., shall be visually inspected before each job. i. Line hose, hard guard and hoods shall be visually inspected and electrically retested upon indication that insulating value is suspect and rubber blankets electrically retested every six (6) months or as required when physical inspection reveals defects. Where visual inspection indicates that there may be reason to suspect the electrical integrity of flexible protective equipment, an electrical test shall be performed before reissuing the equipment for service. j. Flexible protective devices shall be stored in special compartments on trucks and elsewhere where they will not be subjected to damage from tools or other equipment. k. Bare communications conductors shall be treated as energized lines and shall be protected accordingly. l. Electrical cords or electric power tools shall not be used near or above lines or equipment exceeding 250 volts. 7. Use and Care of Rubber Gloves and Sleeves a. Only qualified employees or those under the continuous supervision of an experienced journeyman shall work on lines or equipment which is energized. b. When rubber glove work is authorized to be performed, use the following chart. c. Employees shall wear rubber gloves, with leather protectors ground to ground when working on lines or equipment energized at voltages below 500 volts. This only applies to when there is NOT a greater voltage present on the structure or vicinity (service pole, overhead junction box, etc.). If primary voltages are present refer to the below. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 65 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

d. Employees shall wear rubber gloves and sleeves ground to ground when working on lines and equipment energized at voltages over 500 volts unless approved live line tools are used. e. Rubber gloves with leather protectors, overshoes and sleeves shall also be worn by employees on the ground when: i. Working on or within reaching distance of any electrical equipment and/or conductor which are not effectively grounded, and which may become energized (I.E. URD, Sub-Stations, and Traffic Signals). ii. While a pole or other conductive structure is being set or removed from proximity of energized primary lines. They shall be put on before pole is raised and worn until pole is set and secured. iii. Required by supervision. iv. Opening and closing manually operated oil circuit breakers, air- break switches, fuses, or fuse doors on cutouts. v. Making tests to determine if lines are de-energized and applying and removing grounds. f. When working with rubber protective equipment on energized circuits or apparatus the following minimum conditions shall be met, in addition to all other rules governing the use of protective equipment. i. Employees shall not make physical contact with energized conductors or grounds, with other than his rubber gloves. ii. Where the voltage exceeds 5000 volts between a single phase and ground employees shall be isolated from all grounds (wooden poles shall be considered as grounds in this case) by using approved supplementary insulation such as aerial baskets, a lineman’s platform, or other approved insulated devices. All equipment used for lineman protection shall be tested. g. Rubber gloves shall never be worn inside out or without leather protectors. They shall be exchanged at any time they become damaged or the employee to whom they are assigned becomes suspicious of them. Leather protectors or over gloves shall not be worn except when in use over rubber gloves. h. Rubber gloves and sleeves shall be inspected for corona cracks or other damage and the gloves shall be given an air test each day while in use, at the beginning of the work period and at any other time when their condition is in doubt. They shall be given a visual inspection before each use. i. Rubber gloves and sleeves when not in use shall be kept in canvas bags or other approved containers and stored where they will not become Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 66 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

damaged from sharp objects or exposed to direct sunlight. They shall never be folded while stored nor shall other objects be placed upon them. j. Rubber gloves shall be stored in the glove bag with the cuffs down to permit drainage, better ventilation and reduce the possibility of damage. k. Suitable size gloves and sleeves shall be provided by the employer. l. Inner liners may be worn if desired. m. Rubber gloves shall be laboratory tested after thirty (30) days of being issued to the employee. n. Rubber sleeves shall be laboratory tested after sixty (60) days of being issued to the employee. o. An efficient method of numbering and stamping shall be used showing the date of the last laboratory test on sleeves, blankets and gloves. p. Gloves or sleeves that have been electrically tested and sealed in plastic bags but not issued for service shall not be placed into service unless they have been tested within the previous twelve (12) months. Date of issuance shall be stamped on the glove when distributed.

8. Protective Equipment a. Line hose, hard guard and hoods shall be visually inspected and electrically retested upon indication that insulating value is suspect and rubber blankets electrically retested every 12 months or as required when physical inspection reveals defects. b. Rubber blankets shall be visually inspected and electrically retested every six (6) months or as required when physical inspection reveals defects. c. Line hose may be folded back over itself for inspection purposes. d. Rubber blankets should be rolled or stored flat never folded. e. Rubber goods should not be thrown from poles or structures but should be raised and lowered by hand line with a suitable canvas bag or container. f. Defective rubber goods shall not be used. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 67 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

g. Oil shall not be allowed to contact the rubber; if it does, it shall be wiped off at once. 9. Climbing and Working on Poles a. Before ascending, individual climber shall inspect and test all poles to assure all poles are in safe condition for the work to be performed and that they can sustain the additional or unbalanced stresses to which they will be subjected. b. Where poles or structures may be unsafe for climbing, they shall not be climbed until made safe by guying, bracing or by other adequate means. c. Wires shall not be attached to or removed from a pole or structure until it is certain the pole or structure will withstand the altered strain. d. Poles shall be thoroughly tested before they are climbed. If a pole is not strong enough to sustain a lineman’s weight by reason of its condition or its placement (such as in soft ground), it shall be guyed or otherwise secured throughout the time any work is being performed on it. If the pole to be climbed is being replaced and the new pole is set adjacent to it, the old pole may be lashed to the new one in lieu of guying. e. When poles are encountered which are unsafe to climb (ice, badly chewed, wide cracks, shell rot, etc.), the use of an aerial bucket shall be considered. f. All climbing above 4 foot requires 100% fall protection capabilities excluding climbing onto and off heavy equipment. g. Employees shall not wear their climbers while driving or riding in vehicles or when doing work on the ground, on ladders (except hook ladders), in aerial lifts or on platforms in which the wearing of climbers creates a hazard. h. Gaffs on climbers shall be kept within safe length limits i. (1-1/4 inches min.), properly shaped, and sharp. j. Employees shall not work on an elevated pole or structure without first securing themselves with a safety strap. k. Only approved belts and straps shall be used. i. Metal hooks, chains, etc., for holding tools or tape shall not be attached to body belts. Leather or other non-conducting material shall be used for this purpose. l. The safety strap shall not be put around a pole above the uppermost pole attachment position, except where pole top or attachment is above eye level. It shall not be used on pole steps, cross arm braces, insulators, insulator pins, conductors, rotten or otherwise weak cross arms or on attachments that are being moved. When it is necessary to safety off to a cross arm, the safety strap shall never be placed beyond the outside Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 68 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

cross arm attachment. It shall be so placed that it will not be cut by line equipment or twisted or fouled by material that may give way under strain. m. Employees shall not trust their weight to guy wires, pins, braces, conductors, or other such equipment that might prove unstable. n. When two or more employees are to work on the same pole at the same time, one shall reach the working position before the next leaves the ground. They shall descend the pole one at a time. o. When climbers are stored in the truck or tool room, they shall be placed where the sharp points will not damage other equipment or cause personal injury. p. Gaff guards shall be used on climbers when not on the pole. q. The sliding of guy wires to descend poles or structures is strictly forbidden. 10. Working on Energized Lines a. All journeymen working on energized conductors and/ or electrical equipment over 500 volts shall be assisted by a journeyman, or a qualified apprentice, on the same pole, structure or location. (Two separate poles or structures may be considered one for the purpose of this rule if both linemen can step to the other pole or structure without descending to the ground to do so.) b. In no case, when working together in pairs, shall linemen work simultaneously on energized wires or equipment of different phases or polarities. c. Before starting work the lineman shall get himself in such a position that the presence of the second man does not increase the hazard. d. Qualified apprentices may, under the supervision of a Journeyman, work on energized conductors and/or equipment. Qualified apprentices shall be determined by the Joint Apprenticeship and Training Committee. e. Energized conductors and/or equipment shall be handled in accord with the Safety rules, regulations and safe working procedures of the Utility on whose property the work is performed, provided a copy of such procedures, is made available. f. Crew Compliment for Live Line Work. A crew of two (2) qualified employees can handle single phase primary conductors and routine 3 phase primary conductors. The more complex projects, such as sleeving primary, heavy corner and junction poles, etc., should be handled by a minimum of three (3) or more qualified employees, depending upon field conditions determined by the immediate supervisor. g. Phasing sticks or appropriate meters must be used prior to energizing any de-energized line or when paralleling phases. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 69 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

11. Working On De-Energized Lines and Equipment a. General. All conductors and equipment shall be treated as energized until tested to be de-energized and grounded. b. New construction. New lines or equipment may be considered de- energized and worked as such where: i. The lines or equipment are grounded, or ii. The hazards of induced voltages are not present and adequate clearances or other means are implemented to prevent contact with energized lines or equipment and the new lines or equipment. c. Communication conductors. Bare wire communication conductors on power poles or structures shall be treated as energized lines unless protected by insulating materials. d. Workmen working on de-energized lines shall work under the tagging orders on whose property the work is performed. e. Testing equipment of adequate capacity shall be used to determine whether a line and/or equipment is de-energized. f. Grounding equipment shall be used when working on all de-energized circuits and/or equipment. g. Rubber gloves and sleeves must be worn when sticks are used to test, switch, phase-out, or ground circuits and/or equipment. h. Men working in de-energized areas must use barricades, signs, tags, and/or other safety means to designate energized lines and/or equipment. i. All tools shall be kept in good working condition, properly stored, and must be restricted to the use for which they are intended. 12. Dispatching and Clearances a. All oral communications about dispatching and clearances shall be recorded by the person receiving them and read back to the person giving them. b. Under no circumstances shall clearances be granted or released on a predetermined time basis. c. When two or more crews are working on the same line or apparatus and are not under the supervision of the same general foreman or other supervisor, each crew foreman shall request and release his own clearance independently in accordance with these rules. d. A Hold Card shall be attached to each switch that is providing clearance on a cleared line or apparatus. e. The handles of switches providing clearances for working on lines or apparatus shall be locked or blocked open or closed in addition to being Hold Carded.

Safety Manual

f. Under no circumstances shall Hold Cards be removed, or the line or apparatus be put in service until so ordered by the dispatcher. g. Before ordering Hold Cards removed, and line or equipment returned to service, the load dispatcher shall require that the same person who received the clearance shall report that the line or equipment may be re- energized. i. EXCEPTION: If the person who received the clearance must leave the work before it is completed, he shall so inform the dispatcher, giving the name of the man who will take his place. In such cases, the dispatcher shall communicate with both men, releasing the one who is leaving and accepting the other as authorized to report for him. Clear entries of all such authorized changes shall be made on the dispatcher’s records and Hold Cards or Tags. h. When it is necessary to obtain a working clearance on any line or apparatus not under the jurisdiction of a dispatcher, the request shall be made directly to the person having jurisdiction. i. After de-energizing the line or apparatus and attaching Hold Cards to each switch providing clearance on the line or apparatus, the employee shall report back to the person making the request that the line or apparatus is out of service and that work may be begun after adequate grounds have been installed. j. A line or apparatus shall not be put back in service, nor the Hold Cards removed until the person to whom clearance was given releases their clearance. i. EXCEPTION: If the person who received the clearance must leave the work before it is completed, the Employee shall so inform the person having jurisdiction, giving the name of the person who is to take his place. In such cases, the person having jurisdiction shall communicate with both men, releasing the man who is leaving and accepting the other as authorized to report for him. k. When the work is completed, the grounds removed, and all employees are clear, the employee who received the clearance, or his properly authorized substitute, shall report to the person having jurisdiction that the line or apparatus is ready for service. 13. Series Street Lighting Circuits a. Before a series street lighting circuit is opened and work is started, one of the following procedures shall be followed:

Safety Manual

i. Circuit shall be visibly disconnected from the source of supply by opening disconnecting switches or other absolute cutouts and Hold Cards shall be attached to such disconnects or cutouts. Dependence shall not be placed on time switches or other automatic devices. ii. Circuit shall be properly jumpered to avoid an open-circuit condition. b. All series street lighting circuits shall be considered as energized and worked on in as such. 14. Working on Transformers a. The primary leads of a distribution transformer shall be considered energized at full voltage until both the primary and the secondary leads have been disconnected, or it has been determined that the secondary circuit to which it is attached is not energized from other transformers. b. The cases of all transformers connected to a source of supply shall be considered as being energized at the full primary voltage unless they are adequately grounded. c. Employees shall not stand on or otherwise contact transformer cases while working on or near energized circuits. 15. Hoisting Cables-Conductive Material a. Wire rope or other conductive material shall not be used to raise transformers, poles, or any other equipment or materials near energized lines, except: i. When the wire rope is rigged a sufficient distance below all energized wires to prevent the possibility of electrical contact between the energized wires and the wire rope or conductive material being raised. ii. When the wire rope and any conductive material being raised are adequately protected. b. When energized lines and equipment are adequately protected: i. Use of wire rope as a hoist line shall be discontinued when it becomes worn, deteriorated or damaged to a degree that is unsafe. ii. Metallic slings (chain or cable) shall not be used near energized equipment. iii. Whenever possible, chain slings shall not be used for hoisting purposes. iv. Positive control of wire rope shall be maintained at all times.

Safety Manual

v. Synthetic hoisting and pulling lines and ropes shall not be considered as non-conductive, unless properly maintained to preserve their insulating qualities. 16. Working on Capacitors a. Line capacitors shall be considered at full voltage until they have been disconnected from the line, and the terminals short-circuited and discharged to ground by an approved method. b. The terminals shall not be short-circuited until the capacitors have been de-energized for at least five minutes. i. Employee shall wear rubber gloves and use a hot stick while shorting and grounding terminals. c. Employees shall not come in contact with an ungrounded capacitor case until the capacitor has been disconnected from the circuit and the terminals shorted. d. The exposed terminals of line capacitors in storage shall be shorted. 17. Stringing or Removing Conductors a. Prior to stringing operations, the following shall be completed: i. The Wire Pulling Worksheet shall be completed, and information shall be transferred the Wire Pulling Plan. The plan shall be approved by Safety & Quality. ii. A briefing shall be held setting forth the plan of operation and specifying the type of equipment to be used, grounding devices and procedures to be followed, crossover methods to be employed, and the clearance authorization required. iii. Prior to stringing parallel to an existing energized transmission line, a competent determination shall be made to ascertain whether dangerous induced voltage buildups will occur, particularly during switching and ground fault conditions. When there is a possibility that dangerous induced voltage may exist, the following is required: 1. When stringing adjacent to energized lines, the tension stringing method or other methods that preclude unintentional contact between the lines being pulled and any employee shall be used. 2. All energized adjacent lines, especially those on the same structure, shall be requested to be placed on single reclosing prior to commencing work. 3. All pulling and tensioning equipment in the work area shall be bonded together to create an effective equipotential zone. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 73 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

4. A ground shall be installed between the tensioning reel setup and the first structure in order to ground each bare conductor and overhead ground conductor during stringing operations. b. Where there is a possibility of the conductor accidentally contacting an energized circuit, or receiving a dangerous induced voltage buildup, to further protect the employee from the hazards of the conductor, the conductor being installed or removed shall be grounded or provisions made to insulate or isolate the employee. c. For all shield wire pulling operations (steel or “weld-labeled” conductors), it is not permitted to pull in wire with wire. Existing steel or “weld-labeled” conductors may only be used to pull in lead line rope. d. The use of material such as preforms is not permitted for wire pulling. Preforms should only be used per the manufacturer’s instructions and the shape of the preform should never be altered. e. Only mesh grips are permitted for wire pulling unless otherwise approved by Safety & Quality. f. If the existing line is de-energized, proper clearance authorization shall be secured and the line grounded on both sides of the crossover or, the line being strung or removed shall be considered and worked as energized. g. During stringing operations, each bare conductor and overhead ground conductor shall be grounded at the first tower adjacent to both the tensioning and pulling setup. i. The grounds shall be left in place until conductor installation is completed. ii. Such grounds shall be removed as the last phase of aerial cleanup. iii. Except for moving type grounds, the grounds shall be placed and removed with a hot stick. h. When crossing over energized conductors in excess of 500 volts, rope nets or guard structures shall be installed unless provision is made to isolate or insulate the employee or the energized conductor. i. Where practical the automatic reclosing feature of the circuit interrupting device shall be made inoperative. ii. All conductors shall be grounded at energized crossings. i. Conductors being strung in or removed shall be kept under positive control by the use of adequate tension reels, guard structures, tie lines, or other means to prevent accidental contact with energized circuits. j. Conductors and overhead ground conductors shall be grounded at all dead-end, catch-off points and structures being worked. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 74 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

k. A ground shall be located at each side and within 10 feet of working areas where conductors or overhead ground conductors are being spliced at ground level. The two ends to be spliced shall be bonded to each other. l. All conductors and overhead ground conductors shall be bonded to the tower at any isolated tower where it may be necessary to complete work on the transmission line. m. Working aloft on de-energized lines shall require equi-potential zone (EPZ) grounding on all de-energized lines. n. Grounds may be removed as soon as the work is completed, provided that the line is not left open circuited at the isolated tower at which work is being completed. o. When performing work from the structures, clipping crews and all others working on conductors or overhead ground conductors shall be protected by individual (EPZ) grounds installed at every work location. 18. Grounding a. Personal protective grounds shall be applied as to create a zone of equalized potential (EPZ) for those working on de-energized lines or equipment. b. All transmission overhead line verification of potential requires the use of a voltage tester that indicates a voltage. Proximity or “mushroom” type testers shall not be used. Only digital or analog testers should be used. Phasing sticks are to be considered an approved method as well. i. Proximity or “mushroom” type testers are permitted on distribution overhead line verification of potential. c. All EPZ planning shall be addressed in the daily risk assessment that is completed by the jobsite foreman. The EPZ plan must specifically state how the crew is to create an EPZ. The foreman must state the following: i. State the structure number or indicator for the structure. ii. State whether there is a need to bond across lines such as in a dead-end scenario. All open points require a bond to maintain continuity and EPZ. iii. State the plan to address hazards on the ground for step and touch potential. iv. State if there is a need to barricade any hazards. v. State the need for personal grounds from basket to conductor whenever working in a non-insulated aerial device. vi. State how to create an EPZ in emergency situations when conductors are on the ground. vii. Always state where the cluster mount will be situated on the pole for wood pole work. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 75 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

viii. State the process for removal if it differs from installing. ix. State the available fault current for the line being worked as well as the load capacity of the working grounds. This information can be obtained from the “SO”, “OCC”, “DOC”, or energy control representative. x. State the specific method of how to achieve EPZ at the structure that is being worked. Some examples may include (or variations): 1. Static to B phase to A phase to C phase. 2. Driven ground rod to B phase to A phase to C phase. 3. Structure to phase and equipment to structure. 4. Neutral to B phase to A phase to C phase. d. New lines or equipment may be considered de-energized and worked as such where: i. The lines or equipment are EPZ grounded, or ii. The hazard of induced voltages is not present due to adequate clearances or other means are implemented to prevent contact with energized lines or equipment and the new lines or equipment. e. Bare wire communication conductors on power poles or structures shall be treated as energized lines unless protected by insulating materials. f. De-energized conductors and equipment that are to be grounded shall first be tested for the presence of voltage. g. Adequate capacity cables and clamps shall be provided for grounding. They shall be inspected for defects prior to being used. h. EPZ grounds shall be at the structure being worked. A grounding bracket shall be attached to the pole at a point below the work area to achieve an EPZ. i. Attaching grounds. i. When attaching grounds, the ground end shall be attached first, and the other end shall be attached and removed by means of insulated tools and rubber gloves and sleeves for distribution. Transmission grounds shall be installed with tested and inspected live-line tools and rubber gloves and sleeves. ii. When removing grounds, the grounding device shall first be removed from the line or equipment using insulated tools and rubber gloves and sleeves. j. Where the making of a ground is impracticable on voltages below 19.9 Kv, or the conditions resulting there from would be more hazardous than working on the lines or equipment without grounding, the grounds may be omitted, and the line or equipment worked as energized.

Safety Manual

k. Grounds may be temporarily removed only when necessary for test purposes and extreme caution shall be exercised during the test procedures. l. Grounding to tower shall be made with a tower clamp capable of conducting the anticipated fault current. m. A ground lead, to be attached to either a tower ground or driven ground, shall be capable of conducting the anticipated fault current and shall have a minimum conductance of 2/0 AWG copper. n. Grounding equipment shall be of sufficient carrying capacity to actuate protective devices such as oil circuit breakers, relays, etc., without destroying the grounding equipment. 19. Pole Hauling and Temporary Storage a. The trailing end of a load of poles shall be marked by a red flag during the day and a red light at night. As an additional precaution, warning flags or lights may be placed in the center of long loads. An employee shall be used for flagging when necessary. b. If it becomes necessary to store poles at the location where they are to be set, they shall be so placed that they will not interfere with traffic. c. If poles left on or near streets, highways or walkways overnight create a hazard; they shall be safeguarded by red lights or well-lighted warning signs. d. Poles shall be placed or blocked so that they will not roll. e. Employees shall not remain on a pole pile while poles are being hoisted. f. Poles loaded on a truck or trailer shall be securely fastened every ten feet. g. When a load of poles is within working distance of the ground, load binders shall be installed so that they can and will be operated by employees while standing on the ground. h. Employees shall not ride pole dollies or trailers. i. The wheels of the transporting vehicle shall be chocked or securely braked prior to loading. 20. Setting and Removing Poles a. If any holes are left unfilled at the end of the work period, they shall be protected with substantial coverings. b. All persons not engaged in pole-setting operations shall keep out of the work area. c. No one shall be on a gin pole when it is being used to raise another pole. d. While setting or removing poles between or near conductors energized above 500 volts:

Safety Manual

i. If safe clearance cannot be maintained, the conductors shall be de-energized, covered with protective devices, spread apart, or a pole guard shall be used, to minimize accidental contact. ii. Workmen handling the butt of the pole shall wear rubber gloves and sleeves whether or not cant hooks, peaveys, or slings are used. iii. Until a pole is positively secured from moving against an energized conductor, no one shall step on or off the truck or pole trailer, nor shall an employee standing on the ground touch any part of the truck or pole trailer without using rubber gloves. iv. Ground wires shall not be attached to the pole higher than 10 feet from the ground. e. When pikes are used to hold poles in place while holes are being backfilled, they shall be firmly secured until the backfill is sufficient to hold. When a pole is being “canted” or “hooked”, the pikes shall be held. f. Employees shall not stand or pass under a suspended load or adjacent to or over or under a loaded winch line. g. Employees engaged in handling or working on poles shall wear suitable gloves and shall wear a shirt or jacket with the sleeves rolled down. h. Hoisting equipment operators shall accept signals only from the employee specifically designated. The operator shall obey a stop signal given by anyone. i. The operation of setting a pole in an energized line shall require two (2) qualified employees in the group including one (1) journeyman and a qualified apprentice or two (2) journeymen. The number of employees utilized will depend on the work to be done. Additional qualified personnel will be assigned whenever required to perform the work safely. 21. Derrick Trucks, Cranes, Etc. a. All derrick trucks, cranes, etc. shall be grounded when operating near electrical (energized or de-energized) 69 kV or above facilities. This is due to the inability to effectively insulate. b. Mechanical equipment shall not be operated closer to any energized line or equipment than the Minimum Approach Distances (MAD) set forth unless: i. An insulated barrier is installed between the energized part and the mechanical equipment and the mechanical equipment is insulated. ii. The mechanical equipment is grounded or considered energized. 22. Fuses

Safety Manual

a. Rubber gloves and sleeves shall be worn while opening, closing, removing or replacing hot clamps, fuses or fuse doors on cutouts when using an approved switch stick or hot line tool. Approved eye protection shall also be used during these procedures. 23. Rope (Synthetic Fiber-Manila) a. A rope shall not be overloaded or dragged over rough or sharp objects. b. Short bends over sharp-edged surfaces shall be avoided. c. Kinks shall be removed before any strain is put on a rope. d. When not in use, rope shall be dried and stored properly and kept free from mechanical damage and excessive heat and dryness. i. Rope shall be examined regularly for cuts, worn spots, burns and rot. The rope shall be untwisted at various places and inspected for poor fiber and dry rot. ii. The outward appearance of rope shall not be accepted as proof of quality or strength. iii. The safe loads, as specified by the manufacturer, shall not be exceeded. iv. Hand lines shall be a minimum of ½ inch diameter and have a strength equivalent to ½ inch manila. v. Eyes and splices shall be made in accordance with the instructions given by the rope manufacturer. 24. Underground Lines and Equipment Opening and Guarding Holes a. Whenever the cover is to be removed from a manhole or a vault, or when any other obstruction to traffic exists, the following precautions shall be taken. b. All obstructions to traffic shall be guarded by adequate signs, barricades, lights, flares or flags. Traffic shall be warned in advance through the use of signs, high level standards, flashing lights, traffic cones or flaggers, as may be required by the situation. c. Where permissible and practicable, the truck shall be placed to guard the work area against oncoming traffic. d. A blow torch or other open flame shall never be used to melt ice around a manhole or vault cover. e. Manhole, vault and service-box covers shall always be removed and replaced by means of approved hooks and hoists. 25. Entering Underground Structures a. Testing of the confined or enclosed space should be listed as a requirement before opening underground structures. b. All employees required to enter confined or enclosed spaces shall be instructed as to the nature of the hazards involved, the necessary Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 79 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

precautions to be taken, and in the use of protective and emergency equipment required. The employer shall comply with any specific regulations that apply to work in dangerous or potentially dangerous areas. c. Before an employee enters a street opening, such as a manhole or an unvented vault, it shall be promptly protected with a barrier, temporary cover, or other suitable guard. d. If, in an emergency, it becomes necessary for an employee to enter a manhole or vault where gas is present, he shall use an approved gas mask and a rescue harness to which there is attached a lifeline attended by another employee stationed at the manhole or vault opening. e. A ladder shall always be used in entering or leaving a manhole or vault. Climbing into or out of manholes or vaults by stepping on cables or hangers is forbidden. f. While work is being performed in manholes, an employee shall be available in the immediate vicinity to render emergency assistance as may be required. This shall not prevent the employee in the immediate vicinity from occasionally entering a manhole to provide assistance, other than emergency. This requirement does not preclude an authorized employee, working alone, from entering for brief periods of time, a manhole where energized cables or equipment are in service, for the purpose of inspection, housekeeping, taking readings, or similar work if such work can be performed safely. g. Before any work is done on a cable, it shall be identified by an approved method. If there is any doubt as to the identification, work shall not be started until it is checked and identified by the proper authority. h. No workman shall use or be required to use any toxic cleaning fluids in manholes, vaults or excavations. 26. Work on Energized Cables a. All underground cables and apparatus carrying current at voltage above 500 volts shall be de-energized before work is done on the conductor or before the cables are cut into or spliced. b. Before any work is done on an energized cable, other cables and all grounded equipment with which contact can be made while working on the energized cable shall be covered with rubber blankets or approved insulating shields. (Cables with non-metallic sheaths and those with an insulating jacket over the metallic sheath need not be covered). c. Because of the characteristics of a low voltage network system, when work is performed on cables or apparatus carrying less than 500 volts, employees shall take extra precautions in the use of necessary rubber Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 80 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

protective equipment, in observing adequate clearances and in using proper tools in order to prevent short circuits. d. Employees shall wear rubber gloves with leather protectors, sleeves and stand on rubber mats or use insulated tools while cutting into and removing sheathing or sleeves and while testing an energized cable. e. After removing a section of lead sheath or sleeve on an energized cable, the lead on each side of the open shall be covered with insulating tape for a distance of at least 9 inches. f. When cutting an energized multiple conductor cable, a piece of fiber or wood shall be placed between the conductor being cut and the other conductors, and the cut shall be made directly over the shield. g. Immediately after each conductor of an energized multiple conductor cable is cut in two, the ends shall be insulated before another conductor is cut. During the course of the work, only one un-insulated conductor shall be exposed at any one time. h. Phasing sticks or appropriate meters must be used prior to energizing any de-energized cables or when paralleling phases. 27. Work On De-Energized Cables a. When cables and apparatus are taken out of service to be worked on, the procedure outlined in Rule 31-6 shall be followed. b. When grounding de-energized underground cable, a zone of equalized potential shall be created for the employees who are working on it. c. When a high voltage cable is to be cut, the cable shall be speared at the work location by a remotely operated grounded spear, or a short section of the shielding if any, completely around the cable shall be removed and tests made with two statiscopes or other approved testing devices, to determine whether or not the cable is de-energized. If no indication of a live cable is obtained, the employee may proceed with the work. d. When opening a joint or splice in a high voltage cable, it shall be speared as in (C) or the sleeve of the joint shall be cut completely around near the wipes and then cut lengthwise and removed from the joint. No effort shall be made to remove the compound. The employee shall then test over each conductor with two statiscopes or other approved testing devices. If no indication of a live cable is obtained, the Employee shall remove the compound. If shielding tape is then encountered, it shall be removed, and another test made over each conductor with two statiscopes or other approved testing devices. If no indication of a live cable is then obtained, the Employee shall cut through the joint until the saw touches one of the conductors. Before sawing further, a statiscope test shall be made on the blade of the saw. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 81 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

e. When cutting or opening joints on low voltage cables, the same procedure as outlined above for high tension cables shall be followed, except in testing. To determine whether the conductor is energized, the insulation shall be cut away to the conductor and tests made with an approved tester. On multiple conductor cables, only one conductor shall be cut into at a time, and tests shall be made on at least two conductors before proceeding with work. 28. Pulling Cables a. Employees shall not handle pull-wires or pulling-lines within reaching distance of blocks, sheaves, winch drums or take-up reels. b. Pull-wires, steel pulling-lines or metal rodding shall not be pushed through ducts where energized equipment is present unless another employee is stationed at the other end of the run. c. Employees shall not remain in a manhole or vault during pulling operations involving heavy pulling strains unless they can take a position clear of the pulling-line. d. Communications between manholes shall be maintained. e. When pulling cable into vaults, manholes, or duct, care shall be exercised to protect employees and the public from possible injury. Vehicular and pedestrian traffic at the work location shall be studied long enough to enable the equipment to be set up in the safest manner possible and with the least inconvenience to the public. f. An employee or suitable warning sign or barricade, shall be stationed alongside a cable, snake wire, or pulling rope laid out on the sidewalk or street pavement; cables laid across sidewalks temporarily during pulling operations shall be properly guarded, to reduce the hazard to pedestrians. 29. Moving Energized Cables a. Cables operating at voltages above 15,000 volts shall not be moved under any circumstances. b. All cables up to 15,000 volts may be moved at the discretion of the foreman. They shall not, however, be moved where such movement requires changing bends. c. All cables energized above 500 volts shall be handled with rubber gloves and sleeves. 30. Heating Materials a. Metals and insulating compounds shall be heated in such manner as to prevent hazard to the employees working in manholes or vaults and to vehicular or pedestrian traffic.

Safety Manual

b. Gloves shall be worn while heating or working with hot insulating compound. c. Furnaces and tanks containing liquefied petroleum gas shall not be placed in a manhole or vault. d. Cold solder scraps or ladle shall never be placed in a hot solder pot until the chill and any moisture have been removed from the scraps or ladle. e. Heating pots for lead, oil or compound shall be safely positioned so that the contents cannot enter the vault or manhole in the event of spillage. f. Lighted furnaces or torches should not be left unattended. g. Torches or furnaces must be kept at a safe distance from flammable materials. 31. Underground Residential Distribution a. Underground Residential Distribution (URD) systems have a number of apparent advantages over overhead systems; however, they also have some disadvantages such as confined working spaces, closer clearances between energized parts and greater exposure to all types of grounds. In most cases, if protective devices are not used, the employee will be in direct contact with the ground or grounded equipment. This contact completes half of an electrical circuit. If these contacts are not avoided, or protection against contact is not used, serious injury can result. 32. URD-General a. Before a URD transformer enclosure is opened, all unauthorized persons including the public shall be required to leave the work area and remain clear of all hazards involved in the work. b. When underground equipment is being located, previously buried short sections of scrap cable could provide false indications of the actual position of permanent conductors. Therefore, all scrap cable, regardless of length, is to be removed from the job site. 33. Opening and Closing Circuits-URD a. Company switching procedures, including Hold Carding practices, shall be followed when sectionalizing URD systems. b. When a URD circuit has opened, the route of the circuit shall be patrolled for obvious hazards before the circuit is reclosed. c. An approved switching tool and rubber gloves with sleeves shall both be used when switches (including secondary breakers) in an energized circuit are opened or closed. d. Any URD primary circuit shall be de-energized by opening one or more devices. De-energizing shall be done with load break elbow connectors, load break fuse cutout at the riser pole, load break tool or other approved device. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 83 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

e. Eye or face protection shall be worn when primary switching operation are performed. 34. Grounding-URD Note: A capacitance charge can remain in a URD cable after it has been disconnected from the circuit and a static-type arc can occur when grounds are applied to these cables. a. All URD cables and equipment, including services, that have been energized or could become energized from any source, shall be considered as energized until the equipment is positively proven to be de- energized and has been grounded. b. Before doing work on de-energized primary circuits or equipment: i. A visible open break shall be provided. ii. A voltage test shall be made. iii. The equipment shall be grounded. c. When work is to be done on equipment or cables or an underground system, precautions to prevent back feed shall be taken. This shall include grounding of the secondary conductors where applicable. d. De-energized cables shall be grounded at a point as close to the work as possible before work is started. e. All underground cables and apparatus carrying current at voltages above 500 volts shall be de-energized and grounded before cables are cut into or spliced. 35. Rubber Glove and Sleeve Use-URD a. Rubber gloves and sleeves shall be worn before any URD compartment or enclosure (including a service pedestal) is opened. b. Rubber gloves and sleeves shall be worn when removing animals, vines, weeds, grass or vegetation of any kind that has grown into an energized URD installation whether the equipment is opened or closed. c. Rubber gloves and sleeves shall be worn when energized primary cables are moved, handled or protected. d. Rubber gloves and sleeves shall be worn when work is performed on energized secondaries and services. e. Rubber gloves and sleeves shall be worn when working on or contacting a neutral. 36. Work On Energized Equipment-URD a. When work is performed on cables or apparatus carrying less than 500 volts, employees shall take extra precautions in the use of necessary rubber protective equipment, in observing adequate clearances, and in using proper tools in order to prevent short circuits.

Safety Manual

b. When energized pad-mounted transformers are unlocked and opened, they shall be directly attended by an Employee. They shall be kept closed and locked at all other times. c. A primary or secondary system neutral on any energized circuit shall not be opened under any circumstances. d. Elbow connectors provide a great deal of flexibility in switching and system sectionalizing. However, only those connectors designed and approved for load break use shall be used to connect or disconnect an energized circuit. e. Only tools with insulated handles shall be used for making energized secondary connections or when work is performed within energized service pedestals, pad-mount compartments or submersible transformer enclosures. f. Only one energized secondary or service conductor shall be worked on at any one time, and protective devices shall be used to insulate or isolate it from all others. g. Before any attempt is made to replace a damaged or blown cable limiter, the customer’s service will be checked for faults using either an ohmmeter or a voltmeter. h. Appropriate clothing with full-length sleeves, rolled down, shall be worn when work is performed with rubber gloves and sleeves. 37. Excavations-URD a. Mechanical excavating equipment shall be used only in areas where there is no known danger of contacting or damaging buried facilities. b. Whenever excavating is done near buried facilities, it shall be done only by hand digging. c. Before excavating in any area where any buried facilities are suspected, such facilities shall be located as accurately as possible and other utilities shall be notified of the proposed work. d. If electric cables are damaged, the following steps shall be taken: i. If the damaged cable belongs to a power company other than the one performing the work, this company shall be notified at once. ii. The area shall be barricaded, and the public kept out until hazardous conditions can be eliminated. e. If gas lines are damaged, the following steps shall be taken as soon as possible: i. The hole shall be left open to allow the gas to dissipate into the atmosphere. All possible sources of igniting the gas shall be removed or eliminated.

Safety Manual

ii. Residents of the area shall be warned when necessary and the public kept out of the area. f. The following departments shall be notified immediately: i. Local fire ii. Gas company iii. Local police g. If communication cables are damaged, the communication company shall be notified at once. h. When trenches are left open, warning devices, barriers, barricades or guardrails shall be placed to adequately protect the public and employees. i. At the end of each day’s work, as much of the trench as practical shall be closed. No more trench shall be open at one time than is necessary. j. Suitable gloves shall be worn when using any equipment or tools to excavate, expose or handle secondary cables. They shall also be used when digging with approved hand tools to expose primary cables.

Safety Manual

Protective Boundaries and clearances refer to Table 3-2 for restricted approach boundary.

Safety Manual

Table 3-2 MINIMUM CLEARANCE DISTANCES FOR LIVE-LINE WORK (ALTERNATING CURRENT) Distance in feet and inches for maximum voltage Voltage range (phase to phase) Phase to Phase to ground phase

Kilovolt Ph-Gd Ph-Ph 0.050 to 0.300 ...... avoid contact 0.301 to 0.750...... 1 ft. 1 in 1ft. 1 in. 0.751 to 5.0 ...... 2 ft. 1 in. 2 ft. 1 in. 5.1 to 15 ...... 2 ft. 2 in. 2 ft. 3 in. 15.1 to 36 ...... 2 ft. 7 in. 2 ft. 11 in. 36.1 to 46 ...... 2 ft. 9 in. 3 ft. 3 in. 46.1 to 72.5 ...... 3 ft. 4 in. 4 ft. 0 in. Above 72.5 KV consult OSHA Tables for MAD distance using appropriate Voltage and TOV. 38. Live-Line Bare-Hand Work a. Only employees who have been instructed and trained in live-line bare- hand work shall use the technique on energized circuits. Employees shall receive refresher training as required. b. Live-Line bare-hand work shall not be performed on voltages under 69 kV unless minimum clearances specified in Table 3-2 can be maintained. c. Before using the live-line bare-hand technique on energized high voltage conductors or parts, a check shall be made of: i. The voltage rating of the circuit on which the work is to be performed; ii. The clearances to ground of the lines and other energized parts on which work is to be performed; and iii. The voltage limitations of the aerial lift equipment intended to be used.

Safety Manual

d. Only equipment designed, tested, and intended for live-line bare-hand work shall be used. e. The automatic reclosing feature of circuit interrupting devices shall be made inoperative before working on any energized line or equipment. f. Work shall not be performed during the progress of an electrical storm in the immediate vicinity. g. A conductive bucket liner or other suitable conductive device shall be provided for bonding the insulated aerial device to the energized line or equipment. i. The employee shall be connected to the bucket liner by use of conductive shoes, leg clips, or other suitable means. ii. Adequate electrostatic shielding shall be used or conductive clothing suitable for the voltage shall be worn. h. Only tools and equipment intended for live-line bare-hand work shall be used, and such tools and equipment shall be kept clean and dry. i. Before the boom is elevated, the outriggers on the aerial truck shall be extended and adjusted to stabilize the truck and the body of the truck shall be bonded to an effective ground or barricaded and considered as energized equipment. j. Before moving the aerial lift into the work position, all controls (ground level and bucket) shall be checked and tested to determine that they are in proper working condition. k. Arm current tests shall be made before starting work each day, each time during the day when higher voltage is going to be worked and when changed conditions indicate a need for additional tests. This test shall consist of placing the bucket in contact with an energized source equal to the voltage to be worked upon for a minimum of three (3) minutes. The leakage current shall not exceed 1 micro-ampere per kilovolt of nominal line-to-line voltage. Work operations shall be suspended immediately upon any indication of a malfunction in the equipment. l. All aerial lifts to be used for live-line bare-hand work shall have dual controls, lower and upper. i. The upper controls shall be within easy reach of the employee in the basket. If a dual bucket type lift is used, access to the controls shall be within easy reach from either basket. ii. The lower set of controls shall be located near the base of the boom and must permit override operation of the equipment at any time. m. Before the employee contacts the energized part to be worked, the conductive bucket liner shall be bonded to the energized conductor by Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 90 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

means of a positive connection which shall remain attached to the energized conductor until the work on the energized circuit is completed. n. The minimum clearance distances for live-line bare-hand work shall be as specified in Table 3-2. These minimum clearance distances shall be maintained from all grounded objects and from lines and equipment at a different potential than that to which the insulated aerial device is bonded unless such grounded objects or other lines and equipment are covered by insulated guards. These distances shall be maintained when approaching, leaving, and when bonded to the energized circuit. o. The use of hand lines between buckets, booms, and the ground is prohibited. p. No conductive materials over 36 inches long shall be placed in the bucket, except for appropriate length jumpers, armor rods, and tools. q. Non-conductive-type hand lines may be used from line to ground when not supported from the bucket. r. A minimum clearance table (as shown in Table 3-2) shall be printed on a plate of durable non-conductive material and mounted in the buckets or its vicinity so as to be visible to the operator of the boom. s. It is recommended that insulated measuring sticks be used to verify clearance distances. 39. Working On Energized Lines with Live-Line Tools a. All live-line tools to be removed from service and inspected every two (2) years. If, during that inspection, any defects are found that could compromise the dielectric properties of the tool, then it shall be removed from service, repaired and refinished, and tested before returning the tool to service. b. Lines of #6 copper, #6 ACSR, and #8A copperweld or smaller shall not be worked on with live-line tools except in specific instances where continuity of service is vital and then only upon special authorization. c. Planned work with live-line tools shall not be started during unfavorable weather. d. Before work with live-line maintenance tools is begun, the dispatcher or person having jurisdiction shall be notified. If during live-line tools work, an interruption of service occurs, the dispatcher or other person having jurisdiction shall be notified immediately. e. Only tools approved by the Company shall be used in live-line maintenance work. f. A careful check shall be made to see that the condition of the structure and lines at the point of the work is such that the job may be performed safely. In addition, the adjacent spans and structures shall be carefully Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 91 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

checked for defects in conductors, tie wires, insulators, and other equipment. g. Under no circumstances shall a lineman depend on another workman to hold a live conductor clear of him. h. Positive control shall be maintained during the movement of any conductor. i. While live-line work is in progress, no other work of any nature shall be performed on the same pole or structure. j. All live-line tools, when not in use, shall be kept in canvas bags or weatherproof boxes provided for that purpose; these containers shall be stored in dry and, if possible, a warm place. k. Live-line tools shall never be laid directly on the ground or against sharp objects such as barb wire fences. Special tool holders or tarpaulins shall be used for this purpose. l. All live-line tools shall be visually inspected before use each day. Tools to be used shall be wiped clean, and if any hazardous defects are indicated, these tools shall be removed from service. m. When practical, the automatic reclosing feature of circuit interrupting devices shall be made inoperative before work begins. n. Careful attention shall be given to avoid mechanical overloading of live- line tools. o. When installing or removing jumpers, only one connection shall be made at a time. Jumper ends not connected shall be secured in such a manner as to prevent unintended contacts. p. Plan each job carefully to provide the maximum clear working space. Guard against contact with conductors other than the one being worked on. q. Approved protection devices shall be placed in position on any and all conductors energized above 5000 volts when such conductors are within reach of any part of the Employee’s body when live line tools are being used. Such conductor guards shall be installed by means of appropriate live line tools. r. Only clean and dry synthetic rope shall be used on energized conductors above 5KV. Link sticks shall be used between the rope and energized conductor on all voltages. Care shall be exercised to prevent the ends of the tie wires, armor rods, or other conductive material from contacting the structure or attached hardware during removal from or installation on energized conductors

Safety Manual

Regulatory Inspections

This section contains general information about the inspection process from different regulatory agencies governing worker safety. All employees should be aware of the inspection procedures of these agencies. Work performed in Pennsylvania is governed by the Federal Occupational Safety and Health Administration (OSHA). Work performed in Maryland is governed by the Maryland Occupational Safety and Health (MOSH). Work performed on mine and quarry properties is governed by the Mine Safety and Health Administration (MSHA). The inspection procedures of OSHA and MOSH are essentially the same. References to OSHA in this section apply to both agencies. MSHA inspections are slightly different than OSHA. Differences between the agencies are pointed out where appropriate. 1. What Triggers an Inspection? a. OSHA can initiate a job site inspection for various reasons. Inspections are conducted according to the following priority schedule. i. Imminent Danger. Responding to situations of imminent danger is OSHA’s highest priority. Imminent danger is a situation that is likely to cause death or serious physical harm. If a compliance officer witnesses any situation they consider to be an imminent danger to workers, they have the right to initiate an inspection. ii. Investigations of Fatalities and Catastrophes. Second priority is given to investigations of fatalities and catastrophic accidents. iii. Response to Employee Complaints. OSHA responds to every complaint they receive. Serious allegations may result in onsite inspections. iv. Referrals from Other Agencies. Other government agencies may refer OSHA to work sites to investigate worker safety and health conditions. v. Programmed Inspections. In construction, work sites listed on the Dodge Reports are chosen randomly for programmed inspections. vi. Follow-up Inspections. OSHA has the right to conduct follow up inspections to verify abatement of previously cited hazards. b. MSHA schedules inspections of mine properties in a similar manner to OSHA but conducts far more inspections. In addition to accident and complaint investigations, all above ground mines, such as quarries, are inspected at least twice a year. Underground mines are inspected at least 4 times a year. Long term projects at mine sites are almost guaranteed to be inspected by an MSHA compliance officer.

Safety Manual

2. The Inspection Procedure. An inspection can be broken down into three main sections: an opening conference, the walk around portion, and a closing conference. a. Opening Conference i. Compliance officers will show up on a job site unannounced. Before the inspection begins, the compliance officer will hold an opening conference. Call the Safety Department as soon as it is learned that OSHA is on site. The compliance officer may delay the inspection for a short period until safety representatives arrive. At the start of the opening conference the compliance officer should introduce him/herself and show identification. If one is not offered, ask for a business card. The inspector should state the scope of the inspection and why they are there. If they do not, ask the reason for the inspection. Is the inspection random, a referral, a complaint, etc. Also ask if the inspection will be a focused inspection or comprehensive. If it is not a focused inspection, ask why it will not be. ii. If the inspection is the result of an employee complaint, the inspection should be limited to the scope of the complaint. For example, if a complaint was received about a scaffold without guardrails, that should be all the compliance officer inspects. Be aware however, a compliance officer can cite IBA for any serious violations they witness at any time during any type of inspection. Serious violations may also cause the compliance officer to expand the scope of the inspection to a comprehensive inspection of the entire project. iii. A representative of each contractor should attend the opening conference. The compliance officer may ask questions about the project and what activities are taking place. He/she may also ask to see some paperwork such as SDSs or the 300 Log. If the compliance officer asks to see any paperwork that is not available on site, the Safety Department can fax or e-mail it to their office. b. Walk Around Inspection i. A representative of IBA should accompany the inspector during the walk around portion of the inspection. Subcontractor representatives also have the right to attend the walk around inspection. During the inspection, the compliance officer may do any of the following: ii. Inspect the work area for unsafe acts or conditions.

Safety Manual

iii. During the OSHA inspection, the compliance officer will focus on the four leading hazards that cause 90 percent of deaths and injuries in construction. The Focus Four Hazards are: 1. Falls (e.g., floors, platforms, roofs) 2. Struck by (e.g., falling objects, vehicles) 3. Caught in/between (e.g., cave-ins, unguarded machinery, equipment) 4. Electrical (e.g., overhead power lines, power tools and cords, outlets, temporary wiring.) iv. Ask questions of workers. Questions should be answered truthfully but do not offer any unnecessary information. v. Interview workers privately. vi. Inspect equipment such as extension cords, backup alarms, scaffolds, etc. vii. Take pictures or video of work activities. viii. The person accompanying the inspector should take detailed notes of the walk around inspection. If possible, take pictures of anything the compliance officer takes pictures of. Any hazards that are pointed out during the inspection should be corrected immediately. Do not argue with compliance officers, even if you don’t agree with them. It is also not a good idea to stop work altogether while the compliance officer is on site. This will only aggravate the compliance officer and prolong the inspection. IBA employees may not be able to accompany MSHA inspectors during their inspections. Generally, they are escorted by a representative of the mine owner and our work sites are only a small part of the overall inspection. c. Closing Conference i. A closing conference will be held at the end of the walk around inspection. The compliance officer may choose to do this separately with each contractor or together with all representatives at once. At the closing conference the inspector will notify each contractor of their rights and responsibilities after an OSHA inspection and any citations he/she is going to propose. In an MSHA closing conference, citations will be issued on the spot. 3. OSHA citations and MSHA assessments a. OSHA citations and MSHA assessments are sent in the mail in the days or weeks following an inspection. At that point, the Safety Department can appeal the citations and have them reduced or in some cases withdrawn. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 95 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

4. Top 25 Most Frequently Cited OSHA Standards 2002 a. Fall Protection (1926.501) – 6,721 b. Hazard Communication (1910.1200) – 5,192 c. Scaffolding (1926.451) – 4,295 d. Respiratory Protection (1910.134) – 3,305 e. Lockout/Tagout (1910.147) – 3,002 f. Powered Industrial Trucks (1910.178) – 2,760 g. Ladders (1926.1053) – 2,489 h. Electrical – Wiring Methods (1910.305) – 2,404 i. Machine Guarding (1910.212) – 2,295 Electrical – General Requirements (1910.303) – 1,973

Safety Manual

Concrete and Masonry

1. General requirements. a. All protruding reinforcing steel, onto or into which employees could fall, shall be guarded to eliminate the hazard of impalement. i. “Mushroom” style rebar caps may only be used on horizontally protruding rebar. b. Measures shall be taken to ensure unrolled wire mesh does not recoil. c. No employees shall be permitted to ride concrete buckets. d. No employees shall be permitted to work beneath concrete buckets. i. Elevated concrete buckets shall be routed so that no employees, or the fewest number possible, are exposed to the overhead hazard. e. Trowel machines must be equipped with a safety switch that automatically cuts off if the operator’s hand leaves the handles. f. All tools and equipment shall maintain appropriate clearance from energized electrical conductors. g. Masonry saws shall have the blade guarded. 2. Concrete a. Employees shall take precautions to prevent prolonged contact with concrete. Over boots are required when employees will be standing in poured concrete. b. Consult SDS and ensure that proper first aid equipment is available. c. Formwork shall be erected, supported, braced, and maintained so that it will be capable of supporting any loads imposed on it. d. Form scaffolds shall comply with the requirements of the Scaffolding Chapter. e. No employees are permitted below pre-cast panels while they are being erected. 3. Masonry a. A limited access zone shall be established where masonry walls are being constructed. i. The limited access zone shall restrict access to all employees except those engaged in the construction of the wall. ii. The limited access zone shall be equal to the height of the wall plus four feet and shall run the entire length of the wall. b. Masonry walls over eight feet in height shall be braced to prevent collapse unless it is adequately supported so that it will not overturn or collapse (see attached methods of masonry wall bracing) c. Masonry Wall Bracing: Masonry walls under construction collapse far too frequently. It is not acceptable to treat masonry bracing casually during construction. Recent changes in design, codes, and public attitude place

Safety Manual

a great demand on the need for a well-planned and secure temporary support system for masonry walls under construction. 4. General Guidelines for Wall Bracing a. Ensure that masonry walls are not built higher than 10 times their thickness unless they are adequately braced. b. Ensure that masonry walls constructed with joint reinforcing wire and/or cell rebar reinforcing are not built higher than 10 times their thickness unless they are adequately braced. c. Ensure that braces are inclined 30 to 40 to the horizontal and adequately fastened to remain in position. d. Understand that mortar bonds will crack before a masonry wall tips. Look for telltale cracks in the mortar joints immediately after a windstorm. If cracks are present, seek engineering advice. e. Check local laws or regulations pertaining to wall bracing, as they may be more specific. f. Understand that soils also play an important part in the effectiveness of a masonry wall bracing system. Loose, frozen, or wet soil can dangerously weaken a wall bracing system. g. When standard wall bracing techniques cannot be applied, retain an engineer familiar with wall bracing systems to design special bracing.

Safety Manual

Confined Space

1. Scope of Confined Space Program a. I.B. Abel, Inc. (IBA) has established a confined spaces program to protect employees who are exposed to the hazards associated with working in confined spaces. This section applies to work in industrial and construction settings. IBA may follow the Permit Required Confined Spaces Program of a Host Employer as long as it meets or exceeds the requirements in this section. 2. Definitions a. Confined Space means a space that i. Is large enough that an employee can physically enter and perform assigned work, and ii. Has limited means for entry and exit iii. Is not designed for continuous employee occupancy. Examples include but are not limited to, tanks, vaults, tunnels, manholes, vessels, and storage bins. b. Permit Required Confined Space (also referred to as permit spaces) means a confined space that has one or more of the following characteristics: i. Contains or has the potential to contain a hazardous atmosphere. ii. Contains a material that has the potential to engulf an entrant. iii. Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross section; or iv. Contains any other recognized serious safety or health hazard. c. Acceptable Entry Conditions means the conditions that must exist in a confined or permit required confined space to allow entry and to ensure that employees involved with the entry can safely enter and work within the space (see General Requirements for specific atmospheric conditions). d. Prohibited Condition means any condition in a permit space that is not allowed by the permit during the period when entry is authorized. e. Attendant means an individual stationed outside one or more permit spaces who monitors the authorized entrants and who performs all the attendant's duties as assigned in this program. f. Authorized Entrant means an employee who is authorized by the Job Superintendent, Foreman or Safety Director to enter a permit space.

Safety Manual

g. Entry Permit means the written or printed document that is provided to allow and control entry into a permit space and that contains the information required by this program. h. Enclosed Spaces refer to manholes, vaults and other confined spaces that contain operating transmission and distribution conductors or equipment. Personnel entering such spaces must be qualified employees as defined by 1910.269 performing work covered by the 1910.269 standard, and the only hazard is electrical, then the requirements of 1910.269(e) and (t) apply. If the personnel are not 1910.269-qualified, or if the work is not covered by the 1910.269 standard, or if other potential hazards continue to exist even after complying with the requirements in 1910.269(e) and (t), then the requirements in Permit Required Confined Spaces, must be followed. 3. Host Employer Requirements. This section lists the requirements of the Host Employer if IBA employees are to enter a confined space or permit required confined space at a client’s facility. a. Inform IBA employees of permit spaces that exist in work areas. b. Inform IBA employees of the hazards identified and the host employer’s experience with the space that makes the space in question a permit space (ex. oxygen deficiency, engulfment, toxic materials, etc.) c. Inform IBA employees of any precautions or procedures that the host employer has implemented for the protection of employees in or near permit spaces where IBA will be working. d. Coordinate entry procedures when the Host Employer will be working in or near permit spaces at the same time as IBA so that employees of the Host Employer and employees of IBA do not endanger one another inadvertently. 4. IBA Requirements: It is the responsibility of IBA, through the Job Superintendent, Foreman or Safety &Quality Department to: a. Determine if confined spaces, permit spaces or enclosed spaces need to be entered on the project. b. If permit spaces need to be entered at the facility of a Host Employer: i. Reference the IBA Enclosed/Confined Space Procedure. ii. Obtain any information available regarding permit space hazards and entry operations from the Host Employer. iii. Coordinate entry procedures with the Host Employer when IBA Inc. will be working in or near permit spaces at the same time as the Host Employer so that employees of the Host Employer and IBA Inc. do not endanger one another inadvertently. 5. General Requirements for Entering Confined Spaces Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 100 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

a. Required training must be conducted prior to initial assignment, prior to a change in assigned duties, and when new hazard has been created and/or if special deviations have occurred for which an employee has not had previous training. b. Training of IBA employees will be documented. c. IBA will review the confined space program annually and revise the program as necessary. d. Employees of IBA Inc. must be aware of the hazards associated with any permit space before entry is permitted. e. Necessary procedures and practices for safe entry into the permit space must be completed prior to entry. These include but are not limited to: i. Specifying acceptable entry conditions. ii. Isolating the permit space through lockout/tagout, line breaking, blanking, or other procedures. iii. Purging, inerting, flushing, or ventilating the permit space as necessary to eliminate or control atmospheric hazards. iv. Providing pedestrian, vehicle, or other barriers as necessary to protect entrants from external hazards. v. Verifying that conditions in the permit space are acceptable for entry throughout the duration of an authorized entry. f. Air Monitoring. Permit space conditions must be evaluated as follows when entry operations are conducted: i. Test the conditions in the confined space to determine if acceptable entry conditions exist before entry is authorized to begin. ii. Test or monitor the space continually while entry is in process to ensure acceptable entry conditions are being maintained during entry operations. iii. When testing for atmospheric hazards, use a tool watched and calibrated multi-gas meter from the Safety Department. These monitor for oxygen, lower explosive limit, carbon monoxide and hydrogen sulfide simultaneously. iv. Additional air monitoring equipment may be needed based on the potential atmospheric hazards. Contact the Safety Department for air monitoring requests.

Safety Manual

Acceptable Entry Conditions: Oxygen (O2) 19.5% < O2 < 23.5% Flammable Gases or Vapors (LEL) <10% LEL Carbon Monoxide <35 ppm Hydrogen Sulfide (sewer gas) <10 ppm Other Specific Toxins < OSHA Permissible Exposure Limit (PEL) Airborne Combustible Dusts obscured vision at a distance of 5’ or less

g. Provide at least one attendant outside the space into which entry is authorized for the duration of entry operations. NOTE: Attendants may be assigned to monitor more than one space provided the duties described later in this program (“Duties of Attendants”) can effectively be performed for each space that is monitored. a. If multiple spaces are to be monitored by a single attendant, means, and procedures must be developed to enable the attendant to respond to an emergency in one or more of the confined spaces without distraction from the attendant's responsibilities to any other confined spaces. h. Designate the persons who have active roles (for example, authorized entrants, attendants, entry supervisors or persons who test or monitor the atmosphere in a permit space) in entry operations, ensure that each such employee is aware of his/her duties, and has had the appropriate training. i. Ensure that procedures for rescue have been developed prior to entry, including procedures for rescuing entrants from permit spaces, providing necessary emergency services to rescued employees, and for preventing unauthorized employees from attempting a rescue. j. Permits must be completed fully and authorized by the entry supervisor prior to entry. k. Completed permits must be posted at the entrance to the space prior to entry. l. Expired and cancelled permits must be returned to the Safety Dept. and, if required, to the Host Employer. m. An IBA Confined Space Permit must be filled out for all confined space operations. Permits issued from a Host Employer may be substituted only if it is reviewed by Safety and Quality, contains the same information required on an IBA issued permit and copies of Host Employer permits are returned to the safety and quality department the same as IBA Confined Space Entry Permits. 6. General Requirement for Entering Enclosed Spaces

Safety Manual

a. Required training must be conducted prior to initial assignment, prior to a change in assigned duties, and when new hazard has been created and/or if special deviations have occurred for which an employee has not had previous training. b. Training of IBA employees will be documented. c. IBA will review the enclosed space program annually and revise the program as necessary. d. Employees of IBA Inc. must be aware of the hazards associated with any enclosed space before entry is permitted. e. Entry to an enclosed space must be conducted in accordance with the IBA Enclosed space procedure. f. Necessary procedures and practices for safe entry into the enclosed space must be completed prior to entry. These include but are not limited to: i. Specifying acceptable entry conditions. ii. Purging, inerting, flushing, or ventilating the enclosed space as necessary to eliminate or control atmospheric hazards. iii. Providing pedestrian, vehicle, or other barriers as necessary to protect entrants from external hazards. iv. Verifying that conditions in the enclosed space are acceptable for entry throughout the duration of an authorized entry. 7. Duties of Authorized Entrants a. Each Entrant shall: i. Know the hazards that may be faced during entry, including information on the mode, signs, or symptoms and consequences of the exposure. ii. Properly use all equipment issued for entry operations. iii. Communicate as necessary with the attendant to enable the attendant to monitor entrant status and to enable the attendant to alert entrants of the need to evacuate the space as required by the conditions listed under “Duties of Attendants.” iv. Alert the attendant whenever: 1. The entrant recognizes any warning sign or symptom of exposure to a dangerous situation. 2. The entrant detects a prohibited condition. b. Exit from the space as quickly as possible whenever: i. An order is given to evacuate by the attendant or entry supervisor. ii. The entrant recognizes any warning sign or symptom of exposure to a dangerous situation. iii. The entrant detects a prohibited condition. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 103 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

iv. An evacuation alarm is activated. 8. Duties of Attendants a. Each Attendant shall: b. Know the hazards that may be faced during entry, including information on the mode, signs, or symptoms and consequences of the exposure. c. Be aware of possible behavioral effects of hazard exposure in authorized entrants. d. Continuously maintain an accurate count of authorized entrants in the permit space and their identities. e. Remain outside the permit space until relieved by another attendant. f. Be trained in Confined space rescue. NOTE: Attendants properly trained in confined space entry are not authorized to enter permit spaces to attempt rescues unless they have been relieved by another attendant. g. Communicate with authorized entrants as necessary to monitor entrant status and to alert entrants of the need to evacuate the space. h. Monitor activities inside and outside the space to determine if it is safe for entrants to remain in the space and order the authorized entrants to evacuate the space immediately under any of the following conditions: i. If the attendant detects a prohibited condition. ii. If the attendant detects the behavioral effects of hazard exposure in an authorized attendant. iii. If the attendant detects a situation outside the space that could endanger the authorized entrants. iv. If the attendant cannot effectively and safely perform all the duties listed in this section. i. Summon rescue and other emergency services as soon as the attendant determines that the authorized entrants may need assistance to escape from confined space hazard. j. Take the following actions when unauthorized persons approach a confined space while entry is under way: i. Warn the unauthorized persons that they must stay away from the space entry point. ii. Advise the unauthorized person that they must exit the area immediately if they have entered the work area without appropriate PPE. iii. Inform the authorized entrants and entry supervisor if unauthorized persons have entered the space.

Safety Manual

k. Perform non-entry rescues when possible, such as initiating a self-rescue of the entrants, using a winch, and tripod if necessary during vertical entries. l. Perform no duties that might interfere with the attendant’s primary duty to monitor and protect the authorized entrants. 9. Duties of Entry Supervisors a. The supervisor of the crew performing the confined space entry is designated as the entry supervisor. Each Entry Supervisor shall: i. Know the hazards that may be faced during entry, including information on the mode, signs, or symptoms and consequences of the exposure. ii. Verify, by checking that the appropriate entries have been made on the permit, that all tests specified by the permit have been conducted and that all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry to begin. iii. Terminate the entry and cancel the permit when entry operations are completed or if a condition that is not allowed under the entry permit arises in or near the permit space. iv. Verify that rescue services are available and that the means for summoning them are available. v. Remove unauthorized individuals who enter or who attempt to enter the permit space during entry operations. 10. Rescue and Emergency Services a. Rescue service must be on-site for immediately dangerous to life and health conditions (IDLH) while work in a permit required space is being performed. b. Employees of IBA Inc. shall not enter permit spaces for the purpose of attempting confined space rescues. If necessary, arrangements must be made for an outside party to be available for rescue (Host Employer rescue team, Fire Dept.). c. The rescue service must be informed of the hazards they may confront when called upon to perform rescues. d. To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant. e. A mechanical device such as a tripod and winch shall be available to retrieve personnel from vertical type spaces more than four feet deep.

Safety Manual

f. If an injured entrant is exposed to a substance for which a Safety Data Sheet (SDS) is required, the SDS must be made available to the medical facility treating the exposed entrant.

Safety Manual

Cranes and Rigging

1. General Crane Safety a. All manufacturer procedures applicable to the operational function of equipment must be complied with. All instructions and prohibitions must be followed when assembling and/or disassembling. i. Written approval from the manufacturer or a Professional Engineer must be obtained before modifying equipment if the changes may impact safe operation. b. The operator must know the weight of the load. c. The operator must know the pick and set radius of the load to be picked. d. The operator must know if the load is in the structural or tipping portion of the load chart. e. The operator may stop and refuse to lift a load if there is a safety concern. A qualified person shall determine that safety has been assured. f. Rated load capacities and recommended operating speeds, special hazard warnings or instruction shall be posted on all cranes. Instructions and warnings must be visible to the operator in the cab. g. Only a qualified signalman may signal the crane operator. Proper hand/radio signals shall be used to signal the operator. Only one employee shall signal the operator at a time. The operator shall not hoist a load if incorrect signals are used, if more than one employee tries to signal the crane, or the operator is unclear of the signal (see hand signals chart). h. Belt, gears and other rotating or reciprocating parts that employees may be exposed to must be guarded. i. Accessible areas within the swing radius of the counterweight must be barricaded. j. Before operation begins, the crane operator must identify the work zone by demarcating boundaries and prohibit operating past them or define the work zone by 360 degrees around the equipment’s maximum working radius. After the work zone has been defined the operator shall determine if the load, load line, or crane could get within 20 feet of overhead power lines (at equipment’s maximum working radius in the work zone). If so, one of the following options must be followed.

Safety Manual

i. Option 1: The lines shall be de- energized and grounded, or ii. Option 2: Implement encroachment precautions and ensure that no part of the crane, load line or load gets closer than 20 feet. iii. Option 3: Implement encroachment precautions and ensure that no part of the crane, load line or load can get within the distances of the power lines defined by table A. (Table A compares Kilovolts to required distances in feet) 1. Encroachment Precautions: a. Conduct a planning meeting with all employees involved with the crane operation. Fill out the proper IBA form for encroachment. b. All taglines used must be non-conductive c. Erect an elevated warning line at the approach distance (20 feet or as defined in table A clearance) AND perform/complete at least one of the following: d. Use of an insulated link e. Use of a dedicated spotter f. Use of a range control/warning device on the crane g. Use of a proximity alarm. k. IF YOU MUST OPERATE WITHIN TABLE A CLEARANCE PLEASE CONTACT THE SAFETY DEPARTMENT IMMEDIATELY! l. The controlling entity is responsible for providing the crane company with firm and drained ground conditions for site access and crane setup. The crane operator shall make sure the crane is set up on a firm foundation, with adequate cribbing, and deploy all outriggers. Make sure the crane is level. m. Keep workers clear of loads about to be lifted and suspended loads. Warn any unnecessary personnel or stragglers in the area. n. Loads shall not be swung or suspended over persons. o. When picking a load, start, stop and swing slowly. p. Watch for defective rigging equipment or poor rigging technique. q. The operator must be alert at all times. The operator may not leave the cab with a load on the crane. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 108 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

2. Training. All crane operators are certified by a nationally recognized third-party organization and must maintain the required state and city license. Refer to QMS P720-Competence and Awareness. a. Crane Operators will be evaluated on the machine they are assigned to operate. 3. Crane Inspections a. All cranes are to be inspected annually and certification shall be kept on file. b. The operator shall inspect the crane before each use and during use. Deficiencies shall be repaired, or defective parts replaced, before continued use. Inspections shall be documented on a crane inspection checklist daily and retained for a minimum of 3 months. 4. Crane and Assembly and Dismantling a. Assembly/disassembly must be directed by a person who meets the criteria for both a competent person and a qualified person. That person is considered the A/D Director. b. All persons assisting with the A/D of the crane must understand the following: i. Their tasks ii. The hazards associated with their tasks iii. The hazardous positions/conditions that they need to avoid 5. Crane Suspended Personnel Platforms (man baskets). With the exception of steel erection, man baskets may only be used if all other options have been considered and have been determined to be infeasible or more hazardous. a. The total weight of the pick may not exceed 50% of the rated capacity for the radius and configuration of the crane. b. Cranes must be equipped with an anti-two-block device. c. Only approved man baskets may be used for hoisting personnel. Baskets may not be job made. d. Man-baskets may not be used for hoisting only tools, equipment or materials. e. A proof test shall be conducted whenever a man basket is delivered to a job site. The proof test consists of lifting a test weight 125% of the basket’s capacity and holding it for five minutes. At the end of five minutes the rigging and basket are checked for defects. f. A trial lift shall be made every time the crane is set up in a new location to hoist employees. The trial lift shall follow these procedures: i. The empty basket shall be lifted to each area personnel are to be lifted to.

Safety Manual

ii. After the trial lift, the basket, the crane and the rigging shall be inspected for defects. g. In addition to a full guardrail and expanded metal around the basket, employees will be protected from falling by the use of personal fall arrest systems. 6. General Rigging Safety a. Rigging must be used and maintained in accordance with manufacturer's recommendations. b. The rigger must know the weight of the load and the rated capacities of any slings or rigging hardware. Do not exceed these capacities. c. Know the center of gravity of the load. Attach the load above the center of gravity or secure the load. d. Select the sling best suited to the load and select a hitch that will hold and control the load. e. Inspect all rigging equipment prior to each use. f. Protect slings from sharp edges. g. Allow for reductions in sling capacity when using choker hitches or severe sling angles (see diagram). h. Use only alloy chain (Grade 80) when lifting with chain slings. i. All loads shall include at least one tagline to help control and steady the load. j. Riggers must be Qualified Riggers to work in the state of Maryland. 7. Rigging Inspections a. Rigging equipment for material handling shall be inspected each day before being used by a Qualified person to ensure it is safe. Slings and all fastenings and attachments shall be inspected for damage or defects. b. Synthetic Web Slings. Additional inspections shall be performed during sling use, where service conditions warrant. Damaged or defective slings shall be immediately removed from service. Synthetic web slings should be replaced under any of the following conditions: i. Acid or caustic burns ii. Burned, melted or charred iii. Snags, punctures, tears or cuts iv. Broken or worn stitching v. Excessive fraying, red warning threads visible vi. Tag missing or illegible vii. Ultraviolet sunlight damage viii. Any other conditions which may reduce the capacity. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 110 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

c. Wire rope slings. Wire rope slings should be replaced under any of the following conditions: i. Missing or illegible tag ii. 6 Randomly broken wires in one lay or 3 broken wires in one strand in one lay iii. Kinking, crushing, bird-caging or other damage to the braided structure of the rope iv. Heat damage v. Severe corrosion or pitting vi. Damaged end attachments vii. Bent hooks d. Chain Slings. Chain slings should be replaced under any of the following conditions: i. Missing or illegible tag ii. Excessive wear iii. Twisted, bent or cut links iv. Cracked welds in the links v. Severe nicks and gouges vi. Excessively stretched links vii. Severe corrosion viii. Worn or damaged master link ix. Bent hooks 8. Rigging Workplace Safety Program a. Purpose: The purpose of this safety policy and procedure is to establish the methods and guidelines for the safe use of rigging equipment/tools throughout IBA. Slings, grips and swivels are components of hoisting and rigging systems and are used to lift and move loads. At IBA, alloy steel chain, wire rope, natural and synthetic fiber rope, and synthetic web slings are typically used. Our rigging is capable of lifting tremendous loads. This safety policy and procedure provides guidelines for implementing an effective safe rigging use program. It includes provisions for training, recognizing the types of slings, grips, and swivels used at IBA, understanding the attachments used with slings, and inspecting slings. Additionally, it presents information on inspection requirements and subsequent removal from service. It is the policy of IBA to provide a place of employment free from recognized hazards that cause or are likely to cause death or serious physical harm to employees or the public. Therefore, to minimize and eliminate material lifting hazards, properly Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 111 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

rated rigging that are not damaged or defective will be used at IBA. When hazards exist that cannot be eliminated, then engineering practices, administrative practices, safe work practices, Personal Protective Equipment (PPE), and proper training regarding rigging will be implemented. These measures will be implemented to minimize those hazards to ensure the safety of employees and the public. b. Responsibilities: It is the responsibility of the Safety & Quality Department, each manager/unit head, supervisor, and employee to ensure implementation of IBA’s safety policy and procedure on rigging. It is also the responsibility of each IBA employee to report immediately any unsafe act or condition of equipment to his or her supervisor. c. Division Managers: Managers are to assist the Safety & Quality Department to coordinate the required training for the affected employees. Managers will also allow for auditing of their safe rigging use program to ensure effective implementation with this safety policy and procedure. d. Foremen: Each year, foremen or a designated employee will coordinate with the Safety & Quality Department and IBA warehouse staff to inspect all rigging for wear and for defects in composition and welds. The warehouse staff will then tag those slings appropriately as per ANSI requirements and the IBA Tool Watch system. Foremen will ensure that defective or damaged rigging will be removed from service. Foremen will also ensure that employees are provided with the appropriate Personal Protective Equipment (PPE) as necessary for their job (e.g., foot, hand, or eye protection as necessary). Each foreman shall maintain an adequate supply of appropriate rigging. The foremen are to ensure that all components are delivered with the appropriate manufacturer’s certification. e. Employees: Employees shall comply with all applicable training. Additionally, employees shall check tools prior to use each time they are using any rigging material. All employees are to report all damaged rigging and/or unsafe conditions to their supervisors. f. Safety & Quality Department: The Safety & Quality Department will provide prompt assistance to managers, foremen, or others as necessary on any matter concerning this safety policy and procedure. The Safety & Quality Department will assist in developing or securing the required training as well as selecting the appropriate types of rigging tools to be used companywide. The Safety & Quality Department will work to ensure Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 112 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

that all newly purchased tools comply with this safety policy and procedure. Additionally, they will provide consultative and audit assistance to ensure the safe use of rigging. g. Training: Employees who use rigging will be trained in: i. Types of slings, rope, hoists, grips, and swivels ii. Applications and limitations of the various types of rigging iii. Inspection procedures for rigging iv. Appropriate storage of tools v. Remove and destroy damaged rigging from service vi. These employees will be trained upon initial employment or upon new job assignment. Subsequent training will be determined by employee’s supervisor and the Safety & Quality Department. All relevant training associated with the inspection of IBA’s rigging shall also be conducted during the IBA Qualified Rigger Training and/or training from the IBA vendor that is selected. h. Selection and Use of Rigging Types i. Several types of rigging are used throughout IBA and include: 1. Alloy Steel Chain Slings 2. Wire Rope Slings 3. Natural and Synthetic Fiber Rope Slings 4. Synthetic Web Sling 5. Sock Grips 6. Spring Grips 7. Bull Dog Grips 8. Overhead Swivels 9. Underground Swivels 10. Breakaway Swivels 11. “Dummy” Swivels” 12. Shackles 13. Chain Hoists 14. Strap Hoists 15. “Hot” Hoists 16. Pulling Rope 17. Rope slings i. Rigging selection for a particular task is based on: i. Rated capacity of the tool ii. Nature of the task iii. Amount of weight required to be lifted, hoisted or moved Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 113 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

j. Slings: i. The user should determine that the sling is being used in accordance with rated capacity as listed in the manufacturer’s catalog. The alloy steel chain, wire rope and fiber rope slings are typically used where sling damage to the load is not critical. Synthetic web slings are ideal where sling damage to a load is not acceptable. k. Wire rope slings must be proof tested by the manufacturer to ensure quality. A certificate verifying rated capacity will accompany each wire rope sling. This certificate must be available for review. l. The natural and synthetic fiber rope slings are other alternative materials that combine strength with ease of handling. If splices are used in natural and synthetic fiber rope slings, several design requirements must be met. Our pulling rope machines, and transformer slings are to be treated as a slings and the manufacturer’s rating must accompany these items. m. Alloy chain slings will have permanent identification affixed to the sling indicating the size, grade, rated capacity, and reach of the sling. Untagged slings will be removed from service. Alloy steel chains and chain slings should not be heated above 600 degrees after being received from the manufacturer. n. Synthetic web slings must be marked or coded to show the rated capacities for each type of hitch, type of web material, and manufacturer. Additionally, synthetic web slings must not be exposed to fumes, vapors, sprays, mists, liquid acids, liquid phenolic, or liquid caustics. o. Hoists or “Come-a-longs” should be verified that the hoist is being used in accordance with rated capacity as listed in the manufacturer’s catalog. Steel chain, wire rope and synthetic web hoists are what IBA typically uses. Synthetic web strap hoists should be inspected as a synthetic web sling, wire rope hoists should be inspected as wire rope slings are, and chain hoists shall be inspected as chain slings are. Careful inspection of the working body of the hoist is required as well. All defective or damaged hoists shall be returned to the IBA warehouse staff. p. Swivels. The user should determine that the swivel is being used in accordance with rated capacity as listed in the manufacturer’s catalog. All employees shall confirm the breaking strength and safe working load limit (SWL) prior to utilizing the swivel.

Safety Manual

q. Grips. The user should determine that the grip is being used in accordance with rated capacity as listed in the manufacturer’s catalog. All employees shall confirm the breaking strength and safe working load limit (SWL) prior to utilizing the grip. All employees shall confirm that the grip is being used for the size wire that is being pulled. r. Shackles shall have permanently affixed and legible identification markings as prescribed by the manufacturer that indicates the recommended safe working load. s. Attachments. All attachments including hooks, rings, oblong links, pear shaped links, and welded link components will be rated at least at the capacity of the sling itself. Makeshift links or other shop fabricated attachments will not be used. Slings twisted more than 10 degrees from the plane of the unbent hook will not be used. t. Inspections. Rigging will be inspected each day prior to use. Any visual defects must be reported. Damaged tools will not be used. In severe conditions (e.g., temperature, corrosion, etc.), rigging will be inspected throughout the day. Alloy chain slings will have recorded inspections every year by a supervisor or designated employee for wear and defects in composition and welds. This inspection will consider not only the physical aspects, but also the total service life of the slings. This inspection will be recorded and maintained on file with the date of the inspection and name and signature of the employee performing the inspection. This includes all hoists, grips, swivels, and rope. u. Daily inspections are visual inspections by the user of the tool. Recorded inspections will be annual (or as needed) inspections that are documented and placed under the manufacturers testing criteria. v. Sling Repair Slings must be in good condition and not damaged or defective to ensure safe and reliable use. If slings are worn, damaged or defective they shall not be used. If the slings are believed to be repairable, then those slings will be returned to the sling manufacturer for repairs. The manufacturer must proof-test all repaired slings before they are accepted for reuse. Under no circumstances will employees attempt to repair slings for reuse. Broken links or attachments on steel alloy chain slings will not be repaired using mechanical coupling links. Additionally, any sling with temporary repairs will not be used. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 115 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

w. Removal from Service. If slings are damaged or defective, they shall not be used. Until repairs are made on defective or damaged slings, they will be removed from service and made unusable. If these slings are not repairable, they will be permanently removed from service and destroyed. x. All damaged slings or rigging equipment will be “destroyed” if possible. Destroying rigging tools means to cut or make unusable. If the item cannot be “destroyed” in the field, then it must be tagged and returned to the IBA warehouse so that it will be returned to the manufacturer. y. Safe Sling Operation i. The following procedures will be followed when using slings: 1. If there is no rating tag, DO NOT USE. 2. Illegible tags may not be used. They must be returned to the warehouse to be re-tagged. 3. Slings damaged or defective will be removed from service and destroyed. 4. Slings will not be shortened with knots or bolts or other makeshift devices. 5. Sling legs will not be kinked. 6. Slings will not be loaded beyond their rated capacity. 7. Slings used in a basket hitch will have the loads balanced to prevent slippage. 8. Slings will be securely attached to their loads. 9. Slings will be padded or protected from the sharp edges of loads. 10. Suspended loads will be kept clear of obstructions. 11. All employees will be kept clear of loads about to be lifted and of suspended loads. 12. Hands or fingers will be kept clear of loads and not placed between the load and the strap. 13. Shock loading will not be allowed. 14. Slings will not be removed while loads are resting on the sling. z. Natural and Synthetic Fiber Rope Slings Splices The use of natural and synthetic fiber rope slings utilizing splices will not be used unless the following requirements for design are met:

Safety Manual

i. In manila rope, eye splices will consist of at least three full tucks, and short splices will consist of at least six full tucks, three on each side of the splice center line. ii. In synthetic rope, eye splices will consist of at least four full tucks, and short splices will consist of at least eight full tucks, four on each side of the center line. iii. Strand end tails will not be trimmed flush with the surface of the rope immediately adjacent to the full tucks. This applies to all types of fiber rope and both eye and short splices. For fiber rope under one inch in diameter, the tail will project at least six inches beyond the last full tuck. iv. Fiber rope slings will have a minimum clear length of rope between eye splices equal to ten times the rope diameter. v. Knots will not be used in lieu of splices. vi. Clamps not designed specifically for fiber ropes will not be used for splicing. vii. For all eye splices, the eye will be large enough to provide an angle of not greater than 60% at the splice when the eye is placed over the load or support. aa. Wire Rope and Wire Rope Slings Inspection Procedure. i. The following information is to be used as a guide for inspecting wire rope and wire rope slings. Inspection frequency should be based on safety factors, property damage, and the cost of replacing destroyed, or damaged goods and material dropped due to the use or misuse of improper or damaged wire rope and slings. Additionally, slings should be inspected at regular intervals. This interval should be determined by the user and is dependent upon the particular use of the sling and Safety & Quality Department requirements. A sling should be inspected after any unusual situation that may have damaged it, such as overload, accident, or fire. It should not be returned in service until continued safe operation has been verified. All slings, at a minimum, will have a recorded inspection annually. ii. Each sling should have a Tool Watch number or be assigned to a truck. If no number is available, a tag should be attached at the time of inspection. This number should be listed on the inspection report. Inspection should be performed only by persons with sufficient experience and knowledge to properly apply the criteria Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 117 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

for rejection. The following should be considered criteria for rejection: 1. Randomly Distributed Broken Wires in One Rope Lay: There should be no more than 10 broken wires in one lay for the entire length of the sling. 2. Broken Wires in One Strand of One Rope Lay: There should be no more than five broken wires in any one strand (single wire) of any one rope lay. 3. Abrasion: There should be no wearing, scrubbing, or preening of any outside wire causing the reduction of the diameter of a single wire by more than 1/3. 4. Kinking and/or Crushing: There should be no kinking, crushing, or other damage that results in detrimental distortion of the rope structure. 5. Bird Caging: There should be no opening or unlaying of the rope lays nor should the fiber core of the rope be exposed. 6. Heat Damage: There should be no evidence of heat damage including bare electrical conductor, grounding, or welding arc. 7. Corrosion: There should be no evidence of pitting or heavy coating of rust due to corrosion. 8. Reduced Diameter: There should not be any reduction of the diameter of the rope along the main length or of any section (overloading or contact with sharp edges of load without permission). 9. End Attachments: There should be no evidence of cracks, deformity, excessive corrosion, or excessive wear of the fittings forming the splice or socket. 10. Hooks and Rings: Check for throat opening (no more than 15% stretch), twist (no more than 10%), cracks (none), and corrosion bb. Pulling Grips and Swivel Inspection and Use i. Swivel and pulling grips shall: 1. Manufacturer specifications shall always be considered. 2. All swivels and pulling grips shall be inspected prior to each use. All swivels and pulling grips will be removed from service one year after their first use. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 118 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

a. These items will then be inspected prior to be placed back into service. ii. All swivels will have a Tool Watch number applied to the middle of the tool. All pulling grips will have their Tool Watch number applied to the crimp of the rigging eye. 1. Tool Watch to track issue date and utilize “service ticket” option for testing and inspection information. iii. All project tools to be returned at the completion of the project to warehouse staff and the Safety & Quality Department. 1. Distribution swivels and pulling grips will fall under sub bullet “b” and will be removed from service annually. 2. All distribution swivels and pulling grips are to be stored properly. It is recommended for these items to be housed in a designated area at the show up location. iv. Project by project consideration “throw away criteria”. Throw away criteria will be dictated by the Safety & Quality Department. 1. This will include appropriate testing by the IBA warehouse staff, Safety & Quality Department or vendors v. “Stock” pulling grips and swivels will be kept by the warehouse staff under the direction of the Safety & Quality Department. vi. When not in use, rigging equipment shall be removed from the immediate work area. 9. Sling Angles

Mechanical Splice – IWRC - Vertical, Choker or Vertical Basket Rated capacity in tons of 2,000 lbs. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 119 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

VERTICAL VERTICAL BASKET CHOKER

Rope Diameter IPS EIPS EEIPS IPS EIPS EEIPS IPS EIPS EEIPS (Inches)

1/4 0.56 0.65 0.71 0.41 0.48 0.52 1.1 1.3 1.4

5/16 0.87 1.0 1.1 0.64 0.74 0.81 1.7 2.0 2.2

3/8 1.2 1.4 1.6 0.92 1.1 1.2 2.5 2.9 3.2

7/16 1.7 1.9 2.1 1.2 1.4 1.6 3.4 3.9 4.3

1/2 2.2 2.5 2.8 1.6 1.9 2.0 4.4 5.1 5.5

9/16 2.8 3.2 3.5 2.0 2.4 2.6 5.5 6.4 7.0

5/8 3.4 3.9 4.3 2.5 2.9 3.2 6.8 7.8 8.6

3/4 4.9 5.6 6.2 3.6 4.1 4.5 9.7 11 12

7/8 6.6 7.6 8.3 4.8 5.6 6.1 13 15 17

1 8.5 9.8 11 6.3 7.2 8.0 17 20 22

1 1/8 10 12 7.9 9.1 21 24

1 1/4 13 15 10 11 26 30

1 3/8 15 18 12 13 31 36

1 1/2 18 21 14 16 37 42

1 5/8 21 24 16 18 43 49

1 3/4 25 28 19 21 49 57

2 32 37 24 28 64 73

Safety Manual

Rated capacities basket hitch based on D/d ratio of 25. Rated capacities based on pin diameter no larger than natural eye width or less than the nominal sling diameter. Rated capacities based on design of 5 Horizontal sling angles less than 30 degrees shall not be used.

Safety Manual

Cutting and Welding

1. Scope. This section addresses the hazards associated with the cutting and welding of metals. 2. Gas welding and cutting a. Transporting, moving and storing compressed gas cylinders (oxygen, acetylene, argon, etc.). The following rules and precautions shall be followed for all compressed gas cylinders regardless of their contents or whether they are empty or full. i. Valve protection caps shall be in place and secured when cylinders are not in use ii. When cylinders are hoisted, they shall be secured on a cradle, sling board or pallet. They shall not be hoisted or transported by means of magnets or choker slings. iii. Cylinders shall be moved by tilting them and rolling them on their bottom edges. They shall not be intentionally dropped, struck or permitted to strike each other violently iv. When a powered vehicle transports cylinders, they shall be secured in a vertical position v. Valve protection caps shall not be used for lifting cylinders. Bars shall not be used under valve protection caps to pry cylinders loose if they become frozen together vi. Unless cylinders are firmly secured on a cart specifically designed for carrying cylinders, regulators shall be removed, and valve protection caps replaced before cylinders can be moved vii. A suitable cylinder truck, chain or other means shall be used to prevent cylinders from falling over. viii. When work is finished, when cylinders are empty or when cylinders are moved at any time, the cylinder valve shall be closed. ix. Compressed gas cylinders shall be secured in an upright position at all times except, if necessary, for short periods of time when being moved. x. Oxygen cylinders in storage shall be separated from fuel-gas cylinders or combustible materials (especially oil or grease), a minimum distance of at least 20 feet or by a noncombustible barrier at least 5 feet high with a fire resistance rating of at least one-half hour. xi. Inside of buildings, cylinders shall be stored in well ventilated, well protected, dry locations at least 20 feet from highly combustible Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 123 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

materials. Assigned storage areas shall be located away from elevators, stairways or gangways. Storage areas shall also be located where cylinders will not be knocked over, damaged by passing or falling objects or tampered with by unauthorized personnel. Cylinders shall not be kept in unventilated enclosures such as lockers or gang boxes. b. Placement of cylinders i. Cylinders shall be kept far enough away from the actual cutting or welding process so that sparks, hot slag or flame will not reach them. ii. Cylinders shall be placed where they cannot become part of an electrical circuit. Electrodes shall not be struck against a cylinder to strike an arc. iii. Fuel gas cylinders shall be placed with valve end up whenever they are in use. iv. Cylinders containing oxygen or acetylene, or other fuel gas shall not be taken into confined spaces. c. Treatment of cylinders i. Cylinders, whether empty or full, shall not be used as rollers or supports. ii. Employees shall not attempt to mix gases in a cylinder, refill a cylinder or use a cylinder for purposes other than the purposes intended by the supplier. iii. No damaged or defective cylinders shall be used. d. Use of fuel gas i. Before connecting a regulator to a cylinder valve, crack the valve slightly to clear any dirt or debris. Stand to one side of the valve when cracking it and be certain the fuel gas cannot reach another hot work operation. ii. Cylinder valves should always be opened slowly to prevent damage to the regulator. Valves should not be opened more than 1 ½ turns so they may be closed quickly in an emergency. When a special wrench is needed to open a valve, it shall be left on the valve while it is open. iii. Fuel gases shall always be used at pressures reduced through a regulator. iv. Before a regulator is removed from a cylinder valve, the cylinder valve shall be closed, and gas released from the regulator. v. Cylinders found to be leaking shall be removed from the work area. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 124 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

e. Hose i. Hoses shall be inspected at the beginning of each shift. ii. Hose which has been subjected to flashback shows evidence of severe wear or damage, or hose in doubtful condition shall not be used. iii. Couplings shall be of the type that cannot be unlocked or disconnected by a straight pull without rotary motion. iv. Boxes used for the storage of hoses shall be ventilated. v. Hoses, cable, and other equipment shall be kept clear of passageways, ladders and stairs. f. Torches i. Clogged torch tips shall be cleaned with suitable cleaning wires, drills, or other devices designed for that purpose. ii. Torches shall be inspected at the beginning of each shift for leaking shutoff valves, hose couplings, and tip connections. iii. Friction devices, and not matches or hot work shall light torches. g. Miscellaneous i. Oxygen and fuel gas pressure regulators and their gauges must be in proper working order while in use. ii. Oxygen can make oil or grease spontaneously ignite. Oxygen cylinders and fittings shall be kept away from oil or grease. Cylinders, cylinder caps and valves, couplings, regulators, hose, and apparatus shall be kept free from oil or greasy substances and shall not be handled by oily hands or gloves. Oxygen shall not be directed at oily surfaces, greasy clothes or within a fuel oil or other storage tank or vessel. 3. Arc welding and cutting a. Manual electrode holders i. Any current carrying parts passing through the portion of the holder which the cutter or welder grips in his hand, and the outer surfaces of the jaws of the holder, shall be fully insulated against the maximum voltage encountered to ground. b. Welding cables and connectors i. All cables shall be of the flexible type and fully insulated and capable of handling the maximum current requirements of the work in progress. ii. Welding leads must be free of repair or splice within ten feet of the stinger. c. Ground returns and machine grounding

Safety Manual

i. A ground return cable shall have a safe current carrying capacity equal to or exceeding the specified maximum output capacity of the welding machine it is servicing. ii. Pipelines containing gases or flammable liquids, or electrical conduits, shall not be used as a ground return. iii. The generation of an arc, spark, or heat at any point shall cause rejection of a structure as a ground circuit. iv. The frames of all welding machines shall be grounded either through a third wire in the cable containing the circuit conductor or through a separate wire which is grounded at the source of the current. Grounding circuits, other than by means of the structure, shall be checked to ensure that the circuit between the ground and grounded power conductor has resistance low enough to permit sufficient current to flow to cause the fuse or circuit breaker to interrupt the current. d. Safe operating instructions i. When electrode holders are left unattended, the electrodes shall be removed, and the holder shall be placed to prevent accidental contact with employees or conducting objects ii. Hot electrode holders must be kept away from water. iii. When the welder will be away from the electrode holder for any appreciable length of time, such as breaks or lunch, or when the machine is to be moved, the power supply switch to the machine must be opened. iv. Whenever possible, all arc welding and cutting operations shall be shielded to protect employees and other persons in the area from the direct rays of the arc. e. Fire prevention i. When possible, welding or cutting should be done in a designated area free of combustible materials. If the object to be welded or cut cannot be moved, all movable fire hazards in the vicinity shall be moved to a safe place or otherwise guarded. ii. If the object to be welded or cut cannot be moved, positive actions must be taken to contain the release of hot slag, sparks, and flame. iii. No welding, cutting, or heating of objects shall be done where the application of flammable paints or the presence of other flammable compounds, or heavy dust concentrations create a hazard.

Safety Manual

iv. Suitable fire extinguishing equipment shall be immediately available and shall be maintained in a state of readiness for instant use. The annual and monthly inspections shall be kept up to date. v. When the welding, cutting, or heating operation is such that normal fire prevention precautions are not sufficient, a fire-watch shall be posted while the actual welding, cutting, or burning are being conducted and for a thirty-minute period afterward to ensure that no possibility of fire exists. These operations must be documented on a hot work permit and turned into Safety & Quality after work is concluded. The fire-watch must be made aware of the specific nature of any anticipated fire hazards and how the firefighting equipment provided is to be operated. vi. Before heat is applied to a drum, container, or hollow structure, a vent or opening shall be provided for the release of any built-up pressure during the hot work operation. f. Ventilation i. Contaminated air exhausted through either general mechanical ventilation or local exhaust ventilation shall be discharged into the open air or otherwise clear of the source of intake air. ii. Oxygen shall not be used for ventilation purposes, comfort cooling, blowing dust from clothing or for cleaning the work area. g. Welding and cutting in confined spaces i. Ventilation shall be provided whenever welding, cutting, or other hot work is conducted within a confined space. ii. When sufficient ventilation cannot be obtained without blocking access to the confined space, employees in the space shall be protected by air supplying respirators. h. Welding, cutting or heating of metals of toxic significance i. Welding, cutting, or heating in any enclosed spaces involving the metals specified in this section shall be performed with general mechanical or local exhaust ventilation. 1. Zinc-bearing base or filler metals or metals coated with zinc-bearing materials. 2. Cadmium-bearing filler metals. 3. Chromium-bearing metals or metals coated with chromium-bearing materials. ii. Welding, cutting, or heating in any enclosed space involving the metals specified in this section shall be performed with local

Safety Manual

exhaust ventilation, or employees shall be protected by air supplying respirators. 1. Metals containing lead, other than as an impurity, or metals coated with lead-bearing materials. 2. Cadmium-bearing or cadmium-coated base metals. 3. Metals coated with mercury-bearing metals. 4. Beryllium-containing base or filler metals. Because of its high toxicity, welding or burning operations involving beryllium should be performed with both local exhaust ventilation and airline respiratory protection. 5. Air-purifying respirators shall protect employees performing such operations in the open air with appropriate filters. 6. Other employees exposed to the same hazards as those created by welders shall be afforded the same protection. i. Inert-gas metal-arc welding i. The inert-gas metal-arc (MIG, TIG) welding process involves: the production of ultra-violet radiation of intensities of 5 to 30 times that produced during shielded metal arc (stick) welding; the decomposition of chlorinated solvents (methylene chloride, trichloroethylene) by ultra-violet rays; and the liberation of toxic fumes and gases. Employees shall not be permitted to be engaged in, or be exposed to the process until the following special precautions have been taken: 1. The use of chlorinated solvents shall be kept at least 200 feet, unless shielded, from the exposed arc, and surfaces prepared with chlorinated solvents shall be thoroughly dry before welding is permitted on the surface. 2. Appropriate filter lenses shall protect employees in the area not protected by screening. 3. Welders and other employees exposed to radiation shall be protected so that the skin is protected to prevent burns and other damage by ultra-violet rays.

Safety Manual

Driving Safety

1. Scope. This policy applies to all drivers of company owned vehicles and drivers of privately-owned vehicles used for company business. Additional information and requirements for Commercial Motor Vehicles, which is any vehicle used in commerce with a gross weight rating over 10,000 lbs., might be required. 2. Driver Responsibilities. All drivers are required to: a. Read, understand, and follow the requirements of this program. b. Participate in any company sponsored activities or programs to improve driver safety. c. Maintain a valid driver’s license and adhere to license restrictions. d. All CMV drivers must maintain a current DOT physical card. 3. Authorization of Driving Privileges. Employees will not be permitted to operate a motor vehicle for company business if: a. The driver does not have a valid driver’s license issued by their state of residence. b. The driver possesses more than one driver’s license from more than one state. c. The driver’s license has been suspended or revoked for any reason. d. The employee has multiple moving violations. 4. Authorized Vehicle Use. a. Company vehicles may not be driven for personal use. b. Drivers of assigned vehicles may not allow unauthorized persons to operate company owned vehicles. c. Disciplinary action, up to and including termination, may be taken for unauthorized use of company vehicles. d. Employees may be held responsible for any losses incurred during an unauthorized use of company vehicles. 5. Driver Motor Vehicle Record (MVR) Checks. a. An MVR will be obtained for all new employees. b. MVRs will be checked yearly for all drivers. c. MVRs will be stored confidentially in each driver’s file. 6. Identification of High-Risk Drivers. A driver will be classified as “high risk” for any one of the following violations. a. Conviction for an alcohol and/or drug related driving offense. b. Refusal to submit to a Blood Alcohol Content (BAC) test. c. Conviction for reckless driving. d. Any combination of three or more moving violations or chargeable vehicle incidents, suspension, revocation, or administrative restriction within the last three years. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 129 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

e. Leaving the scene of an accident. f. At fault in a fatal accident. g. Felony committed involving a vehicle. h. Two or more damage claims to a company vehicle. i. Multiple speeding tickets. j. Fleeing or attempting to elude police. k. Driving without lights to avoid identification. 7. Management Controls for High Risk Drivers. a. Probation. At the discretion of management or the Loss Control Committee, high risk drivers may be placed on probation for a period of two years starting from the date of the most recent violation. i. Drivers placed on probation will be notified in writing and a copy of the notification will be kept on file. ii. An MVR will be obtained every six months during the probationary period iii. Driving privileges will be immediately suspended for any driving violations during the probationary period. iv. Additional measures may be taken for probationary drivers including: 1. Additional driver training. 2. Loss of company vehicle driving privilege between work and home. v. Suspension of Driving Privileges. Management or the Loss Control Committee may elect to suspend all driving privileges of high-risk drivers. 1. Drivers will be notified in writing of any suspension and a copy of the notification will be kept on file. 2. Management or the Loss Control Committee will determine the length of suspension. The suspension will be for at least a period of three months. 3. After a driver’s driving privileges, have been restored, he or she will be placed on probation for a period of two years. 8. Reporting Responsibilities. a. Each driver is to complete a vehicle incident form and report any vehicle incident to the Safety Department per the requirements of the “Incident Reporting and Investigation” section. b. Drivers are to report to the Safety & Quality Department any illness, injury, physical condition, or uses of medication that may impair or affect their ability to safely operate a motor vehicle.

Safety Manual

c. Drivers are to report to the Safety & Quality Department any suspension, revocation, or administrative restriction of his or her operator’s license. d. Failure to report any of these situations to the Safety & Quality Department may result in disciplinary action up to and including termination. 9. Safety Requirements. a. Seat Belts. The driver and all occupants are required to wear seat belts when operating or riding in a motor vehicle. The driver is responsible for ensuring that all passengers are wearing seat belts. b. Cell Phone. The driver must have a reliable form of communication in case of emergency. c. Impaired Driving. A driver may not operate a motor vehicle at any time when his or her ability is impaired, affected, or influenced by drugs, alcohol, medication, illness, fatigue, or injury. i. Fatigue. When driving long distances and two qualified drivers are in the vehicle take turns driving. If driving alone, pull over at a safe location, get out of your vehicle to stretch and take a break. d. Traffic Laws. Drivers are required to abide by all federal, state, and local motor vehicle regulations, laws and ordinances. i. Each driver is required to report all traffic violations to IBA immediately. ii. This requirement is consistent with the Incident Reporting section of this manual. e. Each driver is responsible for ensuring that the motor vehicle is maintained in safe driving condition and equipped with a roadside emergency kit. f. CMV drivers must perform and document pre/post trip inspections. g. Drivers are required to drive with headlights on at all times when conditions warrant. h. When practicable, driving should be done during daylight hours. i. Drivers may not pick up hitch hikers. j. Drivers may not use radar detectors, laser detectors, or similar devices. k. Drivers may not push or pull another vehicle without authorization. l. Drivers may not transport flammable liquids or gases unless a DOT or UL approved container is utilized. m. Drivers may not use ignition or burning flares. Reflective triangles are preferred. n. Whenever hauling a load that protrudes from the vehicle or trailer, it must be flagged. If travelling at night, the protruding load must have lights to identify the load in the dark. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 131 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

10. Distracted Driving. a. Always give full attention to driving – driving safely is your first responsibility. b. CMV drivers may not hold, dial or text with a cell phone or other message transmitting device, such as computers or tablets. c. Pull off the road and park before making or answering a call if driving conditions so require. d. To avoid interfering with blasting operations, turn your phone OFF when in a “blasting area” or in areas posted “turn off two-way radios”. e. If you must use your phone in traffic use a hands-free device, if available, so both hands can stay on the wheel. f. Realize that you will be distracted every time you use the phone. Adjust your driving accordingly – drive slower and increase your following distance. g. Avoid emotional or complex phone calls. Keep conversations as short as possible. h. Never take notes or look up phone numbers while driving. i. Have passengers place and receive calls for you if possible. j. Check the laws and regulations on the use of wireless telephones in the areas where you drive. Always obey them. 11. Inclement Weather. Always slow down and increase your following distance when driving in inclement weather. a. Rain. i. Always turn your lights on in the rain. ii. Slow below posted speed limits on ramps and curves. iii. Slow to a safe speed before curves and accelerate slightly through them. Avoid braking through curves. iv. If you begin to hydroplane do not apply the brakes, let off the gas (depress clutch in manual transmissions) until you slow, and the tires regain traction. b. Snow and Ice. i. Snow or ice-covered roads are more slippery at 32 degrees than they are at zero due to a layer of moisture on top of the snow or ice. ii. Clean all windows, lights, and turn signals before driving. iii. Keep windshield wiper fluid full iv. Accelerate, turn, change lanes, and stop slowly and smoothly. v. Signal well in advance for turns, stops, and lane changes. vi. Be prepared for a breakdown or getting stuck. Bring warm clothing, boots, flashlight, and telephone. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 132 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

vii. If roads appear wet but other vehicles’ tires are not kicking up spray, the roadways may be icy. c. Fog. i. If visibility diminishes to a point you must slow to a crawl, find a safe place to pull off the road. Pull as far off the road as possible; do not park on the shoulder where you may be struck. ii. Use low beams. d. General moving expectations. i. All drivers are required to perform a Get Out And Look (GOAL) circle for safety prior to moving their vehicle without a spotter. ii. All drivers are required to plan a route before traveling to an unfamiliar destination and communicate this to their supervisor. A GPS device may be used, but printed directions should be kept as back-up when cell phone coverage may not be available. iii. All workers are to use a spotter when available on the jobsite whenever moving a vehicle or piece of equipment. 1. Spotter use is required when moving IBA vehicles in any direction in tight spaces 2. Whenever the driver loses sight of their spotter, they are to STOP and wait until the spotter is seen and provides direction. Vehicle movement is a Critical/Irreversible Step and moving the vehicle requires a spotter as a Peer Check. iv. All large equipment requires cones to be placed at the front and rear of the vehicle after parking. Those cones are to be picked back up prior to moving to ensure an inspection of the truck and plan a route prior to moving. 1. An exception to this rule is when the vehicle is in the construction work zone alongside the roadway. a. Chocks are to be placed on the driver’s and passenger side wheels blocking brake failure for both front and rear movement. This assists in creating a circle for safety when working in a work zone when cones are not being used at the front and rear of the vehicle. v. Any observed improvement opportunities are to be coached to these policies. If the coaching is unsuccessful, then re-training may be assigned by the supervisor or Safety & Quality Department.

Safety Manual

1. All driver re-training is unpaid and held at the Kinsley Education Center or onsite vi. If the operator of the vehicle or equipment has an obstructed view, including to the rear and a second person is available, they shall act as the spotter. vii. Loads shall be secured and within the manufacturer’s legal limits. viii. Vehicles shall be used according to manufacturer’s recommendations as it pertains to size and intended use.

Safety Manual

Excavation

1. General Requirements. This section applies to all open excavations. An excavation is any man-made cut, cavity, trench, or depression in the earth’s surface, formed by earth removal (see attachment 17-1) a. All surface encumbrances, such as signs, telephone poles, etc., shall be removed or supported prior to excavating adjacent to them. b. The locations of all utility installations shall be determined prior to excavation. (see APWA temporary marking guidelines- Appendix B) i. Mark the proposed dig area with white boundaries and then call the appropriate utility location service. ii. The utility location service must be contacted between 3 to 10 days prior to excavating. The location service will mark the estimated locations of all underground utilities within the dig area. Protect and preserve the markings. If they are lost, another call must be made to the utility locator. iii. 811 is the new number you should call before you begin any digging project- Nationwide! iv. An 18-inch tolerance zone must be maintained on either side of any markings. v. Hand dig test pits until the utility is located. vi. If a line must be exposed, it must be supported and protected while the excavation is open. c. A means of egress such as a ladder, ramp, stairway, or other safe means must be provided in every trench type excavation, four feet or more in depth, within 25 feet of lateral travel for any employee working in the trench. d. Employees exposed to vehicular traffic shall be protected by the use of highly visible reflectorized vests and any necessary traffic control patterns as determined by the Manual of Uniform Traffic Control Devices or more stringent state requirements. e. No employees may work underneath loads handled by lifting or excavating equipment. Employees must stay clear of any vehicles being loaded or unloaded. f. Employees may not work in excavations in which water is accumulating unless additional precautions are taken.

Safety Manual

g. The stability of adjacent structures such as walls or buildings must be ensured before excavating adjacent to them. Shoring, bracing or underpinning may be required. h. All loose rock and soil shall be kept from the face of excavation walls. Spoil piles shall be kept back at least two feet from the edge of the excavation. i. Excavations and the surrounding areas must be inspected daily by a competent person to identify hazardous situations such as cave-in, protective system failure, hazardous atmosphere, or other hazardous conditions. j. Excavations not readily seen because of plant growth or other barriers shall be barricaded. All excavations not back filled at the end of the shift shall be barricaded. 2. Protective Systems a. All employees in excavations must be protected from cave-ins by one of the following methods except when: i. The excavation is made entirely in stable rock, or ii. The excavation is less than 5 feet deep and a competent person determine that there is no indication of a potential cave-in. b. Protective Systems i. Sloping or Benching 1. Sloped excavations must be sloped back at an angle not steeper than one and one-half horizontal to one vertical (34-degree angle of repose) 2. Excavations can be sloped or benched in accordance with Appendix A after a soil classification by a competent person. c. Shielding i. Shield systems shall be built and used in accordance with the manufacturer’s certification. The certification must be on site while a shield is being used. ii. Shields may be placed up to two feet from the bottom of the trench if there is no indication of soil loss from below the shield. iii. When a combination sloping-shielding system is being used, the excavation must be sloped back to at least 18 inches below the top of the shield. iv. Employees are not allowed in shields when they are being installed, removed or moved vertically. v. Shields shall be installed in a manner to prevent lateral movement in the event of a cave-in. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 136 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

d. Shoring i. Aluminum hydraulic shoring shall be installed and used in accordance with the manufacturer’s tabulated data. The tab data must be on site while the shoring is being used. ii. Hydraulic shoring is to be set up completely from outside the trench. e. Design by a Registered Professional Engineer i. Any other protective system, or any sloping or benching system in an excavation greater than 20 feet deep shall be designed by a professional registered engineer. ii. The engineered design must be available on site. 3. Soil Classification a. Requirements - Classification of soil and rock deposits. Each soil and rock deposit shall be classified by a competent person as Stable Rock, Type A, Type B or Type C. b. Basis of classification. The classification of the deposits shall be made based on the results of at least one visual and at least one manual analysis. Such analyses shall be conducted by a competent person using tests described in OSHA’s Excavation Standard (Subpart P). c. Layered systems. In a layered system, the system shall be classified in accordance with its weakest layer. However, each layer may be classified individually where a more stable layer lies under a less stable layer (example: Type C over Type B) 4. 811 calls a. 3-10 days in advance i. Mark out area in white ii. Photo/Video of marks prior to digging iii. Survey area to check for discrepancies and tell tales 1. Manholes, valves, pedestals 2. Call for re-mark if they exist iv. Recall if marks are damaged or illegible or every 10 days b. When digging in or around a substation, on PPL property, give 5 days’ advance notice. i. Under “Type of Work” state: “substation excavation work”. ii. Also note the substation name under “Subdivision” iii. Then look out for your One Call response. 5. Trenching/excavating a. 811 call ticket start date must be adhered to b. Considered potentially hazardous until determined otherwise i. Combustible Gas Indicator (CGI) use Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 137 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

1. LEL - Acceptable levels are less than 10% 2. CO – Acceptable levels are less than 35 ppm 3. O2 – Acceptable levels are between 19.5% and 23.5% 4. H2S - Acceptable levels are less than 10 ppm ii. If Alarm sounds clear trench and ventilate as necessary 1. If alarm continues with ventilation stop and call Safety personnel 6. Prudent techniques a. Hand dig to reveal facility b. Hand dig to 18” tolerance zone on both sides of mark (no mechanical devices) i. If no line is uncovered continue to the desired depth maintaining tolerance zone ii. If a line is uncovered tolerance zone is then measured by outer width of the line iii. If trenching parallel to a marked line, test pit at pre-determined intervals to eliminate crossing of intended trench c. Protect or secure any uncovered facility in trench i. Contact facility owner if unsure of procedure d. Backfill protection of uncovered facilities i. Contact facility owner if unsure of procedure 7. Gas Strike a. Any contact with gas line/tracer wire i. Shut down equipment and clear area – if it can be done safely 1. Abandon equipment and move to a “safe distance”. ii. Call 911 (state law) 1. Inform the property owner of hazard and assist in their evacuation. DO NOT RING DOOR BELL! iii. Call facility owner/811 iv. Avoid open flames and remove all ignition sources v. Contact Safety personnel, GF and Construction Supervisors vi. Do not attempt to repair or operate gas line valves vii. Do not attempt to put out any open fires, allow to burn 8. Electrical Strike a. Any contact with electric line including overhead i. Shut down equipment remain in seat and clear area ii. Call 911 iii. Call facility owner/811 or System Operators iv. Contact Safety personnel, GF, and Construction Supervisors 9. All other facilities Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 138 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

a. Damage to Potable water line, Reclaimed water/slurry, Sewer, Communication i. Call 911 (if traffic/property is at risk) ii. Call facility owner/811 iii. Contact Safety personnel, GF, and Construction Supervisors

Safety Manual

Appendix A – Sloping and Benching

Maximum Allowable Slopes (H:V) [1] For Excavations Less

Than 20 Feet Deep[3] Soil or Rock Type

Stable Rock……………………………… Vertical (90 deg.) Type A[2]…………………………………. ¾: 1 (53 deg.) Type B…………………………………… 1: 1 (45 deg.) Type C…………………………………… 1 ½: 1 (34 deg.)

Notes: 1 Numbers shown in parentheses next to maximum allowable slopes are angles expressed in degrees from the Horizontal. Angles have been rounded off. 2 A short- term maximum allowable slope of ½ H: 1 V (63 deg.) is allowable in excavations in Type A soil that are 12 feet or less in depth. Short-term maximum allowable slopes for excavations greater than 12 feet in depth shall be ¾ H: 1 V (53 deg.) 3 Sloping or benching for excavations greater than 20 feet deep shall be designed by a registered professional engineer. (Allowable sloping and benching configurations are included in Appendix A) B - 1.1 Excavations made in Type A soil. All simple slope excavation 20 feet or less in depth shall have a maximum allowable slope of 3/4:1.

SIMPLE SLOPE – GENERAL

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Exception: Simple slope excavations that are open 24 hours or less (short-term) and which are 12 feet or less in depth shall have a maximum allowable slope of 1/2:1.

SIMPLE SLOPE – SHORT-TERM 2. All benched excavations 20 feet or less in depth shall have a maximum allowable slope of 3/4 to 1 and maximum bench dimensions as follows:

SIMPLE BENCH

MULTIPLE BENCHES

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3. All excavations 8 feet or less in depth which have unsupported vertically sided lower portions shall have a maximum vertical side of 3 1/2 feet.

UNSUPPORTED VERTICALLY SIDED LOWER PORTION - MAXIMUM 8 FEET IN DEPTH) All excavations more than 8 feet but not more than 12 feet in depth with unsupported vertically sided lower portions shall have a maximum allowable slope of 1:1 and a maximum vertical side of 3 1/2 feet.

UNSUPPORTED VERTICALLY SIDED LOWER PORTION - MAXIMUM 12 FEET IN DEPTH) All excavations 20 feet or less in depth that have vertically sided lower portions that are supported or shielded shall have a maximum allowable slope of 3/4:1. The support or shield system must extend at least 18 inches above the top of the vertical side.

Safety Manual

B - 1.2 Excavations Made in Type B Soil 1. All simple slope excavations 20 feet or less in depth shall have a maximum allowable slope of 1:1.

SIMPLE SLOPE

2. All benched excavations 20 feet or less in depth shall have a maximum allowable slope of 1:1 and maximum bench dimensions as follows:

SINGLE BENCH

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MULTIPLE BENCHES 3. All excavations 20 feet or less in depth which have vertically sided lower portions shall be shielded or supported to a height at least 18 inches above the top of the vertical side.

All such excavations shall have a maximum allowable slope of 1:1. VERTICALLY SIDED LOWER PORTION

Safety Manual

B - 1.3 Excavations Made in Type C Soil 1. All simple slope excavations 20 feet or less in depth shall have a maximum allowable slope of 1 1/2:1.

SIMPLE SLOPE 2. All excavations 20 feet or less in depth which have vertically sided lower portions shall be shielded or supported to a height at least 18 inches above the top of the vertical side. All such excavations shall have a maximum allowable slope of 1 1/2:1.

VERTICAL SIDED LOWER PORTION

Safety Manual

Appendix B- APWA Temporary Marking Guidelines

WHITE- Proposed Excavation

PINK- Temporary Survey Markings

RED- Electric Power Lines, Cables, Conduit and Lighting Cables

YELLOW- Gas, Oil, Steam, Petroleum or Gaseous Materials

ORANGE- Communication, Alarm or Signal Lines, Cables or Conduit

BLUE- Potable Water

PURPLE- Reclaimed Water, Irrigation and Slurry Lines

GREEN- Sewers and Drain Lines

Safety Manual

Appendix C-IBA Digging Protocol All I.B. Abel, Inc. (IBA) foreman and personnel should review and abide by the following protocol when performing excavation work. What to do prior to, during and in case of an incident for excavation work.

IBA Digging Protocol 1. 811 calls a. 3-10 days in advance i. Mark out area in white ii. Photo/Video of marks prior to digging iii. Survey area to check for discrepancies and tell tales 1. Manholes, valves, pedestals 2. Call for re-mark if they exist iv. Recall if marks are damaged or illegible or every 10 days b. When digging in or around a substation, on PPL property, give 5 days’ advance. i. Under “Type of Work” state: “substation excavation work”. ii. Also note the substation name under “Subdivision” iii. Then look out for your One Call response. 2. Trenching/excavating a. 811 call ticket start date must be adhered to b. Considered potentially hazardous until determined otherwise i. Combustible Gas Indicator (CGI) use 1. LEL - Acceptable levels are less than10% 2. CO - Acceptable levels are less than 35 ppm 3. O2 - Acceptable levels are between 19.5% and 23.5% 4. H2S - Acceptable Levels are less than 10 ppm c. If Alarm sounds clear trench and ventilate as necessary i. If alarm continues with ventilation stop and call Safety personnel 3. Prudent techniques a. Hand dig to reveal facility b. Hand dig to 18” tolerance zone on both sides of mark (no mechanical devices) i. If no line is uncovered continue to the desired depth maintaining tolerance zone ii. If a line is uncovered tolerance zone is then measured by outer width of the line

Safety Manual

iii. If trenching parallel to a marked line, test pit at pre-determined intervals to eliminate crossing of intended trench 4. Protect or secure any uncovered facility in trench a. Contact facility owner if unsure of procedure 5. Backfill protection of uncovered facilities a. Contact facility owner if unsure of procedure 6. Gas Strike a. Any contact with gas line/tracer wire i. Shut down equipment and clear area – if it can be done safely 1. Abandon equipment and move to a “safe distance”. b. Call 911 (state law) i. Inform the property owner of hazard and assist in their evacuation. DO NOT RING DOOR BELL! c. Call facility owner/811 d. Avoid open flames and remove all ignition sources e. Contact Safety personnel, GF and Construction Supervisors f. Do not attempt to repair or operate gas line valves g. Do not attempt to put out any open fires, allow to burn 7. Electrical Strike a. Any contact with electric line including overhead i. Shut down equipment remain in seat and clear area b. Call 911 c. Call facility owner/811 or System Operators d. Contact Safety personnel, GF and Construction Supervisors 8. All other facilities a. Damage to Potable water line, Reclaimed water/slurry, Sewer, Communication i. Call 911 (if traffic/property is at risk) ii. Call facility owner/811 iii. Contact Safety personnel, GF and Construction Supervisors.

Safety Manual

Tower Climbing and Erection

1. Tower Inspections a. All structures to be climbed must be inspected per the guidelines outlined in EIA/TIA-222-F Annex E: Tower Maintenance and Inspection Procedures. b. New structures shall be inspected initially. Guyed towers should be inspected within three years; self-supporting towers should be inspected within five years. c. If a tower owner has not kept current inspection and maintenance information on a tower to be climbed; the Project Manager shall make arrangements for prompt inspection by an experienced, competent inspector. d. These initial and periodic inspections do not replace the daily pre-climb inspections required by this policy. 2. Competent Tower Climbers a. Only authorized Competent Tower Climbers may perform work at elevated heights. b. Authorized Tower Climbers must successfully complete a tower climbing course and participate in annual tower rescue drills. 1. The tower climbing course will be based on the Tower Climbing Safety and Rescue Basic Course provided by ComTrain LLC, or an equivalent. 3. No Free Climbing Policy a. I. B. Abel adheres to a strict No Free Climbing policy. All work on towers will be done utilizing 100% fall protection techniques. b. Any climber not in compliance with this policy will be subject to disciplinary action up to and including removal from the project. 4. Climbing Equipment a. All fall protection equipment must meet the latest revision of ANSI Z359. b. Each climber will be outfitted with a full body harness, twin leg lanyard, safety, safe climb attachment device, rope grabs, descenders, and any other equipment necessary for fall protection, positioning, controlled descent and rescue. c. All climbing equipment will be visually inspected before each use. Damaged or defective equipment will be immediately destroyed or tagged out of service. d. Equipment will be inspected by a competent person, other than the user, at least annually. 5. Prior to Climbing a. Inspect the tower from the ground for hazardous conditions. Using binoculars, check for obvious structural damage, missing members, corrosion, birds’ nests, insects, ice, etc. b. Inspect the safety climb device, if equipped, and steps, pegs, and rungs for damage.

Safety Manual

c. Determine the possible exposure to RF radiation near or in front of any antennae. d. Identify any other nearby hazards such as power lines, buildings, other towers, etc. e. Each crew is to hold a pre-climb safety meeting daily. See attached Daily Meeting form f. Any tower that is deemed unsafe to climb shall immediately be brought to the attention of the Project Engineer and/or the Safety Department. 6. Climbing a. Two Competent Tower Climbers are required on any project during any climbing activity. b. Climbers are to maintain three points of contact when climbing or moving on the structure. c. One-hundred percent attachment is required when climbing, moving, or working on any structure. d. Anchorage points must be capable of supporting 5000 pounds or two times the anticipated impact load of a worker falling six feet. a. Anchoring to tower legs at joints and connections is the preferred anchorage point. b. Anchoring to lattice members with one bolted connection should be avoided. Lattice members with two or more bolted connections is preferred. c. Attachment to diagonal members should be avoided. d. Padded lanyards or cables should be used when anchorage points have sharp edges. e. A personal RF Monitor must be worn when climbing any structure with active transmitters. 7. Crew Requirements e. Only crews with the necessary skills and experience may erect, dismantle, or rig towers. Apprentices and other inexperienced personnel must work under the close supervision of an experienced crew member. 8. Planning a. Contractors are responsible for the means, methods, techniques, and procedures for their work. b. Obtain and review tower erection drawings, and any installation or erection manuals. c. Verify that the foundation has been built to specifications and is capable of supporting construction loads. d. Determine whether any of the erection can be done on the ground to minimize work at elevation. e. Ensure that all tower components have been delivered in good condition. f. Make sure any cranes used have a current annual inspection and a satisfactory daily inspection by a competent person.

Safety Manual

g. Select the appropriate means of accessing the tower. Consider the use of man baskets or aerial lifts for very high towers. 9. Erecting Towers a. Perform as much assembly on the ground as possible to minimize fall hazards. b. Install climbing pegs and ladder sections while the pieces are on the ground. c. Double check that all bolting has been installed and tightened to specifications. Use only structural bolts supplied with the tower. Contact the manufacturer immediately about any missing hardware or components. d. Install temporary fall protection and descent lines on the tower sections on the ground where practical. e. Install the permanent safety climb device, if equipped, as soon as possible. f. Use tag lines when picking tower components. g. Do not attach any components to the tower that interfere with the climbing ladder or step bolts. h. Any welding, drilling, or cutting not specified on the drawings must be approved by the project engineer. Repair any damaged galvanized surfaces.

Safety Manual

Fall Protection

1. Scope. This section outlines the requirements for work performed at heights apart from scaffold erection, which is covered under the scaffold section 2. Fall protection requirements a. An accident investigation will be performed in the event of a fall, near miss or other serious incident. b. All site-specific plans are developed by a qualified person. c. Employees are trained in fall protection and qualified in body positioning techniques on an annual basis. I.B. Abel, Inc. (IBA) utilizes the Buckingham’s “Bucksqueeze” training curriculum regarding climbing techniques and pole top rescue. d. Re-training shall be provided when the following are noted: i. Deficiencies in training ii. Workplace changes iii. Fall protection system or equipment changes that render previous training obsolete. e. Unprotected sides or edges. Employees on walking/working surfaces (horizontal and vertical surfaces) with an unprotected side or edge which is six feet or more above a lower level shall be protected from falling by the use of guardrails, safety net systems, or personal fall arrest systems. f. Hoist areas. Employees shall be protected from falling six or more feet to lower levels by use of guardrail systems or personal fall arrest systems. If a guardrail system must be removed to facilitate landing material from the hoist, and employees are required to lean out over the opening, personal fall arrest systems shall be used. g. Holes. Employees on walking/working surfaces shall be protected from falling through holes (including skylights) more than six feet to a lower level by the use of covers, guardrail systems or personal fall arrest systems. h. Ramps, runways, and other walkways. Employees on ramps, runways and other walkways shall be protected from falling more than six feet to a lower level by the use of guardrail systems. i. Wall openings. Employees working at, above or near wall openings with an outside bottom edge greater than six feet from a lower level and the inside lower edge less than thirty-nine inches high shall be protected by guardrail systems, safety net systems or personal fall arrest systems. j. Excavations. Each employee at the edge of an excavation six feet or more in depth shall be protected from falling by guardrail systems, fences,

Safety Manual

or barricades when the excavations are not readily seen because of plant growth or other visual barrier. k. Roofing work on low slope roofs (less than or equal to a 4 in 12 pitch). Employees engaged in roofing activities on low slope roofs, with unprotected sides and edges six feet or more above lower levels shall be protected from falling by guardrail systems, safety net systems, personal fall arrest system, or a warning line and safety monitoring system. l. On low slope roofs fifty feet or less in width, the use of a safety monitor alone is permitted without perimeter warning lines. m. Walking/working surfaces not otherwise addressed. Employees on any other walking or working surface with a fall potential of greater than six feet shall be protected by guardrail systems, safety net systems or personal fall arrest systems. 3. Positioning Devices Positioning device systems and their use shall conform to the following provisions: a. Positioning devices shall be rigged such that an employee cannot free fall more than 2 feet. b. Positioning device systems shall be inspected prior to each use for wear, damage, and other deterioration, and defective components shall be removed from service. c. The use of non-locking snap hooks shall be prohibited after January 1, 1998. d. Anchorage points for positioning device systems shall be capable of supporting two times the intended load or 3,000 pounds, whichever is greater. 4. Protection from falling objects. When employees are exposed to falling objects, they shall be protected by one of the following methods in addition to wearing ANSI Z89.1 certified hard hats: a. Toe boards and screens shall be used in conjunction with standard guardrail systems to prevent objects from falling from higher levels. b. Potential fall objects shall be kept far enough away from the edge of the higher level so that in the event of accidental displacement they would not fall to a lower level. c. Areas below higher levels where objects may reasonably be expected to fall shall be barricaded to prevent employees and other personnel from entering these areas. 5. Fall protection systems criteria.

Safety Manual

a. Utilized fall protection equipment will meet the requirements of applicable ANSI, ASTM, or OSHA requirements. b. In the event of a fall, prompt rescue of IBA employees will be performed. c. Guardrail systems i. The top edge height of the guardrail system shall be 42 inches plus or minus three inches (39-45 inches). ii. Mid-rails shall be installed midway between the top rail and the walking working surface. iii. Screens and mesh, when used shall extend from the top rail to the walking/working surface and along the entire length of the guardrail. iv. Guardrail systems shall be designed to withstand a force of 200 pounds applied within two inches of the top rail in a downward or sideways direction. The top rail shall not deflect to a height of less than 39 inches when the force is applied in a downward direction. v. Guardrail systems shall be designed to withstand a force of 150 pounds applied in a downward or sideways direction along any point of the mid-rail. vi. Top-rails and mid-rails shall be at least one-quarter inch nominal thickness or diameter to prevent cuts or lacerations. If wire rope is used for top rails it shall be flagged at six-foot intervals with high visibility material such as caution or danger tape. d. Safety net systems. i. Safety nets shall be installed as close as possible to the walking/working surface and in no case shall they be more than thirty feet below the working surface. ii. Safety nets shall be installed with sufficient clearance beneath them to prevent contact with any surfaces or structures below when subjected to an impact force equal to that of the drop test specified below. iii. Safety nets shall be drop tested upon initial installation in accordance with 29CFR1926.502(c)(4). iv. Safety nets shall be inspected at least weekly for wear, damage, and other deterioration. v. Materials, scrap pieces, equipment, and tools which have fallen into the net shall be removed as soon as possible. e. Personal fall arrest systems. i. Personal fall arrest systems shall consist of a full body harness, lanyard/double legged retractable and an approved anchorage point Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 155 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

ii. The anchorage point must be capable of supporting at least five thousand pounds or two times the weight of any force imposed on it. iii. Lanyards shall be attached to the full body harness at the center of the wearer’s shoulder blades. iv. Lanyards shall be rigged to prevent the wearer from falling more than six feet or striking a lower level. v. Harnesses, lanyards, lifelines, and other fall protection devices shall not be used for any purpose other than fall protection. vi. Personal fall arrest systems subjected to impact loading shall be removed from service until it has been inspected by a competent person and determined to be free from damage. f. Warning Line Systems. i. The warning line shall be erected around all sides of the roof work area. ii. The warning line shall be erected in from all edges of the roof the following distances: (low sloped roofs only) 1. Six (6) feet for all roofing work 2. Ten (10) feet if mechanical equipment is used for roofing work 3. Fifteen (15) feet for all other work iii. Warning lines shall consist of ropes, chains, or wire and be erected as follows: 1. The line shall be flagged at six-foot intervals with high visibility material 2. Stanchions shall hold the line between thirty-four and thirty-nine inches high (including sag). 3. The line shall be attached to each stanchion so that pulling on one section of the line does not result in taking slack out of another section. 4. The stanchions must be sturdy enough to resist a sixteen- pound tipping force applied at the top of the stanchion after the line has been erected. g. Safety Monitoring System. Safety monitoring systems and their use shall comply with the following provisions: i. The Safety Monitoring System shall only be used when approved by the Safety Department ii. A competent person shall be designated to monitor the safety of employees on the roof.

Safety Manual

iii. The monitor is responsible for warning other employees when they seem unaware of fall hazards or are acting in an unsafe manner. iv. The monitor must be on the same walking/working surface as the employees being monitored. v. The monitor shall be within visual distance and close enough to communicate with employees. vi. The safety monitor can perform no other duties which could take the monitor’s attention from the monitoring function. h. Covers. Covers for holes larger than 2 inches in floors, roofs, and other walking/working surfaces shall meet the following requirements: i. Covers must be capable of supporting at least two times the weight of any employees, materials, or equipment that may be imposed on them. ii. Covers must be secured against displacement by wind, equipment, or employees. iii. Covers must be labeled “Hole” or “Cover”

Safety Manual

Fire Protection and Prevention

1. Portable Fire Fighting Equipment a. For every 3000 square feet of protected building there must be one fire extinguisher rated at least 2A. b. For multistoried buildings there must be at least one fire extinguisher rated at least 2A on each floor. i. There shall be one fire extinguisher located at every stairway used for emergency egress. c. Wherever 5 gallons of flammable or combustible liquids or 5 pounds of flammable gas is being used there must be a fire extinguisher rated at least 10B within 50 feet. d. Fire extinguishers must be conspicuously located and easily accessible. e. Fire extinguishers shall be visually inspected monthly and maintained in operating condition and subjected to an annual maintenance check. i. Inspection of extinguishers shall include: 1. Check for accessibility. 2. Check nozzle or horn for obstructions or damage. 3. Examine for corrosion. 4. Check for pin and tamper seal. 5. Check fullness (pressure gauge, water level or weight). 6. Check annual inspection tag. f. The inspector should initial the appropriate month on the tag after inspecting the extinguisher. g. Any extinguishers not passing inspection should be removed from service and replaced promptly. h. Every office trailer shall be equipped with at least one fire extinguisher. i. Every tool trailer shall be equipped with at least one fire extinguisher. i. Trailers with swing doors shall have the fire extinguisher mounted on the inside of the door. ii. Trailers with roll-up doors shall have the fire extinguisher mounted on the inside wall, so when opened, it is readily accessible. j. Operation of Extinguishers. All employees should receive training on the use and limitations of different types of fire extinguishers. k. Extinguisher operation training shall be conducted prior to initial assignment and at least annually thereafter 2. Fire Alarm Devices

Safety Manual

a. An alarm system shall be established to notify employees and local fire officials of an emergency (telephone system, siren, etc.) b. Entrances and phones shall conspicuously post emergency number and reporting instructions. 3. Ignition Hazards a. Internal combustion engines shall have their exhaust pointed well away from combustible material. b. Smoking is prohibited in areas that constitute a fire hazard and shall be posted “No Smoking or Open Flame.” 4. Flammable and Combustible Liquids a. Only approved containers and portable tanks shall be used for the storage and handling of flammable and combustible liquids. i. Approved safety cans or DOT approved containers shall be used for the handling and storage of 5 gallons or less of any flammable liquid (highly viscid liquids are exempt). b. Flammable and combustible liquids shall not be stored in any area used for normal passage of employees. 5. Indoor storage of Flammable and Combustible Liquids a. When in excess of 25 gallons, storage outside of approved storage cabinets is prohibited. i. Only approved metal storage cabinets shall be used. ii. Cabinets shall be conspicuously labeled “Flammable-Keep Fire Away.” b. Storage of more than 60 gallons of flammable or 120 gallons of combustible liquids is prohibited within any one-storage cabinet. 6. Fire Control for Flammable or Combustible Liquid Storage a. Any room used for storage of more than 60 gallons of flammable or combustible liquids shall have a fire extinguisher, with a rating above 20B, not more than 10 feet outside of door. b. Any storage of flammable liquids outside must have a fire extinguisher, with a rating above 20B, not less than 25 feet and no more than 75 feet from the storage area. c. All tank trucks used for transporting flammable or combustible liquids must have at least one fire extinguisher, with a rating not less than 20B:C, provided on the truck. 7. Liquefied Petroleum (LP) Gas a. Welding on LPG containers is prohibited.

Safety Manual

b. Temporary heaters should be located at least 6 feet away from LPG containers. c. Blowers and Radiant type heaters shall not be directed toward any LPG container within 20 feet. d. Storage i. Storage of LPG containers inside building is prohibited. ii. Storage of LPG containers outside building as follows: 1. 500 lbs. or less 0 feet from building 2. 501 to 6,000 lbs. 10 feet from building 3. 6,001 to 10,000 lbs. 20 feet from building 4. Over 10,000 lbs. 25 feet from building iii. Storage location of LPG must have at least one approved fire extinguisher having a rating of not less than 20-B:C. 8. Service and Refueling Areas a. Fueling areas should be located at least 25 feet away from other operations. b. Flammable or combustible liquids shall be stored in approved aboveground portable tanks. c. Fuel tanks must be protected against collision damage. d. Signs shall be conspicuously placed prohibiting smoking and open flames. e. All motors shall be shut off during fueling. f. Each area shall have at least one fire extinguisher, with a rating of at least 20B:C, located within 75 feet of each service and fueling area. g. Drainage: Drainage areas shall terminate in a vacant area, so if the liquid were to ignite it would not further expose any tanks or adjoining property. h. Dikes must be capable of holding the greatest volume of the largest tank, as if it were full, in the diked area. 9. Miscellaneous a. All trash shall be removed at the end of each workday. b. Trash barrels shall be placed around the site to help contain possible trash fires.

Safety Manual

Fire Extinguisher Ratings

Size and Type UL Rating

2-1/2 Gallon Pressurized Water Extinguisher 2A

2-1/2 Lb. ABC Dry Chemical Extinguisher 1A: 10 B:C

5 Lb. ABC Dry Chemical Extinguisher 2A: 10 B:C

10 Lb. ABC Dry Chemical Extinguisher 4A: 80 B:C

20 Lb. ABC Dry Chemical Extinguisher 10A: 120 B:C

5 Lb. Carbon Dioxide (CO2) Extinguisher 5 B:C

10 Lb. Carbon Dioxide (CO2) Extinguisher 10 B:C

Note: UL Ratings may be different with different Manufacturers and Models.

Safety Manual

Hand and Power Tools

1. General. a. All tools, whether supplied by I.B. Abel, Inc. (IBA), or an employee’s personal tools, must be maintained in a safe condition. b. Power tools equipped with guards must only be used with the guards in place. c. Appropriate PPE must be used when power tools prevent hazards from falling, flying, abrasive, or splashing objects, or harmful dusts, mists, fumes, vapors, or gases. d. Any tools which are found to be defective or unsafe must be reported to your supervisor and taken out of service. e. Use the proper tool for the job. 2. Hand Tools. a. Wrenches shall not be used when the jaws are sprung to the point that slippage occurs. b. Impact tools such as drift pins, wedges, and chisels shall be kept free of mushroomed heads. c. Wooden handles shall be free of splinters and cracks and shall be tight in the tool. 3. Power Tools. a. Electric Tools. i. Electric power tools shall either be double insulated or grounded. ii. Tools shall not be unplugged, hoisted, or lowered by their cords. iii. Tools shall be unplugged from the power source when they are not being used, changing bits, or servicing the tool. iv. When not in use they should be stored in a dry place. b. Pedestal Grinder i. Must be anchored to the floor. ii. Wheel guard must be adjusted to within 1/4”. iii. Work rest must be adjusted to within 1/8”. c. Pneumatic Power Tools. i. Pneumatic power tools and all airline couplings shall be secured together to prevent them from becoming disconnected. ii. Compressed air shall not be used for cleaning unless reduced to less than 30 psi. Concrete forms may be cleaned with compressed air above this pressure when appropriate eye and face protection are used. iii. Air guns shall never be pointed toward or dead-ended against or towards another individual Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 162 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

d. Fuel Powered Tools. i. Fuel powered tools must be shut off when refueling. ii. Fuel powered tools shall not be used in enclosed spaces unless adequate ventilation is supplied. e. Powder-Actuated Tools. i. Only licensed operators shall use powder-actuated tools. ii. Powder-Actuated tools shall be tested, used and maintained in accordance with the manufacturer’s recommended procedure. iii. Loaded tools must be used immediately and never left unattended. iv. In the event of a misfire follow these steps: 1. Wait 30 seconds then try firing again 2. If it still does not fire, wait an additional 30 seconds before carefully removing the cartridge. 4. Tool guards and safety switches. a. All guards and safety switches must be installed and in proper working order. b. Guards shall be provided to protect the operator from: i. Point of operation ii. In-running nip points iii. Rotating parts iv. Flying chips and sparks Momentary contact “on-off” switches must be provided on the following hand held-drills, tappers, fastener drivers, grinders, disc and belt sanders, reciprocating saws, saber saws, and other similar tools.

Safety Manual

Heavy Equipment

1. General Requirements a. Daily/Shift inspections and tests i. All machinery and equipment should be inspected before use to ensure safe operating procedures. ii. Tests shall be performed to ensure that brakes and all other operational systems are in proper working order. iii. Whenever machinery or equipment is found to have any major deficiencies, it shall be tagged out of service immediately. 1. Tags shall be placed in a conspicuous location and shall indicate that the equipment shall not be used. Tags shall only be removed by the person completing the repairs and only after the repairs are completed (refer to the lockout/tagout section of this handbook). b. Only qualified individuals shall operate any machinery or equipment. c. Equipment and machinery shall not be operated in a manner that will endanger persons or property, nor shall the operating speeds or loads be exceeded. d. Climb into or out of equipment only using provisions provided by the manufacturer, i.e. Steps, rungs and hand holds provided on the machine. Do not jump out of the cab. Accessing or exiting any piece of moving equipment is prohibited. e. Use of mobile phones, headphones, or similar items is strictly prohibited while operating machinery or equipment. 2. Equipment Requirements a. Equipment is only designed to carry as many passengers as there are belted seats. i. Seat belts are required while operating or moving equipment. ii. Mobile equipment to be driven on public roadways shall be properly registered and tagged. 1. Lights shall be in good working order. 2. Warning systems, alarms, and horns shall be in good working order. 3. Orange safety triangle shall be displayed on the rear of equipment. 4. Unregistered (non-plated) equipment must stay within a one-mile radius of the jobsite.

Safety Manual

b. Maintenance and repairs shall only be performed while the equipment is shut off, unless specifically designed for lubricating while the engine is running. c. Equipment shall have all blades, buckets, dump bodies or similar equipment fully lowered or blocked when not being used. d. Heavy Equipment operating close to overhead power lines shall be protected from contact with the energized lines by one of the following methods: i. The lines shall be de-energized and grounded, or ii. Barriers, not a part of the machine shall be erected to prevent contact, or iii. A minimum safe distance of ten feet shall be maintained around all overhead power lines. For lines exceeding 50 kV, a distance of four inches for every additional 10kV shall be added. e. Internal combustion engines shall not be run within an enclosed building unless adequate ventilation controls are in place to ensure hazardous atmospheres are not being created. f. Parking i. All parked equipment shall have the parking brake set and wheels chocked. ii. Equipment parked overnight where there is access to the general public shall be locked, keys removed, and area coned off. Equipment left adjacent to roadways shall have lights or reflectors that are visible to passing motorists. g. Modifications that affect the unit’s capacities or safe operations shall not be made unless written approval is given by the manufacturer, and proper tags are placed on the unit. 3. Safety Devices a. All vehicles shall be equipped with an audible warning device accessible from the operator’s station. b. No equipment having an obstructed view to the rear shall be used unless: i. It is equipped with an audible reverse signal that is distinguishable from surrounding noises or: ii. The equipment is only back under the direct signaling of a specified spotter. c. Equipment being used in clearing and demolition operations shall be protected by guards, canopies or grills. 4. Heavy Equipment Use Around Energized Facilities a. Hydrovac policy –

Safety Manual

i. All crew members shall wear dielectric overshoes and rubber insulating gloves. The hydrovac is required to be grounded and a spotter used whenever digging with the equipment: 1. Closer than 10 feet from equipment energized up to 50KV. 2. When a known electrical hazard is present such as exposing underground electrical facilities, ii. Barricading must be used around the equipment and all employees informed of the hazard(s). Additional PPE includes face shields and hearing protection shall be used. b. Pulling Equipment – Wire pulling equipment will be bonded and grounded to eliminate differences in potential between equipment and operators. This will be accomplished by bonding equipment and using ground mats for employees standing on the ground while operating pulling and tensioning equipment. The work area will be barricaded. Rubber gloves and dielectric overshoes will be worn by all employees in the barricaded wire pull area. c. Barricading – aerial equipment that is operated inside the MAD for unqualified employees should be grounded or barricaded. There should be no contact with an aerial device carrier while the boom is in the MAD zone. i. Transmission voltages, 10 feet to 50 KV plus additional 4 inches for every 10 KV above 50 KV ii. Distribution voltages to 50 KV will be within 10 feet d. PPE i. Rubber gloves and overshoes shall be worn when contacting any vehicle that has a boom in the energized zone. ii.Rubber gloves, sleeves and overshoes will be worn while handling any pole being set in an energized zone.

Safety Manual

Load Securement

1. Legal Requirements a. Equipment < 10,000 lbs. with no hydraulic accessories (boom or loader) i. (2) Tie Downs (front and rear) 1. Example: Scissor Lift b. Equipment > 10,000 lbs. with no hydraulic accessories (boom or loader) i. (4) Tie Downs (1 at each corner) 1. Example: Loader Backhoe c. Each hydraulic accessory requires a separate tie down (boom or loader) d. All tie downs must equal 50% of the weight of the equipment being transported. 2. Safety and standardization requirements: a. All equipment being transported require: i. (4) Tie Downs (1 at each corner) ii. Each hydraulic accessory requires a separate tie down (boom or loader) iii. All tie downs must equal 50% of the weight of the equipment being transported.

Safety Manual

Housekeeping – Material Storage

1. General Requirements a. All materials stored in tiers shall be stored in a manner to prevent sliding, falling, or collapse. b. Aisles and passageways shall be kept clear to provide safe and adequate movement of materials and employees for general and emergency passage. 2. Material Storage a. Materials shall not be stored within 6 feet of any interior floor opening or within 10 feet of any exterior opening unless a barrier capable of supporting the weight of the materials and at least equally as high as the pile is provided. b. Materials shall not be stored on scaffolds or runways that are in excess of what is needed for the immediate operation. c. Light or loose materials shall not be stored on rooftops or floors unless they are adequately secured or enclosed by a wall. d. All stairways and ladder areas shall be kept clear of debris. e. Lumber shall have all protruding nails removed, hammered in, or bent flush with the wood face. f. Stacking of materials shall be as follows: i. Brick stacks shall not exceed 7 feet in height or 4 feet for loose brick unless a taper of at least 2 inches in every foot is provided above 4 feet. ii. Masonry block stacks shall not exceed 6 feet unless a one half- block taper is provided for every tier above 6 feet. g. Propane shall not be stored within an enclosed building. 3. Housekeeping a. Job sites and company property shall be kept in a clean orderly fashion i. Accumulation of waste materials shall be removed from the site daily and put in proper containers. ii. Dumpsters should not be overloaded (avoid compacting a full dumpster with equipment to prevent damage). b. Job site toilets shall be cleaned on a routine basis. c. Office trailers and vehicles shall be maintained in a clean orderly fashion to promote the company image. 4. Disposal of waste materials a. Materials that are being dropped 20 feet or more shall be contained with an enclosed debris chute.

Safety Manual

b. When debris is dropped to a lower level, the landing area shall be adequately taped off with danger tape and signs shall be posted. c. Disposal of waste materials by burning shall be properly permitted and shall follow all local fire regulations. d. All oily rags and flammable liquids shall be stored in proper fire-resistant containers until removed from the job site. e. All project waste, trash, and/or scrap materials will be taken into consideration before work begins. f. Employees will be made aware of the proper method to dispose of wastes. g. Employees shall use proper handling, organization, and storage of waste and scrap materials to ensure minimal potential impact to the environment. h. Waste will be divided accordingly for proper elimination, to ensure opportunities for reuse or recycling and as per customer requests.

Safety Manual

Lock Out/Tag Out

1. Scope. This program covers the servicing or maintenance of machines, equipment, or conductors in which the unexpected energization, or startup of the machines, or equipment or release of stored energy, could cause injury to employees. This program establishes minimum performance requirements for the control of such hazardous energy. This section does not apply to work on cord and plug connected electric equipment for which exposure to the hazards of unexpected energization or startup of the equipment is controlled by the unplugging of the equipment from the energy source and by the plug being under the exclusive control of the employee performing the servicing or maintenance. 2. Definitions a. Affected employee. An employee whose job requires him/her to operate or use a machine, equipment, or conductor on which servicing, or maintenance is being performed under lockout or tagout, or whose job requires him/her to work in an area in which such servicing, or maintenance is being performed. b. Authorized employee. A person who locks or tags machines, equipment, or conductors in order to perform servicing, or maintenance on that machine, equipment, or conductor. An affected employee becomes an authorized employee when that employee’s duties include servicing or maintenance covered under this program. c. Energized. Connected to an energy source or containing residual or stored energy. d. Energy Source. Any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy. e. Lockout. The placement of a lockout device on an energy isolating device, in accordance with an established procedure, ensuring that the energy isolating device and the equipment being controlled cannot be operated until the lockout device is removed. f. Servicing and/or Maintenance. Workplace activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines and equipment. g. Periodic inspection of the energy control procedure shall be conducted and documented at least annually to ensure procedures and requirements are being followed.

Safety Manual

h. Retraining will be required when there is change in job assignments, in machines, a change in the energy control procedures, or a new hazard is introduced. i. Tagout. The placement of a tagout device on an energy isolating device, in accordance with an established procedure, to indicate that the energy isolating device and the equipment being controlled may not be operated until the tagout device is removed. 3. Lockout/Tagout Procedures a. Employees shall ensure that the following procedures for the application of energy control devices have been followed: i. Preparation for shutdown. Before an authorized or affected employee turns off a machine or equipment, the authorized employee shall have knowledge of the type and magnitude of the energy, the hazards of the energy to be controlled, and the method or means to control the energy. ii. Machine, equipment, or conductor shutdown. The machine or equipment shall be turned off or shut down using the procedures established for the machine, equipment, or conductor. An orderly shutdown must be utilized to avoid any additional or increased hazard(s) to employees as a result of the equipment stoppage. iii. Machine, equipment, or conductor isolation. All energy isolating devices that are needed to control the energy to the machine, equipment, or conductor shall be physically located and operated in such a manner to isolate the machine or equipment from the energy source(s). iv. Lockout or tagout device application 1. Authorized employees shall affix lockout or tagout devices to each energy isolating device. a. Group lockout procedures may be when employees are afforded the same level of protection by that of a personal lockout device. 2. Lockout devices, where used, shall be affixed in a manner that will hold the energy isolating device in a safe or off position. 3. Tagout devices, where used, shall be affixed in such a manner as will clearly indicate that the operation or movement of energy isolating devices from the off or safe position is prohibited Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 171 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

4. Where tagout devices are used with energy isolating devices designed with the capability of being locked, the tag attachment shall be fastened at the same point the lock would have been attached. 5. Where a tag cannot be affixed directly to the energy isolating device, the tag shall be located as close as safely possible to the device, in a position that will be immediately obvious to anyone attempting to operate the device. v. Stored energy 1. Following the application of the lockout or tagout devices to energy isolating devices, all potentially hazardous energy stored, or residual energy shall be relieved, disconnected, restrained, and otherwise rendered safe. 2. If there is a possibility of re-accumulation of stored energy to a hazardous level, verification of isolation shall be continued until the servicing or maintenance is completed, or until the possibility of such accumulation no longer exists. vi. Verification of isolation. Before starting work on machines or equipment that have been locked out or tagged out, the authorized employee shall verify that isolation and de-energization of the machine or equipment have been accomplished. The authorized employee shall test for potential energy before any work is performed. 4. Release from lockout or tagout. Before lockout or tagout devices are removed and energy is restored to the machine, equipment, or conductor procedures shall be followed and actions taken by the authorized employee(s) to ensure the following: a. The machine, equipment, or conductor. The work area shall be inspected to ensure that nonessential items have been removed and to ensure that machine or equipment components are operationally intact. Conductors that are being abandoned but not yet removed shall be positively identified and shorted on both ends prior to removal of lockout or tagout devices b. Employees. The work area shall be checked to ensure that all employees have been safely positioned or removed. Affected employees shall be notified that the lockout or tagout devices are being removed both before and after machines or equipment are energized. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 172 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

c. Lockout and Tagout Devices. The employee who applied the device shall remove each lockout or tagout device. In situations when that employee is unavailable, the device may be removed by the employee’s supervisor if the following procedures are followed: i. It is verified that the employee who applied the device is not at the facility. ii. The employee is notified that their device has been removed. iii. It is ensured that the employee has knowledge that their device has been removed before he/she returns to work at that facility. 5. Special Requirements a. Testing or positioning of machines, equipment, or conductors. In situations in which lockout or tagout devices must be temporarily removed from the energy isolating device and the machine, equipment, or conductor energized to test or position the machine, equipment, or component thereof, the following procedures shall be followed: i. Clear the machine or equipment of tools, isolate and barricade cable ends for cable testing. ii. Remove employees from the machine or equipment iii. Remove the lockout or tagout devices iv. Energize and proceed with testing or positioning. v. De-energize all systems and reapply energy control measures in accordance with Section III.B of this program to continue the servicing and/or maintenance. 6. Training. a. Each authorized employee shall receive training in: i. The recognition of the hazardous energy sources of each type of equipment or machinery ii. The type and magnitude of the energy sources to be locked out, and iii. The method for locking and tagging each piece of equipment or machinery. iv. Employees shall be trained that removing another employee’s lock or tag is strictly prohibited.

Safety Manual

Mine Safety

1. Scope. This section applies to all work conducted on mine properties. These rules are specific to work on mine properties and are in addition to the other construction safety and health rules found in this handbook. When working on any mine site, all individuals must adhere to the requirements set forth in 30 CFR of the Mine Safety and Health Administration. 2. Training Requirements a. All employees working on Surface Metal/Non-Metal mine sites are required to have training meeting the requirements of 30 CFR Part 46. i. New Miner Training. New miner training consists of twenty-four hours of classroom training. 1. Before a new miner begins work on a mine site at least four hours of training are required. Required topics are listed in the IBA, Inc. Part 46 Training Plan. These topics are covered in the new hire orientation. 2. Training on additional topics, including first aid, is required within sixty calendar days after starting work. 3. The remainder of the twenty-four hours of training must be completed within ninety calendar days of hire. ii. Annual Refresher Training. Eight hours of annual refresher training are required for each miner. iii. Site Specific Hazard Training. Each mine operator is responsible for providing Site Specific Hazard Training to all employees working on the site. Hazard Training should be completed before working at each new mine site. b. All employees working on the Surface of Metal/Non-Metal mine sites with Underground operations are required to have training meeting the requirements of 30 CFR Part 48 Subpart B. i. New Miner Training. New miner training consists of twenty-four hours of classroom training. 1. Required topics are listed in the IBA, Inc. Part 48 Subpart B Training Plan ii. Annual Refresher Training. Eight hours of annual refresher training are required for each miner. iii. Site Specific Hazard Training. Each mine operator is responsible for providing Site Specific Hazard Training to all employees

Safety Manual

working on the site. Hazard Training should be completed before working at each new mine site. c. All employees working in the Underground of Metal/Non-Metal mine sites are required to have training meeting the requirements of 30 CFR Part 48 Subpart A. i. New Miner Training. New miner training consists of Forty hours of classroom training. 1. Required topics are listed in the IBA Inc. Part 48 Subpart A Training Plan ii. Annual Refresher Training. Eight hours of annual refresher training are required for each miner. iii. Site Specific Hazard Training. Each mine operator is responsible for providing Site Specific Hazard Training to all employees working on the site. Hazard Training should be completed before working at each new mine site. d. Records of Training. Each employee receiving training required under part 46 should receive a Certificate of Training – MSHA Form 5000-23 3. Workplace Examinations. a. A competent person must conduct a daily workplace examination to identify hazardous conditions which may adversely affect safety or health. Hazardous conditions must be corrected promptly. b. Workplace examinations must be documented and retained. 4. Equipment Rules. a. Every piece of equipment must be inspected and written up every day. Defects must be corrected in a timely manner. b. Every mobile piece of equipment where fire could impede escape must have a fire extinguisher. c. Fire extinguishers must be inspected monthly. Inspection tags on extinguishers must be initialed after being inspected. d. Seat belts are mandatory on all equipment with a cab or ROPS structure. 5. Quarry Rules a. Berms must be maintained on roadways where a drop off exists of sufficient grade or depth to cause a vehicle to overturn. Berms must be mid-axle height of the largest machine using the roadway. b. Obey speed limits, stop signs, and traffic signs within the quarry. Many quarries have left hand traffic patterns. c. Always yield to haul trucks and other larger equipment. d. Follow all blasting procedures. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 175 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

i. Be aware of the blasting schedule and vacate blasting areas to a designated safe area when instructed. ii. Heed all blast warning signals. Wait for the all clear signal prior to resuming work. 6. Plant Areas. a. Any moving machine part within seven feet of a work surface must be guarded to prevent contact with gears, sprockets, chains, tail, head, and take-up pulleys, flywheels, couplings, shafts, and similar moving parts. b. Housekeeping. Keep all floors, walkways, catwalks, and work platforms free of spilled rock, dust, or other materials that could prevent safe passage.

Safety Manual

Railway Safety

1. Scope. These rules apply to any work on or near railroad tracks with the potential for fouling the track. 2. Definitions a. Flagman. An employee designated by the railroad to direct or restrict the movement of trains past set points on a track to provide on-track safety for roadway workers. b. Fouling a Track. When an individual or equipment is positioned so that they may be struck by a moving train or on-track equipment or is within 4 feet of the track. c. Job Briefing. A meeting to communicate the activities happening throughout the day while working on railway property. d. On-Track Protection. A way to prevent roadway workers from being struck by a moving train or other equipment. e. Place of Safety. A designated safe location at least thirty feet from the tracks for workers to retreat to when notified by a flagman or watchman. Workers must be able to get to the place of safety at least fifteen seconds before any train passes the work location. f. Train Approach Warning. A method of establishing on-track safety by warning roadway workers of the approach of trains in ample time for them to move to or remain in a place of safety in accordance with the requirements of this part. g. Watchman/Lookout. An employee who has been trained and qualified to provide warning to roadway workers of approaching trains or on-track equipment. h. Working Limits. A segment of track established in accordance with the railroad owner where trains and engines may move only as authorized by the flagman having control over that segment of track. 3. Training. Rail systems are controlled by the Federal Railroad Administration (FRA). The FRA mandates that rail system owners provide training to all workers on or near tracks with the potential to interfere with or be struck by railway traffic. Each railway has their own training requirements. a. Training shall include, at a minimum: i. Recognition of railroad tracks and understanding of the space around them within which on-track safety is required.

Safety Manual

ii. The functions and responsibilities of various persons involved with on-track safety procedures. iii. Proper compliance with on-track safety instructions given by persons performing or responsible for on-track safety functions. iv. Signals given by watchmen/lookouts, and the proper procedures upon receiving a train approach warning from a lookout. v. The hazards associated with working on or near railroad tracks, including review of on-track safety rules and procedures. 4. Job Briefing a. A job briefing must be held with all individuals on the project. Briefings must be held: i. Before work commences on railroad property each day ii. Whenever work conditions or activities have changed b. The following topics shall be covered: i. Who is responsible for On-Track protection? ii. Which type of On-Track protection is in use? iii. Is this protection appropriate? iv. Will other machines or personnel be involved? v. Which type of on track safety is provided on adjacent tracks? vi. Where is the designated place of safety? vii. What are the track limits? viii. When do these limits expire? ix. Where can I find a copy of the On-Track Protection rules? x. Do I understand all the aspects of my On-Track protection? 5. On-Track Protection. There are three types of on-track protection: Working Limits; Train Approach Warning; and Individual Train Detection. The method of On-Track Protection to be used is determined by the railway. a. Working Limits. i. A flagman creates set boundaries and time limits for the work. ii. Trains may only proceed within the boundaries after the flagman clears the tracks of contractors and equipment and signals the train through. iii. Working limits are used when occupying or fouling track with equipment iv. Only the flagman can set these boundaries v. Always obey the flagman. b. Train Approach Warning. Uses a watchman/lookout to warn of approaching trains. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 178 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

i. A watchman/lookout cannot do anything but monitor for trains and warn employees. ii. The watchman/lookout warns workers when a train is approaching to vacate tracks in time to a place of safety. iii. The watchman/lookout uses a whistle and white flag to warn employees. c. Individual Train Detection i. Used for lone worker ii. Relies on the conditions that the worker can see and hear an oncoming train iii. Must have visibility enough to leave the track in time iv. Cannot use power tools v. Must complete a Statement of On-Track Safety Form.

Safety Manual

Scaffolding and Aerial Lifts

1. Platform Construction a. Each working level must be fully planked or decked. b. Scaffold platforms must be within fourteen inches of the work surface. c. Eight-foot scaffold planks must extend over their support at least six inches but less than twelve inches unless secured to prevent movement. d. Sixteen-foot scaffold planks must extend over their support at least six inches but less than eighteen inches unless secured to prevent movement. e. Where planks are overlapped, the overlap must be a minimum of twelve inches and must occur over a support. f. Scaffold planks should not be painted or coated with anything to make them slippery or which could cover up defects such as cracks. 2. Supported Scaffolds a. Scaffolds must be built on a firm foundation. Scaffolds built on the ground require baseplates and mudsills. b. Unstable objects such as masonry blocks may not be used to support scaffolds c. Scaffolds frames must be plumb, and platforms must be level. d. Scaffolds over four times higher than their width must be secured to prevent tipping (usually three bucks high on a walk-through frame scaffold). i. Scaffolds must be secured at both ends and every thirty feet counting from one end. Scaffolds must be secured vertically every twenty feet thereafter. 3. Access. a. When scaffold platforms are more than two feet above or below a point of access, a ladder or some other safe means is required to access the scaffold. b. X-braces may not be used to access scaffolds. c. Walk-through frames may not be climbed as ladders to access the scaffold (Note: Laborers erecting and dismantling the scaffold may climb walk-through frames, but they may not climb the x-braces) 4. Fall Protection on Scaffolds a. Fall protection is required for any scaffold over six (6) feet high.

Safety Manual

b. Laborers erecting, or dismantling scaffolds may work at heights over six (6) feet without fall protection if a competent person determines that it is not feasible or creates a greater hazard to use fall protection. c. Guardrail Systems. The following requirements apply to guardrail systems used on scaffolds i. Guardrail systems are required on all open ends and sides of scaffolds. ii. The guardrail shall consist of a top rail thirty-eight to forty-five inches high and must be capable of supporting two hundred pounds. iii. The mid rail should be approximately midway between the top rail and the platform and must be capable of supporting one hundred- fifty pounds. iv. X-braces may be used in place of a mid-rail if the crossing point of the brace is between twenty and thirty inches high. X-braces may be used in place of a top rail if the crossing point of the brace is between thirty-eight and forty-eight inches high. The end points of the x-brace may not be more than forty-eight inches apart for it to count as a top rail or mid rail. d. Personal Fall Arrest Systems (Harnesses) i. Personal fall arrest systems used on scaffolds must comply with the Fall Protection section of this manual. ii. Harnesses should be connected to vertical lifelines, horizontal lifelines, or structural members. Connection to the scaffold components is not acceptable in most situations. 5. Falling Object Protection a. Toe boards are required on all platforms where work is being performed or material is stored. b. Platforms shall only be loaded with the materials needed for immediate use. c. Debris such as masonry pieces shall not be allowed to accumulate on scaffolds. 6. Use of Scaffolds. Use of scaffolds must comply to the following: a. Training. Required training must be conducted prior to initial assignment, prior to a change in assigned duties, and/or if special deviations have occurred for which an employee has not had previous training.

Safety Manual

i. Training of IBA employees will be conducted on topics including fall protection, electrical safety, falling object protection, scaffold use and load capacity. ii. Retraining will be required in the following situations: 1. When changes at the worksite present a hazard that an employee has not been previously trained. 2. Changes in types of scaffolding, fall protection, falling object protection or other equipment for which, an employee has not been previously trained. 3. When an employee does not demonstrate proficiency in a task that he/she has been previously trained on. b. Scaffolds must be erected, moved, dismantled or altered only under the supervision and direction of a competent person. c. Scaffolds must undergo a pre-shift inspection by a competent person, should there be defects found, scaffolds will be communicated by inspected tag. i. Green tag – No deficiencies. ii. Yellow tag – Additional fall protection required. iii. Red tag – Do not use/Under construction. d. Clearance between scaffolds and power lines shall be the same requirement as for cranes and other equipment (ten feet for power lines up to 50kV). e. Minimum clearance between electrical lines and any part of the equipment is at least 10 feet. f. No work may be performed from snow or ice-covered platforms (except for removal of the snow and ice). g. Makeshift devices such as boxes or buckets may not be used for additional reach on scaffolds. h. Ladders may not be used on scaffold platforms for additional reach (except on large area platforms). i. Scaffold frames must be secured together vertically with coupling pins or an equivalent. j. Outrigger brackets shall be used for personnel only. k. Scaffold casters must be locked when the scaffold is occupied. l. Mobile scaffolds may not be moved while occupied unless the floor is roughly level and free of pits, holes and obstructions; and the scaffold is no higher than two times it’s width. 7. Aerial Lifts

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a. Fall Protection. i. When operating extendable and or articulating boom platforms, personal fall arrest systems are required in addition to full guardrails. ii. When operating scissor type lift, full guardrails systems must be in place along with personal fall arrest systems. This will include the attachment of any safety chain or closure of doors to platform. (NOTE – manufacturers of platform lifts are now installing lanyard attachment points and recommending tying off in platform lifts. This is an MSHA requirement and may also be a customer requirement.) iii. When using PFAS in any lift, the lanyard must be attached to platforms installed attachment point. b. Tying off to structures other than the provided attachment points is not permitted. c. Lifts must be inspected daily prior to use. d. Only authorized employees should operate lifts. e. Employees must stand on the floor of the lift at all times. Standing on the rails or other objects to gain reach is not permitted. f. Weight capacities and personnel limits must not be exceeded. g. Lifts shall not be used for any purpose they were not designed for. Aerial lifts may be field modified for uses other than those intended by the manufacturer only if the modification is certified in writing by the manufacturer. h. Follow all other safety requirements found in the operator’s manual located on the unit. It is IBA’s policy to abide by all manufacturer recommendations. i. Whenever working aloft, workers shall identify the area directly underneath the aerial work zone including all potential drop areas. Cones, tape, rope, signs, or other approved devices shall be used to deter ground workers or the public from entering the aerial work zone. i. Scissor lifts and scaffolds do not require additional barricades. ii. All overhead line work requires the use of barricading while working aloft.

Safety Manual

Stairs and Ladders

1. General Requirements a. A stairway or ladder is required at any point of access where there is a break in elevation greater than nineteen inches and no ramp, runway, sloped embankment or other means of access is provided. b. Stairway, ladders and their landings must be kept clear at all times. c. If a stairway or ladder must be blocked, another means of access must first be provided. 2. Stairways a. Riser heights and tread depths must be uniform within each flight of stairs. b. Where doors or gates open onto a stairway, a landing must be provided. The landing must be at least 20 inches wider than the swing of the door. c. Metal pan stairs may not be used unless the treads are filled in permanently or temporarily. Temporary treads in pan stairs must be solid and fill the full width and length of the tread. d. Stair rails are required on any open side of a stairway having four or more risers or higher than thirty inches. A stair rail consists of a top rail and mid-rail. i. Stair rail height should be thirty-six inches measured from the front of the tread. ii. Mid-rail height is midway between the top rail and the stair surface. iii. A handrail is required on at least one side of the stairway. A stair rail may also serve as a handrail if it is surfaced to prevent injury from punctures or lacerations, and to prevent snagging of clothing. iv. Stair rails must support at least 200 pounds. v. Stair landings must be protected with standard guardrails as described in the fall protection section. 3. Ladders a. General Ladder Safety i. Ladders must be kept free of oil, grease and other slippery substances.

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ii. Precautions must be taken when ladders are placed in doorways, passageways or aisles where they can be displaced by workers or activities in the area. iii. Ladders should not be moved or adjusted while occupied. iv. Conductive (aluminum) ladders cannot be used where the ladder or the employee could contact electrical equipment. v. Ladders must be inspected frequently. Report any defects to your supervisor. The supervisor is responsible for removing from service any ladder that is not safe for use. vi. When climbing a ladder, the user must face the ladder and use the 3 points of contact system. vii. At least one hand must be completely free to grasp the ladder when climbing. No tools or equipment are to be carried up or down a ladder that could cause any employee to lose balance and fall. viii. Use a hoist line to raise or lower larger objects at ladder ways. ix. Ladder rungs must be uniformly spaced or meet OSHA/ANSI specifications. b. Stepladders i. Stepladders may only be used in the open position. A metal spreader or locking device is required to hold the ladder in the open position. ii. The top and the last step of stepladders may not be used as a step. iii. Cross bracing on the back of a stepladder may not be climbed. c. Straight/Extension Ladders i. When extension ladders are used to gain access to another level, the ladder must extend three feet above the upper landing surface. ii. The base of a straight ladder should be set up approximately one- quarter of the working height of the ladder away from the support (for example, the base of a ladder used to get on a twelve-foot roof should be three feet from the building). A rule of thumb – If you place your feet at the bottom of the feet of the ladder, your arms should extend straight out to the side rails of the ladder. iii. Straight ladders must have slip resistant feet. Ladders set up on slippery surfaces must be tied off at the top or bottom to prevent the ladder from kicking out. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 185 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

iv. Ladders used to access another level must be tied off at the top. v. The rails of a straight ladder must be supported equally unless it is equipped with a single support attachment. vi. Ladders must be used on stable and level surfaces unless they are properly secured.

Safety Manual

Steel Erection

1. Start-Up. Before steel erection may begin on any project, the steel erection contractor must ensure the following: a. Written Site-Specific Erection Plan is on-site and addresses the criteria as outlined by 29CFR1926.752 Appendix A. b. A pre-erection meeting shall take place between all appropriate contractors to review the Site-Specific Erection Plan and any other pertinent information. c. Written notification that the concrete in the footings, piers and walls and the mortar in the masonry piers and walls have attained sufficient strength to support the loads imposed during steel erection. d. Any repairs, replacements or modifications to the anchor bolts were documented and approved by the project engineer. 2. Hoisting and Rigging a. Hoist Equipment Inspections. All hoisting equipment must be inspected by a competent person prior to every shift. Any defects affecting the safety of the equipment shall be corrected before the equipment is used. b. Rigging equipment must be inspected by a qualified rigger prior to every shift. c. Riding of the headache ball is strictly prohibited d. Employees may be transported in a man basket if all the conditions of the CRANES section are met. e. Multiple Lifts (Christmas Treeing). Christmas treeing is permissible under the following conditions: i. A multiple lift rigging assembly is used. ii. Only beams and similar structural members are lifted iii. Five members may be rigged at one time, approximately level, and at least seven feet apart from each other. iv. All loads shall include at least one tagline to help control and steady the load. 3. Column Anchorage. a. All columns shall be anchored by a minimum of four anchor bolts b. Repairs, replacements or alterations to anchor bolts must be documented and approved by the project engineer. 4. Beams and Columns.

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a. When connecting solid web structural members, the hoist line shall not be released until two bolts per connection are made and drawn up wrench tight. b. Rigid members in pre-engineered buildings require 50% of their bolts, wrench tight, before releasing the hoist line. c. Diagonal bracing requires one bolt per connection, wrench tight, before releasing the hoist line. d. Double connections at columns require a seat under the first beam, bolted or welded to the column and the beam, or an “OSHA connection” 5. Bar Joists a. Bar joists at columns, not framed in at least two directions, must be stabilized to prevent lateral movement of the columns, and rotation of the bar joist. b. When joists are landed on a structure, they shall be secured to prevent accidental displacement. c. Attachment of Bar Joists i. Each joist shall be attached at least at one end on both sides of the seat immediately upon placement in the final erection position and before additional joists are placed. ii. Each end of "K" series steel joists shall be attached to the support structure with a minimum of two 1/8-inch fillet welds 1-inch-long or with two 1/2-inch bolts, or the equivalent. iii. Each end of "LH" and "DLH" series steel joists and steel joist girders shall be attached to the support structure with a minimum of two 1/4-inch fillet welds 2 inches long, or with two 3/4-inch bolts, or the equivalent. d. Erection of Bar Joists i. For bar joists requiring erection bridging per the attached OSHA Tables A and B, both sides of the seat of one end shall be attached before the hoist line is released. ii. For joists over 60 feet, both ends of the joist shall be attached before the hoist line is released. iii. For bar joists that do not require erection bridging, only one employee may be on the joist until all bridging is installed and anchored. e. Erection Bridging i. Where the span of the steel joist is equal to or greater than the span shown in OSHA’s bar joist Tables A and B (Steel Foreman Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 188 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

shall obtain a copy of the bar joist tables from the Safety Department.), the following shall apply: 1. A row of bolted diagonal bridging shall be installed near the midspan before the hoist line is released. 2. For joists over 60 feet, both ends shall be attached before releasing the hoist line. 3. No more than one employee shall be allowed on any bar joist until all bridging is installed and anchored. No more than two employees shall be allowed on any bar joist over 60 feet through 144 feet, until all bridging is installed. 4. No construction loads are allowed on steel joists until all bridging is installed and anchored and all joist-bearing ends are attached. 6. Fall Protection. a. Falling Objects i. All materials, equipment, and tools not in use must be secured to prevent accidental displacement. ii. No other trades may work below steel erection activities unless adequate overhead protection is provided. b. Ironworkers engaged in steel erection more than six (6) feet above a lower level require fall protection. c. On multi-story buildings, perimeter safety cables must be installed as soon as the metal decking has been laid.

Safety Manual

Work Zone Safety

1. Scope. This section applies to areas where roadwork is occurring, and traffic is affected. Roadwork activity includes: bridge work, adding travel lanes to the roadway, repairing the roadway, repairing electric, gas, or water lines within the roadway. 2. Areas within a work zone. Work zones are divided into four areas: a. Advance warning area – Section of the roadway alerting drivers to the work area. i. Signs used in this area may include Road Work Ahead, Flagger (Symbol), One Lane Road Ahead and Be Prepared to Stop (where appropriate). b. Transition area – Section of the roadway where drivers are redirected to temporary lane with the use of channelizing devices. i. There must be a minimum of six channelizing devices in any taper. ii. Channelizing devices must all be the same in a taper. (All cones or all vertical panels, etc.). iii. Channelizing devices must be made of material that will not significantly damage vehicles if they are struck. c. Activity area – Section of the roadway where work activity takes place. i. Channelizing devices are used to separate workers from traffic. ii. Channelizing devices must be the same in a work area. (All cones or all vertical panels, etc.), but may be different than those in the taper. iii. Channelizers should be spaced in feet two times the normal speed limit. (EX. Normal speed limit is 45 MPH, spacing is 90 ft. apart.) d. Termination area – Section of the roadway used to return drivers to their normal lanes. i. Signs used here include End Road Work or End Active Work Zone. 3. Protective Measures: Protective measures are needed to protect the workers within the work zone and the public using the road. a. Traffic Control Plan. The Temporary Traffic Control Plan (TTCP) describes the measures used to keep traffic moving safely and efficiently through the work zone. The measures selected depend on the residing

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authority, type of roadway, traffic conditions, length of the project, location restrictions and how close the workspace is to traffic. (See appendix A at the end of this section for examples of common TTCP diagrams.) b. Signs. i. Signs must be visible at all times when work is being done and must be removed or covered when the hazards no longer exist. ii. If signs become worn or damaged, they must be replaced. iii. Generally, signs should be placed on the right-hand side of the roadway. c. Signals. Signals warn of possible or existing hazards. They include: i. Sign paddles or flags held by flaggers. ii. Portable changeable message boards. iii. Flashing arrow displays. iv. Channelizing Devices. Channelizing devices include, but are not limited to: cones, tubular markers, vertical panels, drums, barricades, temporary raised islands, and barriers. These devices protect workers in the work zone, warn and alert drivers to conditions created by roadwork, and guide drivers. Make sure these devices are clean and visible. 1. When using vertical slash panels, the stripes should point to the road surface in the direction you want the vehicles to move toward. 4. Flaggers. When signs, signals, and barricades do not provide enough protection for operations on highways or streets, then flaggers or other traffic controls must be provided. However, flagging is dangerous because it exposes the flagger to traffic. Flaggers should follow these rules: a. Stop/Slow paddles when hand signaling in daylight. These paddles are octagonal in shape and have a red STOP sign on one side and an orange SLOW sign on the other. They must be retro-reflective. b. Use red flags (at least 24 inches square) in emergency situations. c. Use red light wand when hand signaling at night. d. Follow the preferred flagging method using a paddle (see diagrams): i. To stop traffic – Face traffic and hold the STOP sign paddle toward traffic with your arm extended horizontally away from the body. Raise your free arm with your palm toward approaching traffic. ii. To direct stopped traffic to proceed – Face traffic and hold the SLOW paddle toward traffic with your arm extended horizontally Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 191 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

away from the body. Motion with your free hand for traffic to proceed. iii. To alert or slow traffic – Face traffic holding the SLOW paddle toward traffic with your arm extended horizontally away from the body. You may motion up and down with your free hand, palm down, indicating that the vehicle needs to slow down.

iv. Wear an approved traffic safety vest. e. Coordinate with other flaggers and communicate by radio if you have no visual contact. f. Know how to combat both heat and cold exposure, dress appropriately, and know where shelter is available. g. Be alert to symptoms associated with carbon monoxide poisoning from vehicular traffic (nausea and headaches). If symptoms develop, get to fresh air. h. Be aware of construction equipment around you; make sure equipment operators know where you are. 5. Safe Work Practices a. When Working Near Traffic or Heavy Equipment: Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 192 I.B. Abel, Inc. – Confidential – All Rights Reserved

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i. Wear highly visible clothing and a light-colored hard hat. During the day, you must wear a vest colored orange, yellow, yellow- green, or a fluorescent version of these colors. At night, wear retro-reflectorized leg bands, a type 3 vest, and hard hat. ii. Work where drivers can see you, but as far as possible from traffic. Be aware that drivers may not be able to see you when the sun is low in the sky or when it is rainy, foggy, or dark. iii. Never get behind a backing vehicle. iv. Stay alert, portable audio players, radios, cell phones and similar devices are prohibited. When you hear backup alarms look to see where the vehicle is located and which direction it is backing. 6. Night work a. Retro-reflective PPE and equipment shall be used during night work. i. Type 3 vest is required. ii. Leg bands are required. iii. Channelizing devices shall be retro-reflective. iv. Stop/Slow paddle for flaggers shall be retro-reflective. v. All signs shall be retro-reflective. vi. Reflective tape applied to hard hats is recommended. b. Work zone lighting. i. Adequate lighting shall be provided for workers in work zone. ii. Flagger stations shall be illuminated at night. 7. Other Work Zone Protective Measures. Other work zone safety precautions and protective measures: a. Temporary barriers – These devices prevent vehicles from entering areas where hazards, workers, or pedestrians may be. b. Lower speeds – If workers are especially vulnerable, work zone engineers should consider lowering the speed of traffic. c. Shadow vehicle – If roadwork is mobile, like for pothole patching, a vehicle with proper lights, signs, or a rear impact attenuator (crash truck) should be used. d. Vehicle arrest systems – This is fencing, cable, or energy absorbing anchors that prevent vehicles from entering activity areas while allowing the vehicle to safely slow down. e. Rumble strips/SNAPS – These consist of textured road surfaces that alert drivers to changing conditions. f. Road closure – If alternate routes can handle additional traffic the road may be closed temporarily to give you the greatest protection. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 193 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

g. Law enforcement – For high risk work zones, police units may be placed to reduce traffic speeds. h. Intrusion warning devices – These devices alert workers of vehicles that accidentally enter the workspace.

Appendix A- Samples of common work zone applications.

Safety Manual

Asbestos Containing Material

1. General. This policy will provide guidance in the recognition and avoidance of materials that may contain asbestos and their hazards. Such materials may include: spray-on fireproofing, boiler and pipe insulation, duct insulation, acoustical plaster and tiles, brake shoes, transite, floor tiles and many other materials. a. Definitions i. Asbestos. Asbestos is a naturally occurring mineral that is made of tiny, sharp fibers that are too small to see, feel or taste. Asbestos was used in many building materials and products. It is associated with many health hazards when it is breathed in. ii. Asbestos Containing Material (ACM). Any material containing more than one percent asbestos. iii. Class I asbestos work. Work involving the removal of thermal systems insulation or surfacing ACM. Examples include the removal of boiler insulation, pipe insulation or spray-on fireproofing. iv. Class II asbestos work. Work involving the removal of any other type of ACM. Examples include transite sheeting and pipe, floor tiles and mastic and roofing and siding shingles. v. Class III asbestos work. Repair and maintenance operations where any type of ACM is likely to be disturbed. vi. Class IV asbestos work. Maintenance or custodial activities where ACM may be contacted but not disturbed. Includes cleanup of Class I, Class II or Class III work. vii. Friable ACM. An asbestos containing material that can be crumbled under hand pressure. Spray-on fire proofing would be considered friable. Transite pipe would be considered non-friable. 2. Health Hazards. Asbestos is harmful when it becomes airborne. All the diseases related to asbestos exposure have a latency period of ten to forty years. This means that you may not become sick until up to forty years after being exposed to asbestos. Exposure to airborne asbestos has been linked to the following diseases: a. Asbestosis. “White Lung Disease,” a scarring of the lungs caused by chronic exposure to asbestos fibers.

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b. Mesothelioma. A cancer of the lining of the lungs or stomach. Mesothelioma is not dose-related like the other associated diseases (dose-related means the more asbestos you are exposed to, the greater the likelihood of developing an asbestos related disease). c. Lung cancer. Lung cancer is the most common disease related to asbestos exposure. Smokers exposed to asbestos are at a much greater risk of developing lung cancer. d. Other cancers. Exposure to asbestos is also related to cancers of the stomach or gut. 3. Control Measures a. IBA employees are not permitted to perform any Class I removal or any Class II removal of ACM that may become friable. These types of work have very strict regulations by OSHA, EPA, DEP Bureau of Air Quality and the Department of Labor and Industry. b. Employees removing or disturbing any kind of ACM must be properly trained. Class II work, Class III work and Class IV work all have specific training requirements for employees. c. Cleanup of ACM should be done with a High Efficiency Particulate Air (HEPA) filtered vacuum cleaner, so fibers are not released into the air. d. Wet methods should be used to minimize airborne fibers. e. Prompt cleanup and disposal of materials in leak tight containers is required. f. If a lot of dust is to be created from sanding, sawing, drilling, etc., an enclosure such as a glove bag will have to be used. g. Respirators with P-100 filters and disposable coveralls must be worn if friable asbestos is removed or disturbed. h. Work must be done in a regulated area to keep unauthorized employees away. i. When employees are working on a multi-contractor worksite, IBA employees will be protected from exposure with applicable controls as needed. j. If asbestos is identified on our job site our employees are trained not to disturb asbestos material and contact applicable agencies for proper handling and/or removal. k. Asbestos awareness training is provided to employees on an initial and ongoing basis, and a documented part of our onboarding training.

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4. Regulations. Asbestos is one of the most heavily regulated hazardous materials. Contact the Safety Department with any questions regarding the regulations on asbestos. a. OSHA. OSHA’s standard on asbestos covers exposure monitoring (air sampling), respiratory protection and protective clothing, mandatory work practices and training. b. EPA. The EPA requires notification before friable materials are removed from a building (NESHAP permit). The EPA also developed the Model Accreditation Plan for training asbestos abatement workers. c. Dept. of Labor and Industry. The PA DOLI requires that any employee in Pennsylvania performing Class I and some Class II asbestos abatement be trained and licensed. The training consists of forty hours of instruction based on the EPA Model Accreditation Plan. d. Local Building Codes. Some local building codes also have rules regarding demolition. Check with the local building code to confirm if other considerations are required.

Safety Manual

Back Injury Prevention

1. General. Back injuries account for a large percentage of work-related accidents. This section discusses the anatomy of the back, risk factors for back injury and how to prevent back injuries. 2. Anatomy of Your Back. The term back injury may refer to an injury to any one of the following structures in your back. a. Vertebrae. Your spine consists of a stack of 33 bones called vertebrae. The vertebrae form an S-shaped column that houses the spinal cord, the message center from your brain to your body. b. Discs. The discs are the cushions between the vertebrae. Discs are like a jelly doughnut with a soft inner core and a tough outer coating. Herniated, slipped, bulging or ruptured disc are all terms meaning the inside of the disc is squeezing out of the tough outer coating. c. Ligaments and Muscles. Most back injuries are strains to the muscles or ligaments in the back. 3. Risk Factors for Back Injuries. The following factors place workers at an increased risk of back injury. a. Lifting heavy objects, especially from low, high or awkward positions. Objects lifted from below knee height or above shoulder height place additional strain on the back. b. Performing jobs that require frequent bending. c. Weak and fatigued muscles cannot support the back as well and are more likely to result in back injury. d. Poor posture while standing or sitting can lead to back injury. 4. Training. Training will be conducted on the general principles of ergonomics, recognition of hazards and injuries, reporting hazardous conditions, and the procedure for reporting of injuries. Job specific training may be required on safe lifting work practices, hazards, and controls. 5. Qualified Observations are conducted periodically by a Qualified Observer trained in identifying improvement opportunities of an employee’s work area and work techniques for several categories including Human Performance, Safety Standards, Ergonomics, Posture, Pre-Job Briefing, Work Area Issues, Energized Work Methods, Material Handling and Rigging. 6. Safe Lifting Practices. Most work-related back injuries occur over a period of time because of workers using poor lifting techniques or improper body mechanics. In

Safety Manual

addition to reducing or eliminating the other risk factors listed above, following these safe lifting practices will minimize back injury and low back pain. a. Before manual lifting is performed, a hazard assessment must be completed. The assessment must consider the size, bulk, and weight of the object(s), if mechanical lifting equipment is required, if two-man lift is required, whether vision is obscured while carrying and the walking surface and path where the object is to be carried. b. Do not move large or heavy objects manually if it can be done with a piece of equipment. Use a forklift, hoist or other piece of equipment to do the job if one is available. c. When lifting heavy objects and mechanical equipment is impractical or not available, two-man lifts must be used. d. Break down the load into two smaller loads if possible. Make two small lifts rather than one heavy lift. e. Pre-plan your route before you lift heavy or large objects. Make sure there are no tripping hazards, slippery surfaces or obstacles in your way. Have someone open doors, gates, etc. for you. f. Get as close to the load as possible. Squat down with one foot slightly forward for balance. Position the load between your legs if possible. Keep your back straight and lift with your legs. Keeping the load as close to your center of gravity as possible reduces strain on your back. g. Try to store heavy objects, such as Simon forms, between knee and shoulder height to avoid awkward lifts. h. Glue your hand to your thigh when lifting heavy objects with one hand, such as a heavy toolbox. Place your free hand on the outside of your thigh and mentally “glue” it there. This will help keep your back aligned. Bending or tilting to the side can be just as bad for your back as bending forward. i. Do not twist your body while lifting a heavy load. Move your feet and turn your whole body. When using a shovel step into the direction you are throwing the material, do not simply twist at your waist to toss the shovel full. j. Avoid fast jerking motions when lifting a heavy load. k. Push heavy carts rather than pulling on them. This is less stressful on the back. 7. Injuries caused by improper lifting will be investigated, documented and assigned corrective actions which may include a change in the procedure to mitigate future hazards. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 200 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

Blood Borne Pathogens

1. Scope and application. This policy applies to all employees who may be reasonably anticipated to have an occupational exposure to blood or other potentially infectious material. 2. Definitions. The following terms are used throughout this policy: a. Blood borne Pathogen means pathogenic microorganisms that are present in human blood and can cause disease in humans. These pathogens include, but are not limited to, hepatitis B virus (HBV), and human immunodeficiency virus (HIV). b. Contaminated means the presence or reasonably anticipated presence of blood or other potentially infectious materials on an item or surface. c. Decontamination means the use of physical or chemical means to remove, inactivate, or destroy blood borne pathogens on a surface or item to the point where they are no longer capable of transmitting infectious particles and the surface or item is rendered safe for handling, use or disposal. d. Exposure Incident means a specific eye, mouth or other mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious materials that result from the performance of an employee’s duties. e. Occupational Exposure means reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of employee’s duties. f. Other Potentially Infectious Materials means: i. The following human body fluids: semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, anybody fluid that is visibly contaminated with blood, and all body fluids where it is impossible to differentiate between body fluids. ii. Any unfixed tissue or organ (other than intact skin) from a human (living or dead); and g. Universal Precautions is an approach to infection control. According to the concept of Universal Precautions, all human blood and certain human body fluids are treated as if known to be infectious for HIV, HBV or other blood borne pathogens. 3. Exposure Control.

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a. Exposure Determination. i. Affected employees. Those personnel trained in First Aid and CPR may have an occupational exposure to blood borne pathogens. ii. Tasks or procedures at risk. Those personnel may be occupationally exposed to blood borne pathogens while administering care to injured or ill employees. b. Control Methods. i. Universal Precautions will be observed at all times to prevent contact with blood or other potentially infectious materials. ii. Employees shall wash their hands and any other skin with soap and water, or flush mucous membranes with water immediately after contact of such body areas with blood or potentially infectious materials. iii. Personal Protective Equipment. The following personal protective equipment shall be available for use when the possibility of contact with blood or other potentially infectious materials exists: 1. Employees will wear appropriate eye and face protection as conditions warrant. 2. Latex gloves will be provided in all first aid kits and used for all care administered. 3. CPR shields equipped with a one-way valve will be supplied to any individual trained to perform CPR. 4. Hepatitis B Vaccination Series and Post-Exposure Evaluation and Follow-Up. a. Hepatitis B Vaccination. IBA shall make available the Hepatitis B vaccination to all employees who have an occupational exposure and post exposure evaluation and follow-up to all employees who have an exposure incident. i. Employees have the right to refuse the hepatitis B vaccination series and may change their minds at any time in the future and initiate the vaccination series. b. Post Exposure Evaluation and Follow-Up. Following a report of an exposure incident, a confidential medical evaluation and follow-up will be provided. They shall consist of the following: i. Documentation of the route of exposure and the circumstances leading to the exposure incident. ii. Identification and evaluation of the source individual if possible.

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iii. If consent is received, the source individual shall receive screening for HIV and HBV infectivity. iv. Screening of the affected employee’s blood for HIV and HBV infectivity v. Post exposure treatment if necessary. vi. Counseling if necessary. vii. Evaluation of reported illnesses. 5. Training. First aid, CPR, and blood borne pathogens training is conducted on an annual or bi-annual basis. Only employees who participate in this training are permitted to render first aid or CPR. The blood borne pathogens training shall consist of the following: a. All control plans are provided with first aid training. b. An explanation of the Blood borne Pathogens Standard. c. A general explanation of the epidemiology and symptoms of blood borne diseases. d. An explanation of the modes of transmission of blood borne diseases. e. An explanation of the Exposure Control Plan. f. An explanation of the controls to be used to limit exposures to blood borne diseases. g. Information on the PPE to be used to control exposures. h. Information on the hepatitis B vaccine, including its effectiveness, safety, method of administration, the benefits of being vaccinated, and that the vaccine is free of charge. i. Information on the procedure to follow in the event of an exposure incident. j. Information on post-exposure evaluations and follow-up treatment.

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Carbon Monoxide

1. This policy will provide guidance in preventing adverse health effects associated with working around Carbon Monoxide. a. Carbon Monoxide (CO) i. CO is an odorless, colorless gas that interferes with the delivery of oxygen in the blood to the rest of the body. ii. Under high pressure it is a liquid. iii. OSHA’s Permissible Exposure Limit (PEL): 50 ppm based on 8- hour Time Weighted Average (TWA) iv. OSHA’s Immediately Dangerous Life or Health Limit (IDLH): 1200 ppm based on 8-hour Time Weighted Average (TWA). v. Gas monitors are available from the Safety Department. b. Sources of CO i. CO is produced as a result of incomplete burning of carbon- containing fuels including gasoline, coal, wood, charcoal, natural gas, and fuel oil. ii. It can be emitted by combustion sources such as unvented kerosene and gas space heaters, furnaces, wood stoves, gas stoves, fireplaces, water heaters, automobile exhaust, gas powered tools, and tobacco smoke. c. Health Effects of Carbon Monoxide i. CO is an asphyxiant to humans. ii. CO interferes with the distribution of oxygen in the blood to the rest of the body. iii. Inhalation of CO causes tissue hypoxia by preventing the blood from carrying sufficient amounts of oxygen to the brain. iv. Depending on the amount inhaled, this gas can impede coordination, worsen cardiovascular conditions, and produce fatigue, headache, weakness, confusion, disorientation, nausea, and dizziness. v. Very high levels can cause death. d. Construction Site CO Exposure i. Make sure all vehicles, welders, gas powered tools are not operated in enclosed areas. e. CO Poisoning i. Get individual to fresh air immediately.

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ii. Turn off CO producing vehicles, equipment or tools immediately. iii. Let the Emergency Medical Technician (EMT) know if CO poisoning is suspected. f. Safeguards for Reducing Exposure to CO i. Beware of health effects and hazards associated with CO. ii. Air monitoring prior to allowing work to take place in areas where suspected high levels of CO may exist. iii. Engineering Controls such as proper ventilation. iv. Knowing work operations where exposure exists. v. Wearing appropriate respiratory protection. Only supplied air respirators protect against CO.

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Process Safety Management

1. General. This program covers maintenance, repair, turnaround, major renovation, and specialty work in facilities covered by the Process Safety Management standard. This program contains requirements to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. 2. Training and Information. Each employee working in a covered area will be trained in the potential fire, explosion, or toxic release hazards related to the work and process and the applicable provisions of the emergency action plan. All training will be documented and will include: a. Properties of, and hazards presented by, the chemicals used in the process. b. Control measures to be taken if physical contact or airborne exposure occurs. c. Quality control for raw materials and control of hazardous chemical inventory levels. d. Any specific or unique hazards. 3. Safe Work Practices. All work shall be done in accordance with established safe work practices to provide for the control of hazards during operations such as lockout/tagout, confined space entry, opening process equipment or piping; and control over entrance into the facility. a. Hot Work Permit. Hot work will be performed by permit only. Permits must be authorized by the Host Employer. 4. Coordination with Host Employer. a. The Project Manager shall ascertain from the Host Employer: i. The details of the Host Employer’s Process Safety Management plan including known potential fire, explosion, or toxic release hazards related to the contracted work. ii. The applicable provisions of the Emergency Action Plan. iii. Entry and exit policy and procedures in covered area. b. The Foreman will notify the Host Employer of the following: i. Any unique hazards created by the scope of contracted work. ii. Any hazards discovered during the course of work that were not previously communicated. 5. Incident Reporting and Investigation. In addition to the reporting and investigation requirements required by company policy; and near miss or incident involving a

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release or potential release of highly hazardous chemicals must be reported to the Host Employer immediately. Employees shall cooperate completely with the Host Employer incident investigation team. 6. Trade Secrets. Employees may be asked to sign Confidentiality Agreements if information is made available to them for purposes of developing safe work practices, emergency action plans, incident investigations, or training.

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Hazard Communication Program (HAZCOM)

1. Scope. The purpose of this program is to ensure that information on the hazards of the chemicals is transmitted to the employers and employees. The information in this program is intended to be consistent with the provisions of the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The transmittal of this information will be done using a Hazard Communications Program which will include container labeling and other forms of warning, Safety Data Sheets and employee training.

2. Labels and other forms of warning. a. Labels on shipped containers (original container) i. Original container labeling will have following information: 1. Product identifier 2. Signal word 3. Hazard statement 4. Pictograms 5. Precautionary statement 6. Name, address, and telephone number of manufacturer, importer or responsible party ii. Sample label and HCS pictograms are shown in appendix A and B of this policy. b. Workplace Labeling (secondary containers) i. Each secondary container of hazardous chemicals shall be labeled, tagged or marked with the following information at minimum: 1. Product identifier of the hazardous chemicals contained therein; and, 2. Appropriate hazard warnings, or alternatively, words, pictures, symbols, or combinations thereof, which provide at least general information regarding the hazards of the chemicals. The preferred hazard warning label will be the NFPA 704 Labeling System ii. NFPA 704 Labeling System is shown in Appendix C of this policy c. Single Use Containers - Labels are not required for portable containers into which hazardous chemicals are transferred from labeled containers,

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and which are intended only for the use of the person who performed the transfer. d. If any label or hazard warning on any material becomes illegible or is missing, it must be replaced with another label containing same information as previous shown on the container. 3. Safety Data Sheets a. Workplace accessible copies of Safety Data Sheets shall be maintained for each hazardous material that is being used or stored onsite. These copies can be accessed through the following means: i. On-site binder maintained by jobsite supervisor ii. Electronically on the Intranet. iii. Subscription service with MSDSonline – see appendix D of this policy iv. Other means such as CDs, thumb drives or other data recording methods b. All SDS information should be kept in a location that is easily accessible if an SDS is requested by an employee, subcontractor, or local or federal agency. c. Each supervisor shall have or obtain a jobsite poster to keep with the index or post in the job or tool trailer. 4. Employee information and training a. Employees shall be provided with effective information and training on hazardous chemicals in their workplace whenever a new physical or health hazard the employees have not been trained about is introduced into their work area. Hazard communication training is part of our onboarding training at the time of hire, and on an ongoing basis. i. Employees shall be informed of the following information: 1. The requirements of the OSHA Hazard Communication Standard 29CFR1910.1200 2. The requirements of the MSHA Hazard Communication Standard 30CFR Part 47 3. Any operations in the work area where hazardous chemicals are present 4. The location and availability of the written Hazard Communication program, including the lists of hazardous chemicals and SDSs

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5. IBA management will coordinate with all site contractors to establish a project by project hazard communication process. ii. Employee training on specific chemicals or building materials shall include at least: 1. Employees are trained to recognize symbols that are on a potentially hazardous chemical which provides a general scope of the hazards associated with the chemical. 2. Employees are trained to utilize a questioning attitude shall they encounter a mislabeled, or unclear container. 3. Employees are trained to perform a stop/time-out when unsure and to contact the Safety & Quality Department for further direction. 4. Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring, odor, visual appearance of a release). 5. The physical and health hazards of the chemicals in the work area. 6. The measures employees can take to protect themselves from these hazards, including specific procedures such as work practices, emergency procedures, and PPE 7. The details of the IBA, Inc. Hazard Communication Program including an explanation of the labeling systems for Original, Secondary and Single-use containers.

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Appendix A – Sample of Label on shipped containers (Original container)

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Appendix B – HCS Pictograms and Hazards

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Appendix C – NFPA 704 Labeling System

RED

BLUE YELLOW

WHITE

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Appendix D – MSDSonline Contact Information

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Hearing Conservation Program

This procedure will provide guidance in preventing adverse health effects associated with working around occupational noise. Employees who are exposed to hazardous levels of noise in the workplace are at risk for developing noise-induced hearing loss. Noise-induced hearing loss is preventable but once acquired, hearing loss is irreversible. 1. Occupational Noise Exposure l. OSHA requires a hearing conservation program whenever employee noise exposures equal or exceed an eight-hour time weighted average (TWA) of 85 decibels (dBA). m. Noise measuring will be performed if employees are being exposed to noise that is 85 dBA or louder on a TWA. n. If an employee is exposed to noise that is 85 dBA or louder on an eight- hour TWA, the employee(s) will be included in a hearing conservation program. o. Hearing protection is provided at no cost to employees. p. I. B. Abel shall evaluate hearing protection for the specific noise environments in which the protection will be used. 2. Hearing Conservation Program If an employee is included in a hearing conservation program, the following will take place: a. An initial hearing test will be conducted within six (6) months of exposure. b. Audiometric testing will be performed annually for employees who are exposed to 85dBA or louder on a TWA. c. If it is determined that an employee tested has a standard threshold shift (STS), the employee will be notified in writing within 21 days. d. In the event of an STS, the employee will be re-evaluated to determine if the correct hearing protection is being used. e. Records of employee exposure and audiometric testing will be maintained. 3. Training g. All employees are provided annual training on hearing conservation and on the required and proper use of hearing protection.

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Lead Awareness

1. General. This program applies to all projects where employees may be exposed to lead. Examples of such projects include demolition or salvage of structures where lead or materials containing lead (such as lead based paint) are present; removal or encapsulation of materials containing lead or installation of materials containing lead. Keeping lead dust out of the air and practicing good hygiene are the keys to reducing lead exposure. a. IBA shall provide training programs for each employee who has potential exposure to lead prior to the time of initial job assignment and annually and training records will be maintained. b. No employee shall be exposed to a PEL on fifty micrograms per cubic meter of air. c. Any lead containing material shall be avoided and left undisturbed. 2. Health hazards. Lead can enter the body through inhalation when it is airborne or through ingestion. Exposure to lead effects the following systems: a. Nervous system. Mood and personality changes and retarded mental development at high doses. b. Renal (blood making) system. Leads to chronic fatigue, anemia. c. Gastrointestinal tract leading to colic’s and cramping (may be flu-like symptoms). d. Reproductive systems in men and women (including increased risk of miscarriage) e. Kidney damage. 3. Control Measures. a. Employees exposed to airborne lead will be provided appropriate respiratory protection in accordance with the Respiratory Protective Equipment section. Air monitors will also be used to when there is a recognized lead hazard in conjunction with the respirators. b. IBA will perform Blood lead and ZPP level sampling and analysis with follow up sampling and analysis after 6 months. A blood lead level at or above 40 ug/100 g of whole blood. This frequency shall continue until two consecutive blood samples and analyses indicate a blood lead level below 40 ug/100 g of whole. Employees will be notified of their results. c. Appropriate PPE will be provided along with wash and change stations for each job site where a hazard exists. Lead qualification and training will occur prior to the start of any lead exposure on the job.

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d. When working on multi-contractor worksites, IBA employees shall be protected from exposure by utilizing proper PPE e. If large amounts of lead containing dust are created, protective clothing will be provided to prevent contamination of workers clothing and the spread of lead contamination. f. Employees exposed to lead containing materials shall not eat, drink, smoke or apply cosmetics in the work area. g. Work areas will be kept as clean as possible to reduce the spread of lead contamination. h. Washing facilities will be provided to employees exposed to lead dust to wash before leaving regulated areas and taking breaks. i. Employees who may be exposed to high levels of lead will be enrolled in a medical surveillance program to monitor blood lead levels and other indicators of lead exposure. Employees over-exposed to lead will be transferred to another project. j. If initial testing is above the action level, monitoring is conducted every six months until two consecutive results are below the action level. k. Employees will be notified in writing of the air monitoring results and corrective actions taken. l. IBA shall provide a written (site specific) compliance program which has been developed & implemented to reduce exposures to or below permissible limits. m. In the event of the presence of lead, IBA will provide the specific type of PPE required to the employees at no cost. n. If lead is present, signs shall be posted in and around the regulated work area. 4. Regulations a. OSHA. OSHA regulates worker’s occupational exposure to lead. The standard includes requirements for exposure monitoring, respiratory protection and biological monitoring of employees. OSHA also sets a permissible exposure limit for airborne lead. b. EPA. The Environmental Protection Agency regulates many aspects of lead. Removal of lead-based paints in child occupied facilities is treated much like their requirements for asbestos abatement.

Safety Manual

Mold Awareness

1. General. Mold is a naturally occurring growth of minute fungi that forms on organic matter and associated with decay and dampness. 2. Characteristics of Mold. a. Molds reproduce through spores that can be hard to detect by naked eye. Spores can float through the air or be transported on contaminated materials. b. Usually not a problem unless the spores land on moist or wet surfaces and begins to grow. c. Spread and thrive when encountering wet or moist surfaces. d. Outdoors, mold can break down dead organic matter such as fallen leaves and dead trees as well as living matter. e. Indoors, it has the potential to create health and structural damage. 3. Mold spores are everywhere. One can never eradicate the presence of mold spores but can deter the growth of mold by eliminating key elements that encourage mold growth. a. Food for mold –Anything organic. Paper, dust, cloth, starch, wood, drywall, fabric, carpet etc. b. Presence of water – Mold likes moist surfaces. High humidity (above 55%), condensation, poor drainage, etc. c. High Temperatures – Mold likes higher temperatures (over 70 deg. F). d. Low light and stagnant air. 4. How to Prevent Mold. a. Control sources of moisture. (more so than temperature) b. Allow moist materials to dry prior to closing, sealing or permanently covering. c. Protect building materials through timely deliveries and site covers. d. Provide ventilation. e. Vent interior fans and appliances to the outside. f. Drain downspouts away from building foundations, etc. 5. How to Manage Mold in Buildings a. Prevent Water Egress – Use flashing, vapor barriers, waterproofing, positive drainage, HVAC condensation management, material protection, etc. b. Reject contaminated materials, protect and ventilate delivered materials.

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c. Respond to mold outbreaks quickly and thoroughly. Remove source of moisture and dry out if possible. 6. Health Hazards - Harmful attributes of Mold. Molds produce… a. Allergens, a substance that can cause allergic reactions. Symptoms may be itchy, watery eyes, runny nose, sneezing and other allergy type symptoms. b. Irritant reaction – caused when mold substances irritate the mucous membrane in the body. c. Infections – Infections caused by mold can lead to flu-like symptoms, skin infections and even pneumonia. d. Mycotoxins – A toxic reaction may also include flu-like symptoms, eye and skin irritation, and breathing troubles. Headaches, nervousness, dizziness, difficult concentration and extreme fatigue may also be experienced. 7. Health Protection a. Always wear gloves and protective clothing (coveralls, coat, etc.) when handling materials with observed mold. b. Wear Eye-protection – Wear goggles that do not have a respirator holes are recommended. Avoid getting mold spores in your eyes! c. Respirators – To limit your exposure to airborne mold, you will need to wear a respirator or dust mask with protection factor N-95 or greater.

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Respiratory Protection

1. Scope a. I.B. Abel, Inc. (IBA) has established a respiratory protective equipment program to protect employees from occupational diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays or vapors. The primary objective will always be to prevent atmospheric contamination by accepted engineering control measures such as enclosure or confinement of the operation, general or local ventilation, and substitution of less toxic materials. b. When engineering controls are not feasible, respirators shall be provided to protect employees. 2. Selection a. Selection of respiratory protection will be controlled through the Safety & Quality Department. b. Only NIOSH-certified respirators shall be used. Respirators shall be used in compliance with the conditions of its certification. 3. Medical Evaluation. a. All employees required to use respirators shall receive a medical evaluation to determine their ability to do so safely. b. Medical evaluations shall be provided by WorkFirst Occupational Healthcare or another approved provider. c. Evaluations shall be conducted in accordance with OSHA’s Respiratory Protection standard. 4. Fit Testing a. Before employees are permitted to use a respirator with a negative or positive pressure tight-fitting face piece, they must be fit tested with the same make, model, style and size of respirator that will be used. b. Employees shall be fit tested prior to initial use of the respirator, whenever a different respirator face piece (size, style, model or make) is used, or at least annually thereafter. c. Additional fit testing may be required whenever the employee reports, or the supervisor or Safety Director makes visual observation of, changes in the employee’s physical condition that could affect the respirator’s fit. Such conditions include, but are not limited to, facial scarring, dental changes, cosmetic surgery, or an obvious change in body weight. d. The test shall be administered using an OSHA-accepted fit test protocol.

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5. Use of Respirators a. Respirators with tight fitting face pieces shall not be worn by employees with: i. Facial hair that comes between the sealing surface of the face piece and the face or that interferes with valve function: or ii. Any condition that interferes with the face to face piece seal or valve function b. Safety glasses, corrective lenses or other personal protective equipment shall be worn in such a manner that does not interfere with the seal of the face piece to the face of the user. c. Each time a respirator is put on, employees shall perform a seal check in accordance with manufacturers recommendations d. Employees shall leave the respirator area: i. To wash their faces and respirator face pieces as necessary to prevent eye or skin irritation associated with respirator use; or ii. If they detect vapor or gas breakthrough, changes in breathing resistance, or leakage of the face piece. 6. Maintenance and Care of Respirators a. Employees shall ensure that all respirators are stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals, and they shall be packed or stored to prevent deformation of the face piece and exhalation valve. b. All respirators are to be inspected as follows: i. All respirators used in routine situations shall be inspected before each use and during cleaning. ii. Any respirator maintained for use in emergency shall be inspected at least monthly and in accordance with the manufacturer recommendations and shall be checked for proper function before and after each use. c. Respirator inspection shall include the following: i. A check of respirator function, tightness of connections, and the condition of the various parts including, but not limited to, the face piece, head straps, valves, connecting tube, and cartridges, canisters or filters; and ii. A check of elastomeric parts for pliability and signs of deterioration.

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d. Respirators that fail an inspection or are found to be defective shall be removed from service, discarded, repaired or adjusted in accordance with manufacturers recommendations i. Repairs or adjustments shall only be made by persons appropriately trained and shall use only the respirator manufacturer’s NIOSH approved parts designed for the respirator. ii. Repairs to respirators used for emergency situations shall only be repaired by the manufacturer or a technician trained by the manufacturer. 7. Training. IBA shall provide training to all employees required to wear respirators. Training shall occur prior to any employee being assigned to a job requiring the use of respiratory protection.

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Silica Awareness

1. This policy will provide guidance in preventing adverse health effects associated with working around Crystalline Silica. a. Crystalline Silica (quartz) i. Crystalline Silica is a natural material found in the earth’s crust, it is a basic component of sand and granite. ii. Crystalline silica is found in many building products including concrete and masonry products. iii. Crystalline silica is linked to diseases of the lungs when it is in the air and workers breathe it in. b. Silicosis i. Silicosis is a disease of the lungs due to breathing of dust containing crystalline silica particles. This dust can cause fibrosis or scar tissue formations in the lungs that reduce the lung’s ability to expand and contract effecting extraction of oxygen from the air. There is no cure for this disease, thus, prevention is the only answer. c. Symptoms of Silicosis i. There are several stages of silicosis and early stages may go completely unnoticed. Continued exposure may result in the exposed individual noticing shortness of breath upon exercising, possible fever and occasionally bluish skin at the ear lobes or lips. Silicosis makes an individual susceptible to infectious disease of the lungs like tuberculosis. Progression of the disease leads to fatigue, extreme shortness of breath, loss of appetite, pain in the chest, and respiratory failure, which all may lead eventually to death. Acute silicosis may develop after short periods of exposure. Chronic silicosis usually occurs after 10 or more years of exposure to lower levels of quartz. Smoking can add to the damage caused by crystalline silica exposure. d. Construction Site Crystalline Silica Exposure i. Concrete mixing, concrete drilling, concrete/brick cutting or sawing and jack hammering. ii. Sand blasting to remove paints and rusts from various surfaces. iii. Work in foundries. e. Safeguards for Reducing Exposure to Crystalline Silica

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i. Beware of health effects and hazards associated with crystalline silica. ii. Wearing approved respirators for protection against crystalline silica-containing dust. iii. Engineering Controls such as spraying water and proper ventilation. iv. Knowing work operations where exposure exists. v. Wash hands and face before eating, drinking, or smoking outside areas where there is dust containing crystalline silica. vi. Air Monitoring vii. If you have any questions, please refer them to the Safety Department.

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Smoking

1. This policy will provide guidance in preventing adverse health effects associated with Smoking. a. Smoking i. Cigarette smoking is the leading preventable cause of death in the United States; it is responsible for one in every five American deaths. Smoking claims the lives of an estimated 1,100 people per day—over 400,000 smokers die from smoking-related diseases and 3,000 nonsmokers die from lung cancer each year. b. Health Effects of Smoking i. Results in premature death and causes significant disease and disability. ii. Coronary heart disease and stroke. iii. Lung Cancer, Laryngeal Cancer, Cancer of Oral Cavity, Bladder Cancer, and can contribute to: Pancreatic Cancer and Renal Cancer. iv. Can cause Chronic Bronchitis and Emphysema. c. Examples of hazardous materials that when combined with smoking present a serious health risk: i. Coal, Grain, Silica, Welding Materials, Asbestos, Petrochemicals, Aromatic Amines, Pesticides, Cotton Dust and Ionizing Radiation.

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Temperature Extremes

1. Scope. This policy will provide guidance in preventing adverse health effects associated with Hot / Cold Temperature Extremes. 2. Heat Stress. Heat is a serious hazard in construction. Your body builds up heat when you work and sweats to get rid of extra heat. But sometimes your body may not cool off fast enough. Employees are trained in heat illness prevention on an initial and ongoing basis. Supervisors are trained to in heat illness prevention before being qualified to supervise other employees a. Heat Stress depends on many things: Physical condition, weather, clothing, and physical exertion. b. Supervisors must take personal factors into consideration before assigning a task where there is a possibility of a heat related illness occurring such as age, weight/fitness, drug/alcohol use, prior heat-related illness, etc. c. Effects of Heat Stress i. Cramps – Often the first sign of heat related illness. ii. Dehydration – When your body loses water, you can’t cool off fast enough feeling thirsty and weak. iii. Heat Exhaustion – Symptoms include fatigue, nausea, headache, and dizziness. Skin will feel damp to the touch and look pale, ashen, or flushed and there is a possibility of fainting. iv. Heat Stroke – Skin will feel hot to touch; dry and body temperature will be very high. Confusion, convulsions, unconsciousness and death may result from heat stroke. d. Safeguards for Reducing Exposure to Hot Temperature Extremes i. All Supervisors and IBA employees are trained in first aid each year, which includes heat illness prevention and when to escalate treatment above first aid to emergency services by calling 911. ii. IBA provides bottled water to all employees on each job site. iii. Drink a lot of cool water all day – before you get thirsty. (Every 15 minutes drink 5-7 ounces of water) iv. At or below 80 degrees Fahrenheit the employee shall have timely access to shade upon request. For temperatures at or above 80 degrees Fahrenheit, one or more areas with shade shall be provided at all times while employees are present. Shade shall

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accommodate the number of employees on recovery or rest periods. v. Keep taking rest breaks. Rest in cool shaded areas. vi. Wear light-colored clothing made of cotton. vii. Do the heaviest work during coolest time of the day. viii. High-heat procedures shall include, but are not limited to: 1. Effective communication by voice, observation or electronic means 2. Observation of employees for alertness and signs/symptoms of heat illness 3. Designating one or more employees on each worksite as authorized to call for emergency medical services 4. Reminding employees to drink water throughout the shift 5. Pre-shift meetings before beginning work to review the high heat procedures, encourage drinking water, and remind employees of their right to take a cool-down rest when necessary. 3. Cold Stress. A cold environment forces the body to work harder to maintain its temperature. a. Four factors that contribute to cold stress are Cold Temperatures, High or Cold Winds, Dampness and Cold Water. b. Health Effects of Cold Stress. When in a cold environment, most of the body’s energy is used to keep your internal temperature warm. Over time, the body will begin to shift blood flow from the extremities (hands, feet, arms and legs) and outer skin to the core (chest and abdomen). This allows exposed skin and the extremities to cool rapidly and increase the risk of the following: i. Frostbite. Frostbite is a freezing of body parts. Frostbite may lead to the loss of fingers, hands, toes, feet or other parts of extremities. Lack of feeling and skin that appears waxy or discolored are signs of frostbite. ii. Hypothermia. Hypothermia is a condition when the body loses its ability to stay warm. Shivering, numbness, apathy, impaired judgement, and weakness are all signs of hypothermia. c. Safeguards for Reducing Exposure to Cold Temperature Extremes i. Dress appropriately for weather conditions. Dress in three different layers (outer, middle and inner). Cotton and wool are preferred materials. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 228 I.B. Abel, Inc. – Confidential – All Rights Reserved

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ii. Wearing a hat. Up to 40% of body heat can be lost if head is left exposed. Hardhat liners are available from the warehouse.

Spill Prevention and Response

1. General Requirements a. All chemical substances shall be stored in proper containers to minimize the potential for a spill. Whenever possible, chemicals shall be kept in closed containers and stored so they are not exposed to stormwater. b. Substances stored in tiers shall be stored in a manner to prevent sliding, falling, or collapse. c. Aisles and passageways shall be kept clear to provide safe and adequate movement of materials and employees for general and emergency passage. 2. Spill Kits. A proper spill kit must contain the appropriate supplies for materials that may be spilled. Supplies must be easily accessible when required, and considerations must be made for both the type and quantity of materials. a. All I.B. Abel locations and trucks will have the appropriate supplies for materials that may be spilled and will be easily accessible. b. I.B. Abel employees will be trained on the materials available for use, proper waste disposal and communication procedures. 3. Material Storage a. Materials shall not be stored within 6 feet of any interior floor opening or within 10 feet of any exterior opening unless a barrier capable of supporting the weight of the materials and at least equally as high as the pile is provided. b. Materials shall not be stored on scaffolds or runways that are in excess of what is needed for the immediate operation. c. Light or loose materials shall not be stored on rooftops or floors unless they are adequately secured or enclosed by a wall. d. All stairways and ladder areas shall be kept clear of debris. e. Lumber shall have all protruding nails removed, hammered in, or bent flush with the wood face. f. Stacking of materials shall be as follows: i. Brick stacks shall not exceed 7 feet in height or 4 feet for loose brick unless a taper of at least 2 inches in every foot is provided above 4 feet. ii. Masonry block stacks shall not exceed 6 feet unless a one half- block taper is provided for every tier above 6 feet. g. Propane shall not be stored within an enclosed building. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 229 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

4. Housekeeping a. Job sites and company property shall be kept in a clean orderly fashion i. Accumulation of waste materials shall be removed from the site daily and put in proper containers. ii. Dumpsters should not be overloaded (avoid compacting a full dumpster with equipment to prevent damage). b. Area where chemicals may be used or stored must be maintained using good housekeeping best management practices. This includes, but is not limited to, clean and organized storage, labeling, and secondary containment where necessary. c. Job site toilets shall be cleaned on a routine basis. d. Office trailers and vehicles shall be maintained in a clean orderly fashion to promote the company image. 5. Disposal of waste materials a. Materials that are being dropped 20 feet or more shall be contained with an enclosed debris chute. b. When debris is dropped to a lower level, the landing area shall be adequately taped off with danger tape and signs shall be posted. c. Disposal of waste materials by burning shall be properly permitted and shall follow all local fire regulations. d. All oily rags and flammable liquids shall be stored in proper fire-resistant containers until removed from the job site. e. All project waste, trash, and/or scrap materials will be taken into consideration before work begins. f. Employees will be made aware of the proper method to dispose of wastes. g. Employees shall use proper handling, organization, and storage of waste and scrap materials to ensure minimal potential impact to the environment. h. Waste will be divided accordingly for proper elimination and as per customer requests. 6. Communication a. Once the incident site is secured, the supervisor must contact the Safety & Quality Department and their foreman or PM immediately, and they will provide instruction at that time.

Safety Manual

Erosion and Sedimentation Control

1. General - The removal or disturbance of natural vegetation or topsoil exposes areas to accelerated erosion. Erosion is the detachment and displacement of soil particles by natural or manmade activity. Sedimentation is the travel and accumulation of sediment. Erosion and Sedimentation Control is the development and implementation of practices to minimize or eliminate soil erosion and the effects of sedimentation. 2. Erosion and Sedimentation Control Plans (E&S Plan) a. Required for projects disturbing over 5,000 s/f and all NPDES permitted projects. b. County Conservation District approval is required for NPDES permitted projects. c. Implement plan according to design description, drawings and details. 3. Best Management Practices – (BMP’s) BMP’s are calculated and tested facilities and procedures that have been proven to reduce the effects of erosion and sedimentation. The following items are standard facilities or practices commonly found on projects creating earth disturbance. a. All BMP’s must be inspected and maintained weekly and after every storm run-off event to ensure effective and efficient operation. b. Limit of Disturbance – (LOD) The LOD is the designated area in which all earth disturbance activity must reside on a given project. Activity outside the LOD is not authorized or permitted. c. Rock Construction Entrance – (RCE) The RCE is a designated point adjacent to a work zone where all vehicular traffic must enter or exit. RCE’s use loose, larger size aggregate to encourage remove mud from vehicle tires prior to the vehicle leaving the project and producing “track- out”. (The transportation of sediment onto unauthorized roadways by way of vehicle tires.) d. Perimeter Controls – Perimeter BMP’s are filtration products that filter, and release collected run-off along the down slope perimeter of the proposed work zone. All potential storm water run-off leaving areas of disturbance must be treated prior to leaving the site. i. Includes Silt Fence, Mulch Socks, Rock Filters, Vegetated Buffers, Inlet Protection, etc. e. Storm Water Collection & Treatment Facilities- Facilities designed to collect larger amounts of storm surface run-off water and release it at a

Safety Manual

slow, calculated rate to enable gravity and time to work together in settling out suspended solids before leaving the facility. i. Examples: Storm water Basins, and Traps ii. Maintain designed accessories for proper capacity and release rates. f. Soil Stabilization – Soil stabilization is the practice of protecting bare soils by providing a barrier or cover to reduce the effects of natural erosion. i. Examples: Temporary or Permanent Vegetation, Straw or Bark Mulches, Erosion Control Blankets, Compost or Synthetic Blankets, Aggregates, Geotextile/Plastic Coverings, etc. g. Water Pump Bags – Pump bags are geo-fabric bags made to collect and release sediment laden water discharged from a mechanical pump. Pump bags collect contain larger suspended solid particles while allowing cleaner water to pass through the material. i. Pump bags must be used for all water pumped from an active excavation. ii. Bag and contents must be removed and disposed of properly. 4. Fuel Storage – EPA requires secondary containment and a protective barrier around bulk fuel tanks placed on a construction site. a. Secondary Containment – Sealed containment system that is calculated to hold 110% of the maximum storage capacity if the tank(s). i. A doubled wall tank does not satisfy secondary containment requirements. b. Protection – Efforts must be made to protect accidental contact that would have the potential to damage or puncture the tank or its appendages. 5. Concrete Wash Out – Concrete wash water needs to be viewed as a potentially hazardous waste with intentional preparation and care given to its safe disposal. Until concrete wastewater solidifies it has the potential to pollute water sources with a “reactive” characteristic with the potential to cause severe irritation and burns. a. Follow EPA guidelines for concrete wash water disposal facility designs and maintenance. b. Once concrete wash water dries and solidifies it can be broken up and used for refreshing a Rock Construction Entrance or for clean fill. c. Check with concrete supplier to see if they provide wash water removal as a customer service. d. Temporary above ground wash-out bags are available for easy set-up and clean up. Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 232 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

Radio Frequency (RF) Radiation

1. Definitions a. Radio Frequency (RF). Radio waves and microwaves with frequencies on the electromagnetic spectrum between 3 kilohertz and 300 gigahertz b. Maximum Permissible Exposure (MPE). The threshold level established by the Federal Communications Commission (FCC) at which harmful biological effects may occur. MPE is frequency dependent and is defined in terms of field strength and in terms of power density (see Table 1). c. General Population/Uncontrolled Limits. RF exposure to the general public or workers who may not be fully aware of their exposure or who cannot exercise control over their exposure. d. Occupational/Controlled Limits. RF exposure to workers who are fully aware of their exposure and can exercise control over their exposure. 2. Health Hazards of RF Radiation a. The main effect of exposure to RF radiation is heating of body tissues. Effects of excessive RF exposure may also include confused behavior, dizziness, headaches, blurred vision, and warming of body parts. i. Prolonged exposure can result in an increase in body temperature. ii. Localized heating (hot spots) can cause tissue burns. Organs with poor heat control are most susceptible (eyes and testes) b. Shocks and burns can result from direct contact or arcs from RF transmitters. RF current can carry throughout other components of a communications tower, such as Safe Climbs and waveguide racks. Always use RF monitors at communications sites to check these areas. c. Reports on other biological effects from RF exposure (i.e. cancer, reproductive effects) have so far been inconclusive. 3. Initial Environmental Evaluation and Exposure Assessments. Prior to accessing towers, rooftops, or other transmitting sites, contact the site or building owner for information on RF exposure. a. FCC regulations require licensed transmitting facilities and operations to conduct an initial environmental evaluation. b. If this evaluation indicates possible exposures above the FCC limits, an exposure assessment must be conducted. c. Some RF sources that offer little potential for causing exposures in excess of the limits are considered “categorically excluded” and are not required to perform these valuations. 4. Protection from Radio Frequency Exposure a. Employees shall not enter areas where RF exposure levels are above the general population/uncontrolled MPE without proper training or appropriate control measures.

Safety Manual

b. Before employees work in areas on a communication tower where RF exposure levels exceed the occupational/controlled MPE values, one of the following control measures shall be instituted: i. Reduce the transmitter power to a level that ensures RF exposure levels in the areas to be worked will be below the occupational/controlled MPE. If power reduction is used as a control measure, a competent person shall lock and tag the transmitter at the reduced level. Ensure that any remote operation of the transmitter is properly disabled. ii. If the transmitter power level cannot be reduced and maintained at a level below the occupational/controlled MPE, the transmitter shall be locked and tagged out in accordance with procedures in the Control of Hazardous Energy section of this manual. Ensure that any remote operation of the transmitter is properly disabled. iii. If the transmitter power level cannot be reduced or locked and tagged out, other administrative controls shall be employed. c. Administrative Controls i. Personal Monitoring. Personal RF monitors should be worn by climbers likely to exceed the MPE, or when exposure levels are not known. Employees must leave the area promptly when alerted by the device. ii. Time Limits. Occupational exposures are based on a six-minute time weighted average. It is possible to exceed the MPE briefly, if the average exposure over six minutes is below the MPE (i.e. a worker can be exposed to two times the MPE for three minutes in any given six-minute period if there is no exposure for the three minutes before or after). iii. RF Protective Clothing. RF protective clothing can be worn to protect against RF exposure. RF protective clothing requires specialized training and may only be used for the RF field intensity and frequency range it was designed for. iv. RF signage descriptions such as blue signage means safe, yellow signage means caution and entry to only Occupational/ Controlled limits personnel, and red signage means danger and limited entry under MPE can be helpful, however RF monitors have priority over all other forms of documents and signage. Paperwork and signs can become outdated as additional antennas are installed, and field personnel should always investigate high RF monitor readings over information obtained by others. v. RF calculators such as that found at www.hintlink.com/power_density.php may be useful to assist field personnel in determining the safe working distance from a given

Safety Manual

antenna. The Safety Department shall be consulted whenever RF calculators alone are used to determine safe working distances. 5. Training. a. Anyone working in areas above occupational/controlled limits should receive periodic training on RF radiation. Training should include: i. Hazards of RF radiation ii. Monitoring equipment iii. Personal protective equipment iv. Exposure control measures

Safety Manual

Environmental Permit Requirements

1. Pre-Construction: Federal, State or Local environmental permits may be required depending on the size, location, environmental interests and activities on the project. Determine what, if any, permits may need issued prior to mobilization. a. Determine Environmental Permit Needs. i. NPDES: (National Pollution Discharge Elimination System) 1. Required if earth disturbance equals or is greater than 1 acre. (43,560 sq./ft.) ii. State GP: (General Permit) Water Obstruction & Encroachment General Permits 1. Required if activity comes in contact with or has the potential to affect regulated waters of the commonwealth. 2. Regulated Waters of the Commonwealth is defined as, “All watercourses, streams or bodies of water and their floodways wholly or partly within or forming part of the boundary of this Commonwealth.” iii. Army Corp of Engineers: 1. Required if activity will come in contact or adversely affect an established or delineated wetland. This permit will be issued in conjunction with a state GP permit. b. Permit Information: A permit is issued to a legal property owner or authorized facility operator who requests permission to conduct activities that will disturb existing environmental conditions. i. Request, review and save all permits issued for your project and activity. ii. Issued permittee holds primary responsibility and liability for permit requirements and conditions. iii. Issued permittee may transfer permit to a contractor or construction manager that has oversight or operational control of earth disturbance activities. iv. Some State NPDES programs require “Co-permittee” status for persons or contractors engaging in or overseeing earth disturbance activity on a NPDES permitted project. Consult the State specific program for permit requirements. 2. During Construction: a. Permit conditions require specified information to be kept on-site for immediate review by enforcement authorities or in some cases the general public.

Safety Manual

i. Permits: Issued permits, directives and conditions must be available. Some clients posted at project entrances. ii. Approved Plans: County or DEP approved Erosion and Sedimentation (E&S) Control plans and Post Construction Storm Management (PCSM) Plans designed to control potential discharges of sediment from the construction site. Plans must be on site and available for review at all times. iii. Preparedness, Prevention and Contingency (PPC) Plan: A written plan developed and implemented to control potential discharges of pollutants other than sediment into the waters of the Commonwealth. 1. Refer to IBA PPC Plan template. Site specific information must be filled in and plan completed for each permitted project. iv. Self-Inspection Reporting: Inspections are to visually confirm and document that the Best Management Practices (BMP’s) are installed and maintained properly, according to manufacturer specifications and State criteria. 1. WEEKLY: A site self-inspection is required at least once every seven days. 2. POST RUN-OFF EVENT: After every significant event that produces surface run-off (rain, snow melt, etc.) 3. Post Construction: At the conclusion of a contractual obligation, or once all earth disturbance has been permanently stabilized, a permit holder can request a Notice of Termination to be released from the permit’s requirements and liabilities. a. At least 70% uniform permanent perennial vegetation is required. b. Release must be acknowledged by the permitting authority. c. Long- Term Maintenance and Operations contact must be identified or delegated to continue routine and scheduled maintenance and inspections.

Safety Manual

Storm Water Pollution Prevention Plan

1. General: A Storm Water Pollution Prevention Plan – (SWPPP, also pronounced “SWPPP”) is a written document that addresses potential environmental concerns associated with collected storm water on a specified industrial or construction site that involves earth disturbance. 2. Elements of a SWPPP: Each SWPPP must include at least the following elements. a. Description of Activity – What is the overall purpose of the project? Specify the activities your company is involved with and the environmental impacts associated with that activity. b. Site Evaluation – Each SWPPP needs to identify potential environmental concerns that may exist through the construction or operation of the site. Evaluations include: i. Project / Site information including physical address ii. Receiving waters of storm water discharge. iii. Inventory of existing pollution sources and exposed materials. c. Contact Information – Each SWPPP needs to identify competent persons engaged in the construction, oversight and routine maintenance of the site and its storm water facility. Contact information should include company name, contact names and information. Also include the 24-hour emergency hotline number. d. Site Maps & Drawings – Storm water collection, treatment and release systems located on the property / project. i. Existing grading and characteristics of the site. (Boundaries, landmarks, streets, buildings, etc.) ii. Existing storm facilities: Drainage areas, Storm water conveyance systems, Outfalls, etc. iii. Designed Erosion and Sedimentation Control plans and Post- Construction Plans. iv. Regulated or Hazardous material storage locations, proposed maintenance areas, staging areas for materials and equipment, etc. e. Erosion and Sediment Controls – Documents supporting the construction activity and E&SC Plan is a vital part of any SWPPP. This information includes, but not limited to, permit requests, approvals and acknowledgements, E&SC Plan, Construction sequence, Best Management Practices associated with project, Details and calculations, and Maintenance Requirements. Off-site dump or borrow-site information should be included in the SWPPP. f. Pollution Prevention Standards – Identify and describe potential pollutant- generating activities or proposed storage areas on the site. For each pollutant- Safety Manual Approved by Corey Mensinger Date: 04.01.2020 Rev 4 238 I.B. Abel, Inc. – Confidential – All Rights Reserved

Safety Manual

generating activity an inventory of the pollutants must be documented within the PPC Plan. (Refer to the company PPC Plan for further instructions.) i. Pollutants to be considered: 1. Regulated and hazardous materials – Storage, protection, and disposal methods for each. Have MSDS information readily available. 2. Concrete, paint, stucco - wash out facilities and disposal methods. 3. Fuel or gas storage. – Storage, Protection, and Fueling and Maintenance of Equipment or vehicles 4. Solid Waste – Storage, disposal, and recycling efforts. ii. Specific Pollution Prevention Practices for each listed pollutant. g. Inspections and Corrective Action Plans – Self inspections are to be conducted and documented routinely on each site involving earth disturbance. i. NPDES requires weekly and post-run-off event inspections. ii. State mandated forms may be required for self-inspection documentation. Please check State permitting program in which your project resides. iii. Inspection documents must be saved for up to 5 years after the permit has been terminated. iv. State specific E&S training and certifications may be required to conduct E&S inspections or maintenance. Please check State permitting program in which your project resides. v. E&S maintenance activities should immediately respond to needed repairs identified in self-inspections. h. Training – It is essential for all personnel to be informed and understanding of the intention and operation of the SWPPP. i. Pre-construction meetings and explanations should be conducted for all personnel and sub-contractors to identify site specific SWPPP materials. ii. Weekly toolbox and safety talks are conducted to help remind and educate field personnel on site, the importance and intent of the SWPPP. iii. Annual “Erosion and Sedimentation” classes are also conducted to serve as reminders as well as share procedure and permitting updates.

Safety Manual

SAFETY MANUAL RECEIPT ACKNOWLEDGEMENT

On the date indicated below, I have been issued the I.B. Abel, Inc. Safety Manual electronically, to my personal email that has been supplied. If I would prefer a printed copy, I will indicate this to my foreman and they will email [email protected].

I have been issued the I.B. Abel, Inc. Safety Handbook. I must read and understand all of the policies and procedures contained in it. I understand that working safely is a condition of my employment at I.B. Abel, Inc.

I understand the information is provided for my referencing and use, and it’s my responsibility to familiarize myself and abide by the contents. The Company has the right to revise the information within the safety manual at any time, for any reason.

Updates to the I.B. Abel, Inc. Safety & Quality Manual will be

communicated via the Monday Morning Safety & Quality Topic as they

arise. All changes will be sent to the workforce within an Information Bulletin.

______Employee Signature

______Print Name

______Date Signed and Received

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CERTIFICATE OF RECEIPT I hereby acknowledge receipt of the employee information package containing material on drug and alcohol testing as required under Section 382.601 of the Federal Motor Carrier Safety Regulations. The package contains: 1. a policy on alcohol and drug abuse 2. the name of the person identified to answer questions 3. the categories of drivers’ subject to alcohol and drug testing 4. what constitutes "Safety-Sensitive" functions 5. an explanation of prohibited conduct 6. when a driver must be tested 7. testing procedures 8. testing programs 9. what constitutes refusal to submit to a test 10. consequences of positive tests and refusals to be tested 11. effects of alcohol and drugs on health, work and personal life 12. information on where to go for help I understand the safety regulations and procedures regarding the testing of drug and alcohol and I agree to follow the company policy. Name (print):______

Signature:______

Date:______To be kept on file by employer