comprehensive titan america safety and health reference manual ta safety and healt… · revised,...

Comprehensive Titan America

Safety and Health Reference Manual

Table of Contents

Section 1

CORPORATE PRINCIPLES AND POLICIES

1. Introduction to Safety and Health Manual………………………………………………..6

2. Top 10 Safety Principles………………………………………………………………….6

3. Safety Task Assessment STA Pledge……………………………………………………..6

4. Letter from CEO Aris Papadopoulos……………………………………………………..7

5. LOTO Letter from CEO Aris Papadopoulos……………………………………………..8

6. LOTO Policy Letter……………………………………………………………………….9

7. TITAN Group OHS Framework…………………………………………………………10

8. TITAN Group OHS Guidelines on Consequence Management…………………………12

9. Workplace Safety Inspections……………………………………………………………14

10. MSHA/OSHA/DOT Inspection Policies………………………………………………..15

Section 2

SAFE WORK OPERATIONS

A. Elevated Work

Fall Protection……………………………………………………………………..16

Floor, Wall and Roof Openings…………………………………………..16

Scaffolds………………………………………………………….............17

Ladders and Stairways………………………………………………….................17

Self-Propelled Aerial Lifts……………………………………………...............…18

Prerequisites……………………………………………………………....18

Inspections………………………………………………………………..18

Work Practices……………………………………………………………19

Training…………………………………………………………………...20

Definitions…………………………………………………………….......20

B. Mechanical Equipment and Power Tools

Portable and Powered Hand Tools………………………………………………...20

Compressed Air Tools……………………………………………………………..21

Equipment Operations……………………………………………………………..21

C. Equipment Maintenance and Repairs……………………………………………………22

Revised, September 30, 2011 of 170

D. Confined Spaces Program

Identification of Confined Space Operations………………………………………22

Entry Procedures to Confined Spaces………………………………………...........22

Atmospheric Testing………………………………………………….....................22

Rescue……………………………………………………………………...............23

Training………………………………………………………………….................23

Definitions…………………………………………………………………………23

E. Energized Equipment – Lockout/Tagout

Lockout/Tagout/Blockout Devices………………………………………………...23

Group Lock Boxes…………………………………………………………............24

Contractors……………………………………………………………....................24

Training and Communications…………………………………………………….24

Monitoring and Enforcement………………………………………………………24

Removal of Safety Locks…………………………………………………………..24

Definitions…………………………………………………………………………24

F. Electrical—Ground, Test, Train

Installation………………………………………………………………………….25

Grounding………………………………………………………………………..…25

Temporary Wiring………………………………………………………………….26

Test Records………………………………………………………………………..27

Overloads and Disconnects………………………………………………………...27

Don’t Overlook…………………………………………………………………….27

Training…………………………………………………………………………….28

Monitoring and Enforcement………………………………………………………28

G. Materials, Fuels and Supplies

Safe Storage and Handling………………………………………………………....28

Procedures…………………………………………………………………28

Storage and Control of Flammable Materials……………………………..28

Fire Prevention and Protection……………………………………………………..29

Flammable and Combustible Liquids………………………………………………29

Temporary Heating Devices………………………………………………………..29

Definitions………………………………………………………………………….29

H. Loaders, Forklifts and Cranes

Equipment Operations……………………………………………………………...30

Mobile Equipment Maintenance and Repairs……………………………………...30

Crane Safety Programs…………………………………………..............................31

Mobile Cranes…………………………………………………………...…31

Overhead Cranes…………………………………………………………...32

Mandatory Lifting and Hoisting Procedures…………………………..................…32

Safety Basics……………………………………………………………….32

Employee Safety……………………………………………………………33

Hand Signals………………………………………………………………..33

Suspended Loads…………………………………………………………...33

Clearances…………………………………………………………………..33

Bin Block Safety………………………………………………………………….....33

Definitions………………………………………………………………….33

Manufacturing of Bin Blocks……………………………………………….35

Lifting and Handling of Bin Blocks……………………………………...…36

Mandatory Lifting and Hoisting – Building Bin Block Walls……………...37


Safety First…………………………………………………………………..39

Wire Rope Slings……………………………………………………………40

Alloy Chain Slings…………………………………………………………..40

Nylon Slings…………………………………………………………………41

Training………………………………………………………………………………41

Inspection and Testing……………………………………………………….42

Excessive Temperatures……………………………………………………..43

I. Excavation, Trenching, Blasting and Underground Work

Underground and Overhead Utilities…………………………………………………43

Work Practices………………………………………………………………………..43

Excavation Protective Systems……………………………………………………….44

Sloping and Benching………………………………………………………...........…44

Records and Files…………………………………………………………..................44

Definitions…………………………………………………………………………….44

Section 3

OCCUPATIONAL HEALTH AND INDUSTRIAL HYGIENE

A. Identifying and Reducing Potential Hazards

Elements………………………………………………………………………………45

Hazard Analysis……………………………………………………………………....45

Exposure Monitoring…………………………………………………………………46

Control Measures……………………………………………………………………..46

Periodic Reviews……………………………………………………………………...46

Training……………………………………………………………………………….46

B. Program Processes

Hazard Communications……………………………………………………….......…46

Material Safety Data Sheets…………………………………………………………..47

Labeling……………………………………………………………………………….47

Definitions…………………………………………………………………………….47

Hearing Conservation…………………………………………………………………48

Noise Control…………………………………………………………………48

Hearing Conservation Program………………………………………………48

Records……………………………………………………………………….48

Notification…………………………………………………………………...48

Heat Stress Guidelines………………………………………………………………...48

Heat Stress Program………………………………………………………….48

Causal Factors………………………………………………………………..49

First Aid………………………………………………………………………49

Definitions……………………………………………………………………49

Personal Protective Equipment…………………………………………….............….49

Radiation (Ionizing) Program…………………………………………………………49

Sources……………………………………………………………………….49

Radiation Safety Officers…………………………………………………….49

Definitions……………………………………………………………………50

Respiratory Protection………………………………………………………………...50

Written Program……………………………………………………………...50

Exposure Assessment………………………………………………………...50

Voluntary Use of Dust Masks………………………………………………..50

Medical Certification…………………………………………………………51


Fit Testing…………………………………………………………………….51

Respiratory Protection Training………………………………………………51

Maintenance…………………………………………………………………..51

Definitions…………………………………………………………………....51

Blood Borne Pathogens…………………………………………………………….…52

Pathogen Control Plan……………………………………………………..…52

Definitions……………………………………………………………………53

Crystalline Silica………………………………………………………………………54

Definitions………………………………………………………………….…54

Asbestos………………………………………………………………………………..54

Assessing Exposure…………………………………………………………...54

Medical Evaluations…………………………………………………………..55

Definitions…………………………………………………………………….55

Lead……………………………………………………………………………………56

Assessing Exposure…………………………………………………………...56

Medical Evaluations…………………………………………………………..56

Definitions…………………………………………………………………….57

Hexavalent Chromium and Contractors……………………………………………….57

Requirements………………………………………………………………….57

Determining Chromium in Paint………………………………………………58

Work Areas……………………………………………………………………58

Engineering Controls………………………………………………………….58

Chemical Cleaning…………………………………………………………….58

Power Tools……………………………………………………………………59

Disposal………………………………………………………………………..59

Definitions……………………………………………………………………..59

Welding, Cutting and Heating………………………………………………………….60

Typical Hazards………………………………………………………………..60

Engineering Controls…………………………………………………………..60

Respiratory Protection……………………………………………………........60

Section 4

SAFETY RECORDKEEPING AND ADMINISTRATION

Method of Investigating Serious Incidents..………….…………………………………………60

Supervisor’s Incident Investigation Report.………….…………………………………………62

Definitions……………………………………………....……………………………………....62

Process…………………………………………………………………………………………..63

Records Retention…………………...……………………….………………………………….63

Policy Provisions………………………………………………………………………………..64

Safety Records Files…………………………………………………………………………….65

Section 5

SAFETY AND HEALTH TRAINING

New Employee Orientation………………………………………………………….………….66

Safety Meetings…………………………………………………………………………………67

Safety Task Assessment Program………………………………………………………………67

STA Process……………………………………………………………………………67

STA Implementation……………………………………………………………….......67


Promoting Safety……………………………………………………………………….68

Follow-up……………………………………………………………………………….68

Section 6

INTRA-PLANT RAIL SWITCHING PROCEDURES

Responsibility…………………………………………………………………………………...68

Definitions……………………………………………………………………………….……...68

Authorized Equipment and Team Members……………………………………………………69

Equipment Preparation…………………………………………………………………69

Radio Communications………………………………………………………………...69

Operating Switches…………………………………………………………………….69

Safe Movement – Responsibility and Teamwork……………………………………………....69

Loadout Switching……………………………………………………………………….......…70

Coupling, Uncoupling and Chocking…………………………………………………………...70

Mounting and Dismounting Moving Vehicles………………………………………………….71

Operating in Severe Weather…………………………………………………………………...71

Safety and Training……………………………………………………………………………..71

APPENDIX

Incident Reporting Procedure…………………………………………………………………...72

Roanoke Cement Outage Best Practice………………………………………………………....73

Sampling Paint to Determine Chromium Content………………………………………………74

Chemical Inventory Form……………………………………………………………………….75

Confined Space Entry Form……………………………………………………………………..76

Permit-Required Confined Space Reclassification Form………………………………………..77

Hot Work Permit…………………………………………………………………………………79

Crane Inspection Form……………………………………………………………………………80

Hepatitis B Vaccine Declination Form…………………………………………………………..81

Lockout/Tagout Inspection Form………………………………………………………………..81

PPE Hazard Assessment Form…………………………………………………………………..82

SOMA Medical Standards Program……………………………………………………………..82

Miscellaneous Safety Documents and Forms……………………………………………………82

Letter of Thanks to Michael T. Heenan, Esq.………………………………………………….....83

Safety and Health at Mines, A Manual for Operators and Contractors, 2nd

Edition……………..84


Section 1

INTRODUCTION TO SAFETY AND HEALTH MANUAL

Titan America values the health of every employee and seeks to ensure that our work is

performed safely. The principles in this manual do not cover every situation, but they help

establish and maintain an incident-free workplace. Key points are:

1. Policies and practices are based on proven principles, not solely on OSHA, MSHA or

other regulations. Many policies and procedures exceed minimum regulation

standards.

2. All locations will have safety procedures with guidance specific to those sites, along

with necessary forms.

3. We will distribute updates as needed. Revision of these materials requires the written

permission of the Director of Corporate Safety and Health.

4. Titan America takes safety very seriously and considers everyone responsible for safe

procedures. Any violation of our safety procedures is subject to disciplinary action up

to and including termination.

5. All visitors to Titan facilities will receive site-specific safety training or will be

escorted by a Titan employee at all times while on Titan property.

Top 10 Safety Principles

1. Everyone is responsible and accountable for safety.

2. Working safely is a condition of employment.

3 Everyone is responsible for stopping any unsafe activity, regardless of position or tenure.

4. Each employee must be constantly aware that safety takes priority over cost or production.

5. Superior safety results from following proven rules, practices and techniques.

6. All incidents are preventable.

7. Safety on the job, and off the job, depends on decisions you make.

8. Unsafe conditions must be reported immediately.

9. Safety training is a critical on-going process.

10. The only acceptable goal is “Zero Incidents.”

Safety Task Assessment Program Pledge

“I pledge that when assigning any task to any employee or group of employees, as a Titan

America supervisor, I will give sufficient instruction to provide adequate safety in that operation.”


Safety is a Priority at Titan America

Since its founding over 100 years ago, Titan has been an industry leader in employee

safety. Titan facilities consistently rank among the best in our industry in safety training and

accident prevention. I believe this comes from a dynamic Safety Culture that goes beyond policies

and procedures.

Titan America wants every employee to participate and become involved in the overall

Safety efforts of their work place. Indeed, we encourage employees to feel responsible not only for

their Safety, but for the Safety of their co-workers as well. That type of involvement spreads

control of our Safety program to everyone and encourages employee ownership. It also forges

partnerships that can make Titan America’s Safety Culture the best in the business.

We want to overcome the perception that Safety must stand aside in some situations to

achieve production goals. I’d like a level of partnership whereby any employee feels comfortable

approaching anyone else at Titan America—including this CEO—to mention a Safety concern.

This Safety manual is not intended to be all-inclusive. No manual can cover all possible

contingencies. However, this manual does serve as a guideline and the use of electronic

publication and links to important sources help keep it current. Because even MSHA and OSHA

requirements don’t cover every situation, Titan America policies exceed federal standards in many

cases. We will maintain site-specific procedures and materials at individual locations and will

provide the forms necessary to comply with appropriate regulatory requirements. As needed, we

will update this manual to keep abreast of our changing needs as our company grows.

Titan America wants every employee to end their workday as healthy as they started it. We

continue to support the enduring values established when we opened for business in 1902. They

include being sensitive to social responsibility, respecting the environment, and supporting a Safe

work place for its staff and their families.

Sincerely,

Aris Papadopoulos, CEO

Titan America


TITAN POLICY

MANDATORY LOCK OUT REQUIREMENTS FOR

EMPLOYEE SAFETY

Background

Every year hundreds of workers die or are seriously injured because they did not lock out

the equipment they were going to work on. The National Safety Council reports over a thousand

amputations and other serious injuries each year due to employees being caught when machinery

starts unexpectedly without employee locks in place to prevent accidental start up.

In mining and petroleum, forty individuals died last year under circumstances where

proper lock-out could have prevented their deaths. Electrocutions for failure to lock out equipment

prior to electrical work are equally threatening. Federal law wisely prohibits anyone from working

on machinery and electrical equipment without placing their personal locks on to prevent

activation or motion while work is being done.

Titan wants every employee to go home safe and sound every day. No employee should

suffer injury for failure to put a personal lock on a power source prior to work. No assignment is

important enough to forgo this step. A simple act of getting on a conveyor belt, for example, could

cost you your life. It has happened too many times to too many workers.

Mandatory Investigative and Disciplinary Procedures

Failure to follow proper lock-out procedures will result in disciplinary action, up to and

including discharge. Upon observing or learning of a violation, supervision will immediately

suspend the employee or employees suspected of being involved. Supervision, in consultation

with the Safety Department, will conduct a detailed investigation to determine if in fact procedures

were violated. If a violation is confirmed, disciplinary action will be determined. If the

investigation concludes that proper procedures were in fact followed, the employee or employees

will be returned to work and paid for lost time.

No excuse will be accepted because an excuse will never give you your arm or leg back.

BE SAFE—BE SECURE IN YOUR JOB—LOCK OUT ALWAYS


TITAN Group OH&S Framework

Vision and Policy

To achieve the Vision of a healthy work environment free of Incidents. Injuries and

Accidents,

1. Needless to say, we comply with local legislation and all directives related to Health

and Safety at work.

2. We are committed to do our best to safeguard the OH&S of all our direct and indirect

employees in all activities where we have management control.

3. We aim at continuous improvement of our OH&S performance by managing it as our

top Business Priority.

4. We manage OH&S as an integrated system of goals, with clear responsibilities and

accountabilities.

5. We continuously strive to embed safe and sound behavior throughout the organization

in our everyday activities and to create an environment in which everyone and all of

us are responsible for our own and our colleagues' safety.

6. All employees are expected to follow safe-work practices, obey rules and regulations

and work in a manner that upholds the high safety standards developed and endorsed

by the Group.

7. We use our influence to the best of our ability to persuade our suppliers, contractors

and third parties to adopt similar OH&S policy.

8. We willingly engage with stakeholders and third parties who may seek our advice.

Goals

We benchmark our safety performance within the global heavy building material sector

and aim to be in the top quartile.

ZERO fatalities

ZERO serious accidents

Role of Group OH&S Function

1. In cooperation with Regions, develop OH&S Programs and Tools as required.

2. Provide OH&S advice to Group and Regional Executives.

3. Facilitate OH&S information and knowledge sharing between Regions.

4. Develop, in collaboration with the Regions, common terminology and definitions to

be used for Group reporting.


5. Satisfy reporting needs vis-à-vis Group OH&S Council and Group external reporting

requirements.

6. In collaboration with Business Regions, participate in investigating serious accidents

and conducting special audits.

7. Represent Group in external organizations that are not part of any Region’s scope.

8. Act as secretary to Group OH&S Council.

Role of Regional OH&S Functions

Regional OH&S Strategies and Programs will incorporate all elements of the Group

OH&S Framework.

1. Compliance with all legislation, regulations, Group standards and commitments.

2. An integrated approach to OH&S that encompasses vision, strategy, culture

improvement, visible leadership, performance management and accountability,

resource planning, training, employee development, internal & external

communications, acquisitions, capital investments and continuous improvement.

3. Where local legislation does not provide a recognized framework, an OH&S

Management System will be adopted such as OHSAS 18001, or equivalent, that is

compatible with the Group OH&S Management System.

4. Training programs for employees and programs to encourage awareness-building for

all third-party members present at our facilities.

5. Procedures for selecting personnel physically capable of safely performing job tasks,

consistent with local legislation and regulation.

6. A process of assuring that contractors possess a reasonable level of commitment to

safety and have the appropriate training in OH&S.

7. Procedures for incorporating Safety into engineering designs, construction plans and

maintenance programs.

8. A continuous communications program at multiple employee levels and through

multiple channels, that is regularly refreshed with employee suggestions.

9. Systems for the proper recording, classification, investigation and reporting of safety

incidents and near misses, that also meet Group reporting requirements and lead to

continuous improvement.

10. Systems that recognize and reward OH&S performance and provide consequence

management for OH&S violations.

11. A process for assessing, discussing and agreeing on Safety risks and controls amongst

the involved personnel prior to commencing a work shift and non-routine task.


12. Periodic internal and external OH&S audits to monitor progress and ensure that Group

and Regional OH&S objectives are being met.

13. Under the Group Framework, Regional OH&S Strategies and Programs are adapted to

individual regulatory, legal and social environments, activity mixes and different

stages of Safety culture development, which can lead to diversity in implementation.

Charter of the TITAN Group OH&S COUNCIL

Has the primary responsibility to steer the Titan Group towards attaining the Vision of an

incident-free and healthy working environment by :

1. Demonstrating and promoting visible Leadership and Commitment to Occupational

Health and Safety.

2. Establishing and ensuring implementation of the Group Vision, Policies and

Framework related to Occupational Health and Safety.

3. Approving and monitoring at a high level Regional OH&S Strategies and Programs.

4. Setting and monitoring Group-wide OH&S goals and associated KPIs.

5. Reviewing the Group’s Occupational Health and Safety Management System.

6. Reviewing investigations of serious incidents.

7. Facilitating the communication, understanding and sharing of information and

knowledge between Regional Executives and Group OH&S.

8. Taking any and every initiative it deems necessary to achieve its goal.

TITAN Group Guidelines on OH&S Consequence Management

1. Scope and Field

Each BU must have a SYSTEM that recognizes and rewards OH&S performance and provides

for consequences in the case of OH&S violations. The BU OH&S Consequence Management

system must be in alignment with the demands of the local legislation and must incorporate, at

a minimum, the following key principles:

All employees are part of the same reward and recognition as well as consequence

system.

All employees are well aware and fully understand the requirements of the system.

Every employee is responsible for his/her actions and accountable to follow the

requirements of the system.


Safe performance is a condition of employment for all.

2. Management Responsibilities

All BU Line Managers must ensure that all employees understand and can relate to their

OH&S Consequence Management System.

Management is accountable for OH&S performance.

Management must demonstrate commitment and support for OH&S performance

through recognition.

Management is accountable for training employees and engaging in dialogue over

goals and performance related to OH&S.

3. Recognition System (Promotions, Awards, Appraisals, Bonuses)

OH&S performance must be taken seriously into consideration when promotion of an

employee is considered. Good OH&S performance must aid promotion and poor

OH&S performance must block it.

Individual as well as team awards against qualified gains for excellent performance in

OH&S must be incorporated in the system.

Annual performance appraisals should have an OH&S component.

Reward systems should have a meaningful component based on SMART goals related

to individual performance.

The weighting accorded to OH&S performance may vary according to the position of the

individual.

4. Addressing Inadequate Performance

The BUs Consequence Management System must incorporate Don’ts rules communicated to

each employee. Violation of such a rule could result in negative consequences up to the level

of termination. The escalation of such negative consequences will depend on the following

factors:

a. The person’s attitude history on safety;

b. The severity of the violation; and

c. The local labor and legal environment

A list of basic safety requirements should be maintained and all employees should understand

that breaching these requirements could result in disciplinary action.

An indicative list of such basic safety requirements is as follows:

Direct or willful condoning of violations of OH&S procedures.

Failure to follow LOTO (Lock Out/ Tag Out) procedure.


Failure to follow Confined Space procedure.

Intentional overriding of an interlock.

Failure to follow Fall Protection procedure.

Reckless actions that could lead to endangerment of self and others.

Carrying or use of Weapons, Alcohol and Drugs.

Breaking Fire Control procedure.

Direct insubordination or assault.

Note: Within procedures “breaching these requirements” means acting in a way that ignores

“must”, “will” and “shall” in the relevant procedures.

5. Contractors Evaluation

A provision for contractors’ evaluation on OH&S performance providing for consequences on

poor performance must be incorporated into the system.

6. BU Consequence Management System Training, Communication and Renewal Process

BU Management must ensure that their Consequence Management System is fully

understood by each new employee.

The system must be reviewed every three years by the BU OH&S department.

The system must be re-communicated to all employees on renewal.

Workplace Safety Inspections

Titan America establishes minimum requirements for workplace inspections of facilities, plants,

equipment and vehicles to comply with governmental regulatory requirements (MSHA, OSHA,

DOT, etc.) and company policies.

A safe and healthful working environment requires many eyes to identify hazards, document them

and correct them. Titan America’s policies apply to all employees without exception. Detailed

procedures are available from Safety Managers.

It is the goal in Titan America to have all senior managers periodically walk the facilities, speaking

with employees, with the goal of enhancing Safety awareness (Safety Walks).

Biannual Inspections/Audits:

1. Safety managers will perform a minimum of two (2) plant safety inspections per

facility per year within their areas of responsibility. When available, management

representative(s) will participate.

2. Results will be distributed to the plant manager, supervisor and appropriate senior

management.

3. Production/operations managers shall resolve unsafe conditions noted during

inspection, on a timetable agreed to by the responsible manager and the safety

manager. As appropriate, issues not resolved at the first level will be escalated by the

safety manager.


Monthly Inspections/Audits:

1. Supervisors/managers, their designee, or safety committee members will inspect their

plant(s) monthly using approved forms to record results, and shall submit monthly

inspection reports to the Safety Manager.

2. Within their authority, plant supervisors/managers shall resolve unsafe conditions

noted during inspection. Issues outside their authority, once controlled, will be

forwarded to management with appropriate authority.

Daily Inspections/Safety Walks: 1. Supervisors shall perform and document (where applicable) a daily inspection in each

work area.

2. Employees shall inspect their workplace, equipment and vehicles at the start and end

of each shift, per government and Titan America requirements.

a. Pre-shift reports shall be turned in before using related equipment. Post-shift

reports (where applicable) will be turned in before end-of-shift.

b. Supervisors will review these reports. Unsafe equipment will be tagged and

removed from service until repairs are made.

MSHA/ OSHA/ DOT Inspection Policies

Compliance

Titan America and its subsidiaries cooperate fully with government agencies that enforce safety

regulations, and work with authorized representatives who visit Titan properties on safety matters.

Titan supports workplace safety regulations and, by policy, expects all employees to help comply

with health and safety standards.

To avoid disruption, inspectors and compliance officers will follow proper procedures for visiting

Titan America facilities.

Employee procedures for all federally regulated units of Titan America, without exception:

1. Notify the appropriate Senior Manager and Safety Manager. If unavailable, proceed

courteously.

2. Ask for the inspector’s identification. Write down name and office information. Retain it

in your files.

3. Ask the reason for inspection. If an “employee complaint,” request the copy he is required

to provide.

a. Except for employee interviews, stay with inspector at all times and make note of

his activities.

b. If he has a camera, you should, too. If he takes a photo, you should, too.

c. Do not demonstrate, or allow demonstration of, equipment that is not operational.

4. When the inspector leaves, write a memo ASAP to document activities, conversations, the

time, date, duration and purpose of the inspection, etc.

All managers and supervisors are responsible for compliance with this policy. Safety Managers

must ensure that managers and supervisors are aware of pertinent federal regulations and Titan

America inspection procedures. Report to Human Resources any non-compliance with this policy.


Section 2

SAFE WORK OPERATIONS

Effective safety programs address hazards found every day. Every person at every job site

must comply with all applicable laws and regulations. If additional safety information is required,

contact the Safety and Health Department.

A. ELEVATED WORK

Fall Protection Each location in Titan America must perform a fall protection assessment.

Injury prevention requires that any personnel on Titan property who are on a horizontal or

vertical surface with an unprotected side or edge that poses a significant fall hazard shall be

protected from falling. Affected employees will be trained to recognize fall hazards and properly

use protection systems. Before each use, they will visually inspect such devices for damage or

defect.

Titan requires an approved safety harness with a double locking lanyard that attaches to

existing permanent structures or anchorage points. The only exception is the use of ladders.

1. Before each use, check lanyards for damage or defect. Replace if necessary.

2. Secure lanyards to designated anchor points capable of withstanding 5,000 pounds

minimum per person.

3. Use horizontal or parallel lifelines meeting OSHA regulations (see link below), with

continuous fall protection when other protection is unavailable.

4. All elevated work platforms should be fully decked with handrails, midrails and toe

boards.

5. Employees working at heights will be secured by full-body harnesses and lanyards. When

employees cannot safely tie-off, they cannot work at heights until lifelines or other means

of protection are in place.

6. Body belts can only be used as a positioning device.

See: www.msha.gov 56.15005 and www.osha.gov 1910.66 App C.

Floor, Wall and Roof Openings

Openings should be protected in one of the following ways:

1. Rigid guardrails of 2" x 4" lumber, 2" x 2" x 1/4" angle, or 1 ½" pipe or equivalent

supported by a post on 8-foot centers with toe boards at least four (4) inches high.

Guardrails shall be capable of withstanding a force of at least 200 pounds applied within

two (2) inches of the top edge, in any outward or downward direction, at any point along

the top edge.

http://www.msha.gov/30cfr/56.15005.htm

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9730


2. Cable guardrail and mid-rail of at least ½ inch cable with toe boards. Guardrail and mid-

rail cable shall meet the minimum requirement of 5,000 lbs. breaking strength, per

employee.

3. Floor openings should be covered with a minimum of braced 3/4" plywood or other

material that can withstand at least twice the anticipated load. The covering should overlap

all edges at least three (3) inches and be firmly secured against easy movement. All

coverings should be labeled "HOLE" or barricaded.

See: www.msha.gov 56.11012 or www.osha.gov 1910.66 App C.

Scaffolds

Use scaffolds for work that cannot be done safely with ladders or mobile platforms. Scaffold

design and installation shall be secure and resist settling or displacement under the maximum

intended load. That load must not be exceeded. All decking must be approved scaffold grade and

secured to its frame. Scaffolds shall be free of debris.

1. Inspect all scaffolds and ladders before use. Damaged scaffolds shall be tagged, repaired

immediately and not used until repairs are complete.

2. Before each shift, a competent person must inspect and tag scaffolds as meeting all

requirements.

3. Fall protection, such as retractable reels or rope grabs, is required on uncaged scaffold

ladders when user cannot maintain three (3) points of contact.

4. Toe boards and protective netting are required between the top-rail and toe board when

employees are moving underneath.

5. Use ladders, gangways or stairs for safe access. Climbing scaffold bucks or cross-braces is

prohibited.

Employees working on scaffolds must work behind properly constructed guard rails or must

be secured with full-body harnesses and be tied-off at all times to a support that can withstand a

force of 5,000 pounds per person.

See: www.msha.gov 56.11027 or www.osha.gov 1910.28.

Ladders and Stairways Titan America uses fiberglass ladders only. All ladders shall be inspected before use and

maintained in safe condition and securely stored when not in use. Damaged ladders shall be

removed from service and destroyed.

1. Fall protection is required when using uncaged ladders and extension ladders when user

cannot maintain three (3) points of contact.

2. Step spacing on fixed or portable ladders shall not exceed one (1) foot.

3. Job-built portable ladders, or those built “on site,” are not permitted.






4. Use extension ladders with 4-to-1 rules: One foot out for every four feet up.

5. Step ladders shall be less than 20 feet long.

6. Straight ladders shall be less than 30 feet long and extension ladders less than 60 feet long.

Both shall use non-slip (safety cleat) feet.

7. Fixed ladders shall have landing platforms for every 30 feet of height, and personnel cages

shall be provided on those exceeding 20 feet starting at 7 feet above the work platform.

8. Fixed ladders shall be securely anchored to the structure, must bear expected loads and

must resist expected exposure.

See: www.msha.gov 56.11003 - 11026 or www.osha.gov 1910.27.

Self-Propelled Aerial Lifts

Safe operation of self-propelled aerial lifts (man-lifts, boom lifts and scissor lifts) involves

compliance with 29 CFR 1926.453.

Prerequisites

1. Only qualified personnel shall operate a self-propelled aerial lift, and only if trained on the

specific brand and model in use.

2. Instruction and warning placards and load chart shall be conspicuously displayed and

legible on the lift. The operator’s manual shall be readily available.

3. Never exceed a manufacturer’s recommended working load limit.

4. No more than two people shall occupy the platform at any time.

Inspections: Perform and document:

1. Preshift inspections will be performed by operators per manufacturer recommendations. If

operators change prior to the end of the shift, another inspection must be performed.

2. Post incident examinations will be performed by authorized personnel immediately after

an incident.

a. Before use, a qualified person shall inspect the lift using manufacturer guidelines and

immediately report defects to the supervisor. Defective equipment shall be removed

from service and not used until repaired or documented that repairs are unnecessary

for safe use.

b. The supervisor shall verify that inspection is complete, ensure any deficiencies are

repaired, and file the completed inspection form.

c. Repairs or modifications shall meet manufacturer specifications.

d. Authorized operators shall test each control every day before use and ensure the lift

controls/functions are clearly marked.





Work Practices: Before using a self-propelled aerial lift, operators shall:

1. Assure that controls and functions are plainly marked.

2. Inspect the machine and work area daily before starting.

3. Restrict platform to the authorized operator only while the lift is traveling, except for

training and/or operator certification.

4. Use a walking observer whenever operator's view is obstructed while traveling.

5. Lower boom below horizontal when traveling and use “Slow” mode over rough terrain.

6. Use “Slow” mode for any positioning while platform is elevated.

7. Traveling while hoisted in a scissor lift is not recommended (prohibited in some areas),

and is permitted only on level paved surfaces at speeds less than one mile per hour.

8. Maintain safe clearances when moving or extending boom or outriggers.

9. Shut off all power before leaving machine and before any maintenance.

10. Assure that the work area is level, stable and unlikely to cause tipping.

11. Do not remove, block, disable or modify the foot switch.

12. Before lifting personnel, fully extend outriggers and axles, if available.

13. Use an observer to ensure proper clearance when in congested areas or with restricted

visibility.

14. All platform occupants shall wear approved fall arrest harnesses with lanyards attached to

the specified platform attachment point. Do not attach fall arrest equipment to any part of

a building or structure while working in the platform.

15. If employee transfers to the structure, use a double lanyard procedure.

16. Operators will not use the lift for material transport, except for small supplies. All items

must fit inside the workbasket. Do not exceed the manufacturer’s load rating for

personnel, tools and supplies.

17. Personnel shall stand on the platform floor, not on boxes, planks, railings, or other

devices.

18. Aerial lifts shall not be operated near electrical power lines or energized equipment unless

the lines have been de-energized or adequate minimum clearance is maintained in

accordance with the following (excerpted from 29 CFR 1926.1408(h)).

Voltage Range Minimum Separation Distance

Less than 50kV 10 feet

50K to 200kV 15 feet

200KV to 350kV 20 feet






Except in emergencies, do not use ground controls to operate an occupied lift.

Training

A Titan America-approved curriculum will be used to train and qualify employees as operators

of self-propelled aerial lifts. Training shall use classroom lectures, discussions and videos specific

to the equipment being used, provided from the manufacturer, trade association or rental agency.

Training will include a written evaluation and a proficiency demonstration. All training shall be

documented and kept in safety files at designated locations.

Prospective operators unable to perform proficiently shall not operate aerial lifts unless

accompanied by a qualified operator. Until trainees demonstrate sufficient skills, they remain "in

training."

Retraining is required when there is an incident, a near miss or when an operator is observed

being reckless or careless. New training is required for extendable axles, articulated booms or

models different from those the operator is qualified to operate. A proficiency demonstration also

is required for models new to the operator.

Definitions

Aerial Lifts include self-propelled aerial lift devices used to elevate personnel, such as (1)

extendable boom platforms, (2) aerial ladders, (3) articulating boom platforms and (4)

combinations of the above.

See: www.osha.gov 1910.67.

B. MECHANICAL EQUIPMENT AND POWER TOOLS

Portable and Powered Hand Tools

Only qualified personnel shall operate powered hand tools, and the following procedures will

apply:

1. All hand tools shall be inspected for safe operation. Defective tools shall be removed from

service.

2. Use all guards supplied by the manufacturer or required by Titan America.

3. Powered hand tools shall have a constant pressure switch that allows turn-on/turn-off with

the same finger.

4. MSHA regulated facilities will not use locking mechanisms on powered hand tools.

Definitions

"Powered hand tools" include electric, hydraulic, pneumatic, percussion devices or

accessories.

"Qualified Personnel" are those with the necessary experience.






Compressed Air Tools

1. Compressed air shall not be used for cleaning unless fitted with a reducer that meets

OSHA regulations.

2. Workers will ensure that hose connections are secure and properly rated.

3. Bleed lines before disconnecting at compressors.

4. Never replace compressed air with oxygen or other gases.

5. Keep tools in good condition. Take defective tools out of service and tag for repair.

6. All hoses and fittings shall be appropriately rated and sized (hose clamps are not permitted

on air lines).

7. All Chicago-style fittings must be pinned when connected.


Equipment Operations:

Protect employees from the hazards of mobile equipment.

1. Only properly trained and qualified personnel shall operate mobile equipment.

Unauthorized use of mobile equipment will be cause for disciplinary action.

2. Each operator is responsible for inspecting equipment before use for safe operation.

Operators shall keep equipment (including fire extinguishers) in safe condition and assure

that backup alarms, seat belts and other required safety devices function properly. Report

defects to a supervisor immediately.

3. Employees shall obey all safety-warning signs, speed limits and other signs. Machinery,

valves or electric switches shall not be used until determined safe to do so with Lock-Out/

Tag-Out policies and all appropriate regulations.

4. Work Practices:

a. Equipment shall not be adjusted, repaired, lubricated or fueled while in motion or

plugged into an electrical outlet.

b. All equipment, crane and concrete pump booms shall be kept at least ten (10) feet

from telephone poles or power lines energized up to 125,000 volts. A Power Line

Proximity Permit will be completed before a crane movement near power lines. Safe

distances are greater around higher voltage lines or during bad weather—15 feet for

125,000-250,000 and 20 feet for over 250,000 volts.

c. Backing up “blind” is prohibited.

d. Riding on equipment without approved seats and belts is prohibited.

e. Loader buckets shall not be used as work platforms.

f. Heavy equipment has right-of-way in all plants.

See: www.msha.gov 56.14105 or www.osha.gov 1910.178 and 1910.180.







C. EQUIPMENT MAINTENANCE AND REPAIRS

1. No work will be performed under equipment supported by jacks or hoists without

protective blocking.

2. If work must be performed under suspended equipment, the equipment will be safely

blocked or cribbed.

3. To clean parts, use approved solvents and personal protective equipment.

4. Service to lock-ring tires must be performed by outside vendors.

5. Before working on any equipment, verify that all energized parts are locked out, the key is

out of the ignition, and controls have been properly tagged.

Refer to the Lockout/Tagout (Control of Hazardous energy) Section of this manual for additional

information.

D. CONFINED SPACES PROGRAM

Safety Managers will maintain entry and training procedures to minimize the impact of volatile,

toxic or engulfment materials in confined spaces. Procedures will cover:

1. Identification and labeling of confined spaces and related operations;

2. Entry procedures, including ventilation and control of engulfment materials;

3. Requirements for atmospheric testing of confined spaces;

4. Rescue procedures;

5. Training of those required to enter confined spaces.

6. Reclassification of a permit-required confined space to a non-permit required confined

space.

Identification of Confined Space Operations: Supervisors shall identify operations that require

entry into confined spaces for routine, emergency or other procedures. They must contact a Safety

Manager before entry to any confined space.

Entry Procedures To Confined Spaces will include permitting and authorizing entry and work.

The permit shall:

1. Identify operational work space, authorized persons and special precautions;

2. Identify the period for which the permit is valid;

3. Identify such entry requirements as ventilation, vessel isolation, communications,

atmospheric condition maintenance and monitoring, and personal protective and extraction

equipment required.

4. Be valid upon completion of a non-routine task STA.

Entry Procedure for a Non-Permit Confined Space will include completion of the Permit

Required Confined Space Reclassification Form by the Safety Department.

NOTE: Introducing hazards (i.e. welding, cutting, electrical components) will automatically

mandate an entry permit.

Atmospheric Testing: Atmospheric testing will be performed before entry into permitted confined

spaces and during operations. Trained personnel with appropriate equipment will evaluate:

1. Oxygen deficiency and/or enrichment;

2. Airborne flammable or combustible dust, vapors or gas;


3. Presence of toxic gas or vapor.

Rescue capability will be available for each entry. Identify rescue personnel, personal protective

equipment needed for rescue and extraction and retrieval equipment, which shall be in place before

entry.

Training: Affected employees will be trained in:

1. Identification of site-specific confined space operations and hazards;

2. Methods for evaluating atmospheric safety inside the space and its impact;

3. Communication procedures in confined spaces;

4. Entry and extraction procedures;

5. Review of rescue procedures at that site.

All contractors shall have confined space programs that meet or exceed Titan America standards.

Definitions:

“Attendant” – Trained individuals who remain outside spaces to monitor conditions.

“Authorized Entrant” – A trained individual authorized to enter the space.

“Confined Space” – A potentially hazardous space with limited openings, large enough to enter

but not intended for continuous occupancy.

“Entry” – Passing through an opening into a confined space.

“Extraction and Retrieval Equipment” – Fixed or portable equipment for removing someone.

“Personal Protective Equipment” – Clothing or other gear that protects users from injury by

chemical or other hazards, e.g. gloves, face shields, safety glasses, respirators, ear plugs, steel-toed

shoes, chemical aprons or gowns, hard hats, safety harnesses and belts.


The above are minimum requirements. For additional safety measures, consult the Titan America

Safety Department.

E. ENERGIZED EQUIPMENT – Lockout / Tagout

Unintended release of energy is hazardous. These requirements, related training and

inspections apply to all Titan America employees.

Written Programs: Each site will use a documented program to control hazardous energy,

including:

1. Isolating all hazardous energy sources at the site.

2. Installation, servicing and use of equipment associated with hazardous energy.

3. Clearing jams and other tasks that involve risk.

4. Using Lockout/Tagout energy isolation devices.

5. Blockout/Tagout procedures must be used when warranted.

6. Use of Tagout only when Lockout is physically impossible.

7. Group lockout procedures and multi-shift tasks.

8. Removing Lockout/Tagout when the employee who applied them is unavailable.



Lockout, Tagout and Blockout devices will be given to employees who perform work that

requires them. Only employees so assigned will have keys to the locks. Only authorized

personnel may remove Lockout, Blockout or Tagout devices.

Group lock boxes enable safe conditions when multiple people are working on the same

equipment.

Contractors at the site are required to use energy control procedures compatible with Titan

America’s program.

Training and Communication. All employees who perform work that may involve hazardous

energy must be given training that includes:

1. Information identifying known sources of hazardous energy;

2. How to identify those sources;

3. Use of isolation devices, their limitations and removal;

4. Relevant parts of the contractor’s hazardous energy program (when applicable).

5. Retraining if there is a change in assignment, equipment, process, hazards, or management

discretion.

Monitoring and enforcement is the responsibility of the manager or designee. A person who fails

to lockout/tagout before performing maintenance or repair, or one who removes another’s lock

without authorization, will be subject to disciplinary action up to discharge.

Removal of Safety Locks is the responsibility of the shift supervisor, who will follow these

procedures when a safety lock is on equipment that needs to be started.

1. Thoroughly check the plant to locate the lock’s owner, who shall remove it.

2. If necessary, the supervisor will contact the lock owner’s supervisor (day or night) for help

in locating the owner.

3. The shift supervisor will call the owner’s home or other location.

4. The owner will return to the plant and remove the lock, without pay.

5. If the lock owner refuses to return, the shift supervisor will note the refusal. On return to

work, the owner will report to the plant manager and review lockout procedures.

6. The supervisor will contact the Safety Director (day or night) to report the problem.

7. If the lock’s owner cannot be found within a reasonable time, the supervisor will

thoroughly inspect the machinery and related equipment. If certain that the lock owner is

unavailable, the shift supervisor will cut the lock.

Definitions

Authorized Personnel – A supervisor or designee who locks-out or tags-out equipment to service

or maintain it.

Blockout – Placing an unlockable barrier on equipment to prevent injury.

Energy Isolation Device – A device that physically prevents release of energy.

Hazardous Energy – Electrical, mechanical, hydraulic, pneumatic, chemical, thermal,

gravitational and rotational forces that may cause injury.

Inspection – Independent review to correct inadequate application of a program.


Lockout – Locking a device on equipment to prevent its operation or its unexpected release of

energy.

Tagout – Securely attaching a distinctive warning tag to (1) equipment or controls warning against

its operation and/or (2) to safety devices warning against their removal.


Sample forms for this section appear in the Appendix.

F. ELECTRICAL – Ground, Test, Train

Installation and use of electrical equipment shall comply with all appropriate MSHA and OSHA

standards.

See: www.msha.gov 56.12001 - 12071 and www.osha.gov

1910.302 Electric Utilization Systems

1910.303 General Requirements

1910.304 Wiring Design and Protection

1910.305 Wiring Methods, Components and Equipment for General Use

1910.306 Specific Purpose Equipment and Installations

1910.308 Special Systems

1910.332 Training

1910.333 Selection and Use of Work Practices

1910.334 Use of Equipment

1910.335 Safeguards for Personnel Protection

1926 K Electrical

Routinely inspect equipment for suitability based on type, size, rating and the effects of heat or

arcing under load. Per OSHA Part 1910.304, permanent visible labels shall show manufacturer’s

name, voltage, wattage and other specifications. Use of equipment must match those

specifications. Also:

1. Unused openings (knockouts) or fittings and enclosures like switches, receptacles, and

junction boxes shall be closed with proper covers.

2. Raceways and enclosures shall be securely fastened.

For work on or near electrical equipment, guard or enclose energized components and provide safe

access, space and lighting:

1. De-energize electrical gear and circuits using procedures established for lockout/tagout in

this manual.

2. Only qualified persons shall work on or test electric circuits and equipment.

3. Turn OFF disconnect switches before replacing fuses.

4. No employee shall work alone on lines or equipment energized over 600 volts.


Grounding:

A. Conductors shall be color-coded (MSHA-regulated facilities). Grounded conductors shall

be marked differently.

B. Ground metal cable trays, raceways and enclosures.

C. Ground exposed metal parts that could accidentally be energized if the equipment is:














http://www.osha.gov/Publications/Const_Res_Man/1926sub-k-overview.html






1. within 8 vertical feet or 5 horizontal feet of ground, or grounded objects, and is subject

to employee contact,

2. in a wet or damp environment,

3. in electrical contact with metal,

4. energized by wires inside metal cladding, sheathing or grounded raceway,

5. operated with a terminal at over 150 volts to ground, except:

a. switch and breaker enclosures accessible by qualified persons only and not used

for service equipment,

b. metal frames of electrically-heated appliances permanently insulated from ground,

or

c. transformer/capacitor cases on wood poles at heights 8 feet or more above grade.

D. Ground metal parts of equipment supplied by cord and plug unless:

1. current arrives through an isolating transformer with an ungrounded secondary of not

more than 50 volts, and

2. the tool is doubled-insulated and so marked.

E. Ground metal parts of:

1. frames and tracks of electrically operated cranes, and

2. metal enclosures on equipment with over 750 volts between conductors.

F. Grounding conductors for non-energized metal parts shall run with power conductors in

the same conduit, or shall be the conduit.

G. MSHA-regulated facilities will be required to conduct annual ground continuity tests,

maintaining records and complying with color coding requirements.

See: www.msha.gov 56.12023, 56.12025, and 56.12026, or www.osha.gov 1910.304 for circuits

and equipment.

Temporary Wiring and related equipment.

Before every shift, visually inspect cords, plugs and receptacles. They must have a grounding

conductor. Their use shall meet specifications of the National Electrical Manufacturers

Association (NEMA). Conductors and equipment shall be protected against loads greater than

their rating, per the National Electrical Code (NEC). Double insulated tools require no grounding.

A. Do not substitute flexible cable for fixed/permanent wiring, except for

1. Pendants, fixtures and portable appliances

2. Wiring of cranes or hoists that require flexibility

3. Connecting stationary equipment that often moves

4. Prevention of vibration that harms fixed wiring

5. Appliances with connections removable for maintenance

6. Approved data processing cables and surge protectors

B. Where otherwise allowed, flexible cables shall not:

1. Be concealed behind nor run through holes in, walls, ceilings, floors, etc.

2. Run through doorways, windows, etc.

3. Attach to surfaces with staples, nails or similar fasteners.

C. Supervisors shall ensure that cord sets are plugged into properly wired receptacles, and

that receptacle testers are used to determine correct connections.

D. Test polarity and continuity of the grounding conductor on temporary wiring and

connected equipment:

1. Before first use and after repairs,

2. Before use after possible damage

3. Tests apply to equipment owned by Titan America.

4. At the work site, record and file test results.

a. Identify safe wiring/fixtures with a log and colored (not black) tape.






b. Show the date of the last test and the tape color used for that cycle.

c. Use different colors for successive cycles. See the “Electrical Equipment Test

Documentation Form” (or “Form #xx”) in the Appendix.

d. Remove and repair unsafe equipment.

Test Records: Supervisors shall require that:

1. Tests are recorded, logged, color-coded and maintained until updated.

2. Records are available on-site for inspection by OSHA/MSHA and company personnel.

3. Equipment not in compliance is out of service until repaired or corrected.

Titan America’s annual coding system uses tape/ties of alternating colors to show compliance,

performance and expiration dates.


Overloads and Disconnects

A. Motors shall have clearly visible disconnect switches that indicate OFF (open) and ON

(closed) positions. For branch circuits exceeding 600 volts, disconnects need not be visible

by controllers.

B. Motors, controls and branch circuit conductors shall be protected against overheating due

to overload (or failure to start), against short circuits and against ground faults.

C. Prevent accidental contact with energized parts of motors or controllers operating at 50

volts or more by installing such devices:

1. In an enclosure accessible only by qualified persons

2. On a surface elevated and designed to exclude unqualified persons

3. Eight (8) or more feet above the floor

D. Transformer installations shall display warnings that note operating voltage of exposed

energized parts.

1. Use vaults to restrain access to—and contain fire hazards at—indoor installations

of oil-insulated and dry-type high fire point liquid-insulated and askarel-insulated

transformers.

a. Vault doors must allow opening from inside.

b. Do not store materials in vaults, nor allow pipes/ducts to enter.

c. Protect against oil-insulated transformers spreading fire to adjacent areas.

E. Equip capacitors with discharge devices that activate when circuit is de-energized.

F. Use Ground Fault Circuit Interrupters (GFCIs) to protect all outlets, portable equipment

and 15 or 20 amp circuits (120v AC) on construction, demolition, alterations or

excavations.

G. All switches, disconnects, and panels shall be clearly labeled as to what circuit is

controlled.

H. Any voltage over 250 volts must be labeled “Danger High Voltage Keep Out”.

Don’t Overlook 1. Portable equipment and flexible cords used in damp/wet conditions must be approved for

those conditions.

2. Beware sources that produce electric arcs—store no flammables within 25 feet.

3. Use non-conductive ladders. Titan America uses fiberglass ladders only.

4. Conductive jewelry and clothing shall not be worn when working around energized

equipment.

5. Use personal protective equipment when working near electrical hazards.




6. Use insulated tools near electrical equipment. Metallic measuring tapes and ropes with

woven metallic thread are prohibited.

7. As required, use accident prevention signs and symbols, barricades and attendants to warn

of electrical hazards.

Training

Titan America provides periodic classes on working safely around electricity. Employees

whose work may expose them to electric shock shall be trained as required by MSHA/OSHA (see

link below). Completion of such training is part of Titan America’s New Employee Safety

Orientation Program and shall address:

1. Job duties, safe work practices, and techniques for identifying exposed energized

equipment.

See: www.osha.gov 1910.331, 1910.332, 1910.333, 1910.334, and 1910.335.

Monitoring and Enforcement

Supervisors are responsible for implementing and enforcing this policy. Employees who

fail to follow safe procedures, or fail to use proper personal protection, may face disciplinary

action up to and including termination.

G. MATERIALS, FUELS AND SUPPLIES

Safe Storage and Handling

Procedures: Supervisors shall ensure that:

1. Stored materials will be stacked, racked, blocked, interlocked, or otherwise secured to

prevent sliding, falling, or collapsing.

2. Excess materials will not restrict foot or vehicular traffic.

3. Height and weight limitations will apply when stacking and storing.

4. Oxygen and acetylene bottles will be stored upright on racks or platforms.

5. Oxygen cylinders will be separated from fuel-gas cylinders or other combustibles

(especially oil or grease) by no less than 20 feet or by a noncombustible barrier at least 5

feet high having a fire-resistance rating of at least one-half hour. The storage area shall be

a safe distance from the work area.

6. Backflow preventer shall be used on all hoses and lines at the gauges or manifolds.

7. Flashback arrestors shall be installed on all torch handles.

Storage and Control of Flammable Material: Supervisors shall require:

1. Adequate ventilation to prevent accumulation of explosive vapors above 10% of the lower

explosive limit.

2. Vapors maintained below the maximum allowable concentration.

3. Controls on spark-producing devices in and near storage areas.

4. Use of appropriate Personal Protective Equipment.

5. Appropriate smoking prohibition “No Smoking – No Open Flames within 50 feet”.

6. Marking and labeling of containers.

7. Grounding to prevent ignition from static electricity, and

8. Adequate rules, controls and equipment for refueling vehicles.

See: www.msha.gov 56.4430, 56.4531 and 56.16003, or www.osha.gov 1910.176.











Fire Prevention and Protection

All Titan America facilities will use programs that address Fire Prevention, Fire Protection and

requirements for use of LP-gas and Temporary Heating Devices.

Fires and extinguishing agents involve four kinds of combustibles:

1. Class A: Paper, wood, fabric, some rubbers and plastics

2. Class B: Liquids, gases, grease, some rubbers and plastics

3. Class C: Energized electrical equipment—extinguish with nonconductive agents

4. Class D: Combustible metals

Fire Prevention a first priority.

1. Keep exits, fire extinguishers and sprinkling systems free of obstruction.

2. Smoking is prohibited less than 50 feet from flammable or combustible materials.

Fire Protection: Equipment will be selected, and its use will follow, standards of the National Fire

Protection Association, Underwriters' Laboratories, Inc. and related regulations.

1. Use a posted emergency number and fire alarm system to alert employees and fire

officials.

2. Before using open flames (welding, etc.) deploy appropriate fire protection equipment.

Flammable and Combustible Liquids: Each site will store flammable liquids and combustibles in

approved containers. Storage will be minimized. Containers will be closed when not in use.

1. Storage containers and locations will be marked to identify contents and danger. Locations

will permit access by delivery equipment/personnel but not impede exits, stairs or normal

passageways.

2. Indoor storage will meet applicable MSHA/OSHA/NFPA restrictions on volume and other

applicable codes and ordinances.

3. Dispensing, transfer, handling, storage and use of flammable liquids in containers or pipe

systems shall not allow accidental release of the contents.

4. Storage containers, piping, valves, regulating and other equipment shall be accessible but

protected from damage and tampering.

5. Tank trucks containing fuel shall comply with the Standard for Tank Vehicles for

Flammable and Combustible Liquids.

6. Where flammable vapors are present, eliminate or control ignition sources.

7. Locate suitable fire control devices where flammable liquids are stored.

8. Obtain licenses or permits for storage and handling of chemicals before activity.

9. Provide bonding and grounding systems when dispensing flammable liquids.

Temporary Heating Devices: shall comply with the National Fire Protection Association Code

and, along with motors and other ignition sources, shall be approved by Underwriters'

Laboratories, Inc.

Fire Extinguisher Maintenance: All portable fire extinguishers must be inspected on a daily,

monthly, and annual basis.

a. Daily: Employees note that fire extinguishers are in designated areas and charged,

ready for use.

b. Monthly: Fire extinguishers are visually inspected and the results documented.

c. Annually: Fire extinguishers are serviced by a third party licensed contractor and the

results documented.


Definitions:

Liquefied Petroleum Gas or "LP Gas" or "LPG" contains such hydrocarbons as propane,

propylene, butane (normal butane or iso-butane) and butylene (including isomers). Liquefied

Petroleum gas must conform to standards located in NFPA No. 58, 1974.

Flammable Liquids have a flash point below 140 degrees F, and a vapor pressure not exceeding

40 pounds per square inch (absolute) at 100 degrees F.

Combustible Liquids have a flash point at or above 140 degrees and below 200 degrees.

See: www.msha.gov 56.16003, 56.16004 and 56.16005, or www.osha.gov 1910 Subpart L,

www.osha.gov 1910.157, 1910.164 and 1910.165.

H. LOADERS, FORKLIFTS AND CRANES

Supervisors will ensure proper training, available resources, safe procedures, monitoring,

enforcement of policies and record keeping. Programs at each site will cover this equipment,

related devices, rigging, operating limitations and restrictions, surface conditions and probable

loads. Training will comply with and be documented per appropriate MSHA and OSHA

regulations.

Equipment Operations:

Protect employees from the hazards of mobile equipment.

5. Only properly trained and qualified personnel shall operate mobile equipment.

6. Each operator is responsible for inspecting equipment before use for safe operation.

Operators shall keep equipment (including fire extinguishers) in safe condition and assure

that backup alarms, seat belts and other required safety devices function properly. Report

defects to a supervisor immediately.

7. Employees shall obey all safety-warning signs, speed limits and other signs.

8. Work Practices:

g. Mobile equipment shall not be adjusted, repaired, lubricated or fueled while in motion

or plugged into an electrical outlet.

h. All equipment, crane and concrete pump booms shall be kept at least ten (10) feet

from telephone poles or power lines energized up to 50,000 volts. Safe distances are

greater around higher voltage lines or during bad weather—15 feet for 50,000-200,000

and 20 feet for 200,000-350,000 volts.

i. Backing up “blind” is prohibited.

j. Riding on equipment without approved seats and belts is prohibited.

k. Loader buckets shall not be used as work platforms.

l. Heavy equipment has right-of-way in all plants.


Mobile Equipment Maintenance And Repairs












6. No work will be performed under equipment supported by jacks or hoists without

protective blocking.

7. If work must be performed under equipment, the equipment will be safely blocked or

cribbed.

8. To clean parts, use approved solvents and personal protective equipment.

9. Service to lock-ring tires must be performed by outside vendors.

10. Before working on any equipment, verify that all energized parts are locked out

(disconnect battery cables), the key is out of the ignition, and controls have been properly

tagged.

Refer to the Lockout/Tagout (Control of Hazardous energy) Section of this manual for additional

information.

Crane Safety Programs at each site will cover use of mobile and overhead cranes, related devices

and rigging. Inspections and documentation shall be complete and include repair results, if any.

Mobile Cranes – Truck-Mounted and Crawler.

1. Prior to initial use, a new or altered crane will be tested for safe use of hoisting, lowering,

swinging travel mechanisms and safety devices.

2. Prior to initial use, any new or altered crane will be load tested, not to exceed 110 percent of

its rating, and results filed.

3. Pre-operational inspections shall be completed per checklist and documented by each

operator before use by that operator.

4. Frequent inspections shall be completed per checklist and documented by the operator or

other competent person per manufacturer schedule, but at least monthly.

5. Periodic inspections shall be completed per checklist and documented by a competent

person per manufacturer schedule, but at least annually.

6. Daily inspection records and documents shall be kept at the job site.

7. Equipment found defective shall be tagged and removed from service until repaired by

qualified persons using manufacturer specifications.

8. Welding repairs to booms and other components shall be done by a certified welder and

supervised by the manufacturer or its designee.

9. Titan America’s preventive maintenance program is based on manufacturer

recommendations. Before adjustments or repairs begin:

10. Place the crane where it causes the least interference with other operations.

11. Place controls in the “Off” position.


12. Mark power sources and controls “Do Not Operate” as defined in Titan America’s

Lockout/Tagout program.

13. Following repair, do not operate the crane until re-configured for safe use.

14. Do not operate mobile cranes with insufficient counterweight. Counterweights may not

exceed manufacturer specifications.

Overhead Cranes – Cab Operated and Floor Operated

1. Inspection of wire rope (running or otherwise) shall be done by the operator or other

qualified person and results detailed on the proper form.

2. Prior to initial use a new or altered crane will be tested for safe hoisting, lowering, trolley

and bridge travel, limit switches, locking and safety devices. Overhead cranes shall be

load tested, not to exceed 125 percent of its rating unless recommended by the

manufacturer. Reports shall be filed and available.

3. Pre-operational inspections shall be completed per checklist and documented by each

operator before use by that operator.

4. Frequent inspections shall be completed per checklist and documented by the operator or

other competent person per manufacturer schedule, but at least monthly.

5. Periodic inspections shall be completed per checklist and documented by a competent

person per manufacturer schedule, but at least annually.

6. Equipment found defective shall be tagged and removed from service until repaired by

qualified persons using manufacturer’s specifications.

7. Welding repairs to booms and other components shall be done by a certified welder and

supervised by the manufacturer or its designee.

8. Titan America’s preventive maintenance program is based on manufacturer’s

recommendations. Before adjustments or repairs begin:

a. Place crane where it causes the least interference with other operations.

b. Place controls in the “Off” position

c. Mark power sources and controls “Do Not Operate” as defined in Titan America’s

Lockout/Tagout program.

d. Use rail stops or other means to prevent interference with other cranes.

9. Following repair do not operate the crane until re-configured for safe use.

10. Cranes that contact high voltage or lightning fail under load or have structural or

mechanical damage shall be tagged and removed from service until inspected and repaired

by qualified, certified personnel.

11. Never use damaged or un-repairable rigging for overhead lifting.


Mandatory Lifting and Hoisting Procedures – Mobile and Overhead Cranes

Safety Basics: The Supervisor or designee shall plan and discuss critical lifts with affected

employees. Only trained, competent personnel will rig loads and operate cranes. Load capacities,

rigging and components shall be clearly marked and visible. Crane-specific and securely fastened

load charts shall be visible to operators in cabs of all mobile cranes. Never exceed recommended

safe loads. All safety devices shall be functional. Barricades shall prevent access to the swing area

of the counterweight.

Employee Safety: Employees shall not work or travel on the bridge of an overhead crane not

equipped with proper travelways, toe boards and handrails. Personnel shall not ride or be hoisted

except in devices designed for and in compliance with regulations. Such devices shall be load

tested, equipped with anti-two-block and auto-shut-down gear, and equipped for anti-free-fall

controlled lowering.

Hand Signals: ANSI-standard hand signals shall be posted on mobile cranes, and in work areas

for overhead cranes, and shall be used for all lifts. Except for emergency stop, all hand signals

shall come from one qualified person.

Suspended loads: Personnel shall stay clear of suspended loads. Use of taglines or positioning

poles to steady or guide loads is required.

Clearances: Do not operate cranes closer than 10 feet of overhead power lines rated 50 kV or

below. For wires rated higher, minimum clearance shall be 10 feet plus 0.4 inches for each one (1)

kV over 50, or twice the length of the line insulator, but never less than 10 feet.

A crane in-transit with lowered boom and no load shall maintain minimum clearances of four

(4) feet for voltages less than 50 kV, 10-feet for voltages between 50 and 340 kV, and 16 feet for

voltages up to 750 kV.

To move or operate cranes within 10 feet of high voltage lines, de-energize the lines or take

other precautions.

See: www.msha.gov 56.19000 Subpart R or www.osha.gov 1910.179.

Bin Block Safety

Purpose – To establish requirements and procedures for the safe manufacture, lifting and handling,

and of building bin block walls in Titan America facilities.

Responsibility – Operating unit managers, e.g., General Managers are responsible for ensuring all

elements of this program are followed and that employees who manufacture, handle, or are tasked

to build bin block walls are trained as outlined in this program. It is also the responsibility of the

operating unit manager to ensure necessary resources are available to facilitate this program and

that all safe operating procedures are followed.

Definitions

Bin Block – A concrete block, made from excess concrete by pouring concrete into a block form.

Used in the construction of retaining walls for aggregates.

Blank Out - An insert placed into the top of the mold to allow lifting lug to lay inside top V with

no concrete around it.




Block Form – A ten gauge steel (or equivalent) form used for making concrete bin blocks Three

molds will be used, Full, Half, and Corner molds.

Block Storing – The location and method in which the bin blocks can be stored or staged.

Boom Truck – A rotating superstructure with power plant, operating machinery and boom, which

is mounted on an automotive truck equipped with a power plant for travel. Its function is to hoist

and swing loads at various radii.

Clearance – The distance from any part of the crane to a point of the nearest obstruction.

Competent Person – A person designated by the operations manager to be responsible for critical

lifting operations. Must have current training and significant experience on all aspects of bin block

building.

Crane – A machine for lifting and lowering a load and moving it horizontally, with the hoisting

mechanism an integral part of the machine. Cranes (whether fixed or mobile) are driven manually

or by power.

Curing Time – The amount of time a block is required to cure prior to movement or use. The

curing time will be met when the block reaches 2000 psi. The strength will be determined using a

Swiss hammer test apparatus in strict accordance with ASTM C-805 “Standard Test Method for

Rebound Number of Hardened Concrete” and ACI 228.1R “In-Place Methods to Estimate

Compressive Strength”. Chapter 4 of ACI 228.1R; Section 4.2.5.1 presents a procedure for

establishing the relationship between a particular test devise and the measured compressive

strength of standard specimens or cores.

Excavator – A track or rubber tire excavator used for earth moving, which can be used for

movement of bin block.

Frequent Inspection – A thorough inspection of all critical components of a crane, performed by

an operator or other qualified person on a monthly basis.

Hitch – The device rigged to the load for the purpose of lifting the load. The hitch is the entire

device from the lifting eye or lifting device hook to the load.

Jib – An extension attached to the boom point to provide added boom length for lifting specified

loads. The jib may be in line with the boom or offset to various angles.

Lifting Eye – The lifting point on the wheel loader where the hitch (lifting sling) is attached. The

lifting eye MUST be that specified by the Safety Department purchased through our designated

supplier and attached on loader per the manufactures specifications.

Lifting Lugs – The rebar that is inserted into the form for lifting the bin block. Rebar to be used is

#5, 5/8 inch rebar pre-cut and pre-bent by supplier. Note specifications.

Load Ratings – Crane and rigging ratings in pounds established by the manufacturer of equipment

and rigging devices.

Multiple Pour – The process of pouring into the mold in increments at different times of the day

or on different days. NO MULTIPLE POURS ARE ALLOWED IN BLOCK FORMING.


Periodic Inspection – A complete inspection of all critical components of a crane, performed by

an independent certified inspector, contracted on an annual basis.

Pre-operation Inspection – A visual inspection of a crane, or wheel loader performed by an

operator, prior to the use of the machine by that operator.

Rigging – The devices used in the process of lifting the bin blocks for moving, stacking, or

building retaining walls.

Rope – Wire rope, unless otherwise specified.

Slings An assembly designed to connect a load to be lifted to a lifting device.

Swing – The rotation of the superstructure for movement of loads in a horizontal direction about

the axis of rotation.

Qualified personnel – Employees that have successfully completed Titan America’s Bin Block

training program.

Wheel Loader – A rubber tired loader used in Titan facilities for moving aggregate materials,

loading of bins, and the moving and lifting of bin blocks and other production related materials.

Manufacturing of Bin Blocks

1. The forms used in Bin Block manufacturing must be the Interlocking Block forms made

by Leonard Marr Inc. or equivalent. They will be either pinning locking or latch type and

all locking devices must be working properly prior to forming. The forms will be of 10

gauge steel with ¾ inch pins.

2. A blank out must be used in the forming of bin blocks. The #5 Grade 60 rebar must be

placed into the blank out and place the ends of the rebar in the corners above the V. In a

corner block, two lifting lugs will be placed in the mold as per manufacturer specifications

(see illustration). The rebar must be pre-cut and pre-bent from the supplier. Titan

employees shall not cut or bend rebar used for lifting bin blocks.


3. The bin blocks must be formed on a smooth flat surface. The area must be capable of

holding the bin blocks during curing time. The top of the mold must be smooth.

4. A corner block must be used at all corner locations. This will tie the walls together and

ensure the wall structure.

5. Half blocks must be used in areas around corners and other areas to fill in gaps. Under no

circumstances may the interlocking groove be removed by grinding or chipping off. Full

Molds cannot be modified. Use a half block where necessary.

6. All Bin Blocks must be poured full at one time. No multiple pours shall occur. No cold

joints are allowed.

7. Bin block forms may be modified to allow movement with bucket fork attachments on a

wheel loader or with a forklift. Block modification must be approved by the Safety

Department prior to implementation. Wheel loader and forklift load ratings must not be

exceeded.

8. Curing time for bin blocks will be determined by QC department. Once a bin block has

been poured, QC will be notified by the plant supervisor. QC will use a Swiss hammer test

to determine blocks have met minimum strength requirements which is 2000 psi. Bin

blocks shall not be moved or lifted until curing time has been met. If a bin block does not

meet 2000 psi within 28 days the block must be destroyed. Plant personnel will use a large

permanent marker to identify block consisting of plant number followed by 0001 for the

first block made and in sequence following with each additional block. I.e. for Daytona the

number would be DA0001 for the first block. The block number will then be entered into

the bin block log sheet with the date the block was poured (log sheet attached). QC

technicians will be responsible for performing the Swiss hammer test on the bin blocks


and to verify the bin blocks have been tested. QC will mark the bin block with “OK by

QC” with the date verified on the block. The log sheet will be the responsibility of the

Plant Supervisor. The Plant Supervisor will be responsible for maintaining the bin block

log sheet and for compliance of this procedure by plant personnel assigned to their plant.

The Operations Managers are responsible for ensuring compliance of this procedure by

Plant Supervisors and by plant personnel under their direction. The Safety Managers are

responsible for inspecting for compliance of this procedure during their quarterly

inspections.

9. Bin blocks must be stored on a flat surface and stacked no more than three high.

Lifting and Handling of Bin Blocks

Equipment

1. Wheel Loader w/ Lifting Eye attached

2. Wheel Loader w/ Material handling Arm attachment

3. Mobile Crane, Boom Truck, or Excavator

4. Wheel Loader w/ Fork Lift attachment

5. Fork Lift

Rigging

1. Shackles – 5/8 inch shackles will be used.

2. Wire Rope Slings – A single leg wire rope sling will be used for lifting bin blocks. Two

slings for corner block.

3. Grade 80 Alloy Chain Slings/Lifting chains

4. All slings MUST have permanently affixed identification tags stating size, grade, rated

capacity, and reach. If tags are missing sling is out of service. Two approved slings must

be used when handling corner block.

5. Rigging for any type of lifting must be approved by the Safety department prior to doing

any lifting not specified by this procedure.

6. All cranes, hoisting and lifting devices and rigging found to have safety defects as a result

of an inspection, shall be tagged and taken out of service until such time as qualified

personnel can make repairs.

7. Only qualified persons, in accordance with the manufacturer’s recommendations, using

manufacturer-specified parts, shall make safety repairs or alterations to cranes or hoisting

and lifting devices. All repairs and/or alterations shall be tested and documented by

qualified personnel prior to a crane or hoisting and lifting device being placed into service.

8. A certified welder, under the supervision of the crane manufacturer or its designated

representative, shall complete welding repairs to crane booms or other structural

components.

9. A preventive maintenance program based on the crane manufacturer's recommendations

shall be established at each site where cranes are located or based.

10. No damaged and irreparable rigging shall be used for overhead lifting purposes.

Mandatory Lifting and Hoisting Procedures – Building Bin Block Walls

Moving Bin Blocks with Wheel Loader

1. Bin blocks will be moved using the lifting device (slings) specified by the Safety

department.

2. The slings will be attached to the lifting eye on the top of the wheel loader bucket.


3. The wheel loader bucket must be kept in the forward position at all times during the lifting

process. DO NOT ALLOW THE LEADING EDGE OF THE BUCKET TO COME IN

CONTACT WITH ANY LIFTING DEVICE.

4. Keep the load as close to the ground as possible during movement.

5. Ensure all personnel are clear prior to lifting any load. Do not lift any load over top of any

personnel. Ensure path of movement is clear prior to beginning lift.

6. Use a tag line or positioning pole to stabilize or reposition load. STAY CLEAR OF LOAD

DURING THIS PROCESS.

7. If ground man is used during movement he must stay in sight of the wheel loader operator

at all times. If ground man goes out of view of operator, operator must stop until ground

man is back in sight.

8. Bin blocks may be stacked three (3) high using a wheel loader. If stacking over three high

is necessary, Safety Department approval and additional equipment will be required.

* Caterpillar 936 is limited to two (2) high.

Lifting Bin Blocks using a Wheel Loader with attachment.


department.

2. The slings will be attached to the lifting eye on the attachment of the wheel loader.

3. Keep the load as close to the ground as possible during movement.





6. If ground man is used during movement he must stay in sight of the wheel loader operator

at all times. If ground man goes out of view of operator, operator must stop until ground

man is back in sight.

7. Only authorized personnel that have been trained specific to moving bin block walls may

be tasked to move bin blocks.

Lifting Bin Blocks using a Boom Truck/Mobile Crane/Track Excavator.


department.

2. The slings will be attached to the Boom truck/Crane hook or Track excavator lifting eye.





5. If ground man is used during movement he must stay in sight of the boom truck/crane

operator at all times. If ground man goes out of view of operator, operator must stop until

ground man is back in sight.

6. Bin blocks may be stacked four (4) high using a boom truck/crane/track excavator. If

stacking over four high is required, Safety department approval will be required.

7. Only authorized personnel that have been trained specific to building bin block walls may

be tasked to build bin block walls.

8. Operations Manager/Maintenance Manager must ensure crane/excavator operator is

certified to operate equipment either Titan employee or outside contractor.

Lifting Bin Block using a Forklift or Wheel Loader with bucket fork attachment


1. Bin block designed to allow movement with a fork can be moved using a forklift or a

wheel loader with a bucket fork attachment

2. The operator must position the bin block to be completely back against the backrest of the

forks.

3. The operator must ensure that the load does not exceed the load limits of the vehicle used

to lift the block.

4. The operator must ensure that he has level ground to travel on when transporting block

with a fork truck.

Building Bin Block Walls

1. Only interlocking bin blocks shall be used in construction of any bin block walls.

2. Only authorized personnel that have been trained specific to building bin block walls may

be tasked to build bin block walls.

3. Operations Manager must ensure adequate ground preparation of area where bin block

wall will be constructed to maintain integrity of wall i.e. straight, with no leaning of walls

outward or inward.





6. If ground man is used during movement he must stay in sight of the boom truck/crane

operator at all times. If ground man goes out of view of operator, operator must stop until

ground man is back in sight.

Safety First

1. The plant manager or his designee shall plan and discuss all critical lifts with all affected

employees and/or contractors working in the adjacent area of the lift, prior to the lift

taking place.

2. Only trained and authorized operators shall operate cranes or other hoisting or lifting

devices.

3. Only trained and authorized persons shall rig loads to be lifted by a crane or other hoisting

or lifting device.

4. The rated load capacity shall be clearly marked on both sides of all overhead cranes and

other hoisting and lifting devices. The block of each overhead crane and other hoisting and

lifting device shall be clearly marked with its load rating.

5. A crane-specific load rating chart shall be securely affixed in the cab of all mobile cranes

and shall be visible to the operator.

6. The rated load capacity of all rigging shall be clearly marked on all rigging by means of

permanently affixed tags. Rigging with missing tags shall not be used unless the rigging is

tested, its load capacity determined and another tag is affixed to the rigging.

7. Cranes, hoisting and lifting devices and rigging shall not be loaded in excess of

recommended safe working loads.

8. Cranes shall only be used if all safety devices are in place and functional.

9. Employees shall not work from or travel on the bridge of an overhead crane unless the

bridge is provided with substantial travelways with toe boards and standard handrails the

length of the bridge.

10. Employees or other personnel shall not ride loads, crane hooks or other hoisting

equipment.

11. Hand signals, as prescribed by applicable ANSI standards for mobile cranes, will be

posted on all mobile cranes and shall be used for all lifts. (See Example 1.)


12. Hand signals, as prescribed by applicable ANSI standards for overhead cranes, will be

posted in the work areas of overhead cranes and shall be used for all lifts. (See Example

2.)

13. Only one designated and trained signal person shall give hand signals to a crane operator,

except in the case of “emergency stop” which can be given by anyone.

14. All personnel shall stay clear of suspended loads.

15. Taglines shall be attached to loads that may require steadying or guidance while

suspended.

16. A crane shall not be operated closer than 10 feet of overhead power lines rated 50 kV. or

below. For overhead power lines rated over 50 kV, the minimum clearance between the

crane and the lines shall be 10 feet plus 0.4 inch for each 1 kV. over 50 kV., or twice the

length of the line insulator, but never less than 10 feet.

17. A crane which is in transit with no load and boom lowered shall maintain a minimum

clearance from overhead power lines of 4 feet for voltages less than 50 kV., 10 feet for

voltages over 50 kV., up to and including 345 kV., and 16 feet for voltages up to and

including 750 kV.

18. If cranes must be moved or operated within 10 feet of energized high-voltage power lines,

the lines shall be de-energized or other precautionary measures shall be taken.

19. Mobile cranes shall not be operated without the full amount of counterweight in place as

specified by the manufacturer. Truck cranes may be operated temporarily with special care

and only for light loads without the full counterweight in place. The counter-weight placed

on any mobile crane shall not exceed that specified by the manufacturer.

20. A competent person shall inspect all hoist chains and slings prior to their use on a daily

basis. A monthly inspection of all hoist chains and slings that includes a certification

record shall be completed by a competent person. This certification record shall include

the date of inspection, the signature of the person who performed the inspection and an

identifier of the chain that was inspected.

Slings

Wire Rope Slings shall have permanently affixed to them a durable marking that states the rated

capacity, manufacturer, size, reach, and type of sling. If this tag is illegible or removed the sling

must be taken out of service until it is recertified.

1. Wire rope slings must be removed from service if any of the following conditions exist:

a) Ten randomly distributed broken wires in one rope lay, or five broken wires in one

strand in one rope lay.

b) Wear or scraping of one-third the original diameter of outside individual wires.

c) Kinking, crushing, bird-caging, or any other damage resulting in distortion of the wire

rope structure.

d) Evidence of heat damage

e) End attachments that are cracked, deformed, or worn.

f) Hooks that have been opened more than 15 percent of the normal throat opening

measured at the narrowest point or twisted more than 10 degrees from the plane of the

unbent hook.

g) Corrosion of the rope or end attachments.

2. In addition to the inspection prior to each use, a quarterly inspection must be conducted by

a competent person, and annually by the supplier. These inspections must be documented

and available at the plant for review by Safety department.

3. When not in use slings must be hung up out of the weather. Do not allow to lie on

ground.


Alloy Chain Slings. Only grade 80 alloy steel chain can be used in chain slings for lifting. All

alloy steel chain slings must have the size, grade, reach, and rated load capacity permanently

marked on the sling. If the tag becomes illegible or removed the sling must be taken out of service

until it is recertified.

1. On a daily basis or prior to each use check the chain and attachments for:

a) Wear

b) Kinks

c) Cracks

d) Breaks

e) Gouges

f) Bends

g) Weld splatters

h) Discoloration from excessive heat

i) Stretches

j) Hooks that have been opened more than 15 percent of the normal throat opening

measured at the narrowest point or twisted more than 10 degrees from the plane of the

unbent hook. Latches should work properly if provided.





ground.

Nylon Slings

1. Each sling must be marked or coded to show the rated capacities for each type of hitch,

type of web material and manufacturer. Only slings with legible identification tags shall be

used.

2. Slings must contain web that is of uniform thickness and width, and selvage edges must

not be split from the webbing width.

3. Fittings must be free of all sharp edges that could damage the webbing and must be of

minimum breaking strength equal to that of the sling.

4. Stitching shall be the only method used to attach end fittings to webbing and to form eyes.

5. Slings must be inspected prior to each use for wear. Slings shall be removed from service

if any of the following occur:

a) Acid or caustic burns

b) melting or charring of any part of surface

c) snags, punctures, tears, or cuts.

d) broken or worn stitches.

e) distortion of fittings

f) Safety threading showing (usually red or green) from inside sling.





ground.

Training


1. Employees required to use lifting and hoisting devices will be instructed in the inspection

of and proper use of cranes, wheel loaders, hoisting and lifting devices, and rigging.

2. Cranes, wheel loaders, hoisting and lifting devices, and rigging will be a periodic safety-

training topic.

3. Employees required to manufacture and/or build bin block walls will be instructed in the

proper methods per this procedure and be deemed competent by the Operations Manager.

Monitoring and Enforcement: The operation/production/maintenance manager or his/her designee

shall be responsible for implementation and manager enforcement of this policy. The Safety

Department will be responsible for inspection of this procedure and compliance during any

inspections at the facilities.

Record Keeping: Unit operations/productions/maintenance managers are responsible for ensuring

that employees receive appropriate safety and health training as outlined above. All training shall

be documented. MSHA regulated sites shall utilize Form 5000-23 or equivalent document for all

training except toolbox safety talks. Training for OSHA-regulated site employees shall be

recorded on a Titan America Training Documentation Form.

Slings

Each day before it is used, a sling and all fastenings and attachments shall be inspected for

damage or defects by a competent person designated by the employer. Damaged or defective

slings shall be immediately removed from service. When and where service conditions warrant,

additional inspections shall be performed during sling use.

Slings shall not be shortened with knots, bolts or other makeshift devices. There should be

no kinks in their legs, and they shall not be loaded in excess of their rated capacities.

Slings shall be securely attached to their loads and, if used in a basket hitch, shall have

loads balanced to prevent slippage. Hands or fingers shall not be placed between a sling and its

load while tightening around the load. Slings shall be padded or protected from sharp edges of

their loads. All employees shall be kept clear of loads about to be lifted, and clear of suspended

loads. Suspended loads shall be kept clear of all obstructions. Shock loading is prohibited.

Wire Rope Slings: Remove wire rope slings from service if any of the following exists:

1. Ten (10) randomly distributed broken wires in one rope lay, or five (5) broken wires in one

strand in one rope lay.

2. Wear/scraping on one-third the original diameter of outside individual wires.

3. Distorted rope structure from kinking, crushing, bird-caging, other damage.

4. Evidence of heat damage.

5. Cracked, worn or deformed end attachments.

6. Hooks open more than 15 percent of normal measured at narrow point of throat, or twisted

more than 10 degrees from the plane of an unbent hook.

7. Corrosion of the rope or end attachments.

Web Slings: Use only slings that are marked with capacities for each type of hitch, web material

and manufacturer. Web must have uniform thickness and width, and selvage edges must not be

split from the width. Fittings must not have edges that can damage webbing, and must carry

breaking strength equal to the sling. Stitching shall be the only method used to attach end fittings

to webbing and to form eyes.

Alloy Chain Slings: Alloy steel chain slings shall have permanently-affixed durable identification

that specifies size, grade, rated capacity and reach. These slings shall be used only in accordance

with the manufacturer’s recommendations, and shall not be used with loads that exceed their rated


capacities. Hooks, rings, oblong links, pear shaped links, welded or mechanical coupling links or

other attachments shall have a rated capacity at least equal to that of the chain with which they are

used. If any doubt, the sling shall not be used in excess of the rated capacity of the weakest

component. Makeshift links, fasteners formed from bolts or rods, or other such attachments shall

not be used.

Inspection and Testing: A thorough periodic inspection of alloy steel chain slings in use shall be

made on a regular basis, to be determined by:

1. Frequency of sling use

2. Severity of service conditions

3. Nature of lifts being made

4. Experience gained on the service life of slings used in similar circumstances

5. Such inspections shall in no event be at intervals greater than once every 12 months.

The plant shall create and maintain a record of the most recent month in which each alloy

steel chain sling was thoroughly inspected, and shall make such a record available for

examination. Inspections shall be performed by competent persons designated by Titan, and shall

include a thorough inspection for wear, defective welds, deformation and increase in length.

1. Where such defects or deterioration are present, the sling shall immediately be removed

from service.

2. Worn or damaged alloy steel chain slings or attachments shall not be used until repaired.

3. When welding or heat testing is performed, slings shall not be used unless repaired,

reconditioned and proof tested by the sling manufacturer or an equivalent entity.

4. Mechanical coupling links or low carbon steel repair links shall not be used to repair

broken lengths of chain.

5. Alloy steel chain slings with cracked or deformed master links, coupling links or other

components shall be removed from service.

The plant shall ensure that before use, each new, repaired, or reconditioned alloy steel

chain sling, including all welded components in the sling assembly, shall be proof tested by the

sling manufacturer or equivalent entity, in accordance with paragraph 5.2 of the American Society

of Testing and Materials Specification A391-65, which is incorporated by reference as specified in

Sec. 1910.6 (ANSI G61.1-1968). The employer shall retain a certificate of the proof test and shall

make it available for examination.

Excessive Service Temperatures: Alloy steel chain slings:

1. Shall be permanently removed from service if they are heated above 1,000 degrees F.

2. If exposed to more than 600 degrees F, maximum working load limits shall be reduced in

accordance with the chain or sling manufacturer's recommendations.

See: www.msha.gov 56.19021 - 19030 or www.osha.gov 1910.184.

I. EXCAVATION, TRENCHING, BLASTING AND UNDERGROUND WORK

Soil conditions can change and make excavations unstable. A trench does not have to be deep

to be dangerous. Before entering or working in any excavation or trench, follow these safety

procedures to protect against cave-ins, collapsing materials, failure of related structures and other

hazards.

Underground and Overhead Utilities




1. Advise utility companies of proposed work to determine underground or overhead

locations of pipelines or vessels for fluids, or lines for power, telephone, etc.

2. If pipelines or vessels are involved, obtain Material Safety Data Sheet(s) for their contents

and comply with warnings.

3. A utility representative should be at the work site before digging.

4. A “competent person” shall verify any lines or obstructions.

5. Probe or dig by hand to locate obstructions.

a. Use rubber gloves if near electrical cable.

b. Establish a two (2) foot safe zone on either side of obstruction, and drive stakes to

prohibit mechanical digging in that zone.

6. Prevent rocks, large roots and other debris from falling onto utility lines.

7. Excavation near utility lines is prohibited with buckets that have side cutters or teeth.

8. If explosive atmospheres are [possible/probable] a combustible-gas meter shall be readily

available.

a. If a Lower Explosive Level reading of greater than 0% is registered, stop work

until a Titan America Safety Department representative permits resumption.

9. If there is any doubt that all electrical and mechanical cables have been located:

a. Power tools and mechanical equipment such as concrete breakers, drills and

backhoes should be grounded with a 2/0-ground lead.

b. Class II rubber gloves and boots shall be worn by anyone at risk.

c. Establish emergency procedures for notifying proper utility representatives.

Work Practices

Do not enter any excavation or trench until it has been inspected by a “competent person” and

determined to be safe.

1. Inspect trenches daily or when weather conditions change before entering.

2. All sites five (5) feet deep or more shall be properly sloped or shored to meet MSHA

and OSHA standards.

3. All sites are required to have a safe, secure ladder no more than 25 feet from workers.

The ladder should extend at least three (3) feet above top edge of the excavation, and

should be repositioned as work progresses.

4. All employees must exit immediately if conditions become hazardous.

5. Surface rocks and removed material shall be placed no less than two (2) feet away

from the edge so they cannot fall back into the trench.

6. Near vehicular or foot traffic, install hard barricades at least 42 inches high, square

and level, around all excavations.

7. Job sites defined as “confined spaces” shall be tested regularly for gases and safe

oxygen levels. Repeat tests when conditions change.

8. If unusual or abnormal conditions or circumstances occur, contact the designated

company safety representative before further work.

Excavation Protective Systems

Each job site shall have excavation protective systems that can resist all intended loads or

loads reasonably expected to occur. There are two exceptions: protective systems are not required

in excavations:

1. made in rock classified by a Competent Person as solid/stable, or

2. less than five (5) feet deep and determined by a Competent Person to have no cave-in

potential.

Protective systems requiring soil classification shall have each soil and rock deposit classified

by a Competent Person as Stable Rock Type A or B or C.


1. Soil type shall be based on at least one visual and one manual analysis using

acceptable, recognized methods.

2. Document results on an Excavation Permit form and keep it on site.

3. Competent Person shall choose and produce support systems, shields and other

protection in accordance with MSHA and OSHA standards.

Sloping and Benching

For excavations five (5) to twenty (20) feet deep, Competent Person shall choose and produce

slopes and configurations of such systems based on standard requirements at OSHA 1926.652 (c).

For excavations exceeding twenty (20) feet, systems must be designed and stamped by a

Registered Professional Engineer.

Records and Files

Documents that support Competent Person’s training in OSHA Trenching and Excavating

standards shall be maintained at the job site. All required forms and designs created by a

Registered Professional Engineer shall be maintained at the site until project’s completion, then

archived with project files.

Definitions

Excavations – Any man-made hole or trench formed by removal of soil and other materials that

may cause unstable conditions.

Excavation Protective Systems – Sloping or shoring systems, supports, shields and other devices

that can resist intended loads or those reasonably expected.

Trench – A narrow excavation deeper than its width, typically less than 15 feet wide.

Competent Person – One with training and knowledge about soil, and protection during its

removal, who can identify existing and likely hazards that may impact employees. This person is

authorized to promptly correct conditions to reduce or eliminate hazards.

See: www.msha.gov 56.3401 and www.osha.gov 1926.651.

Section 3

OCCUPATIONAL HEALTH AND INDUSTRIAL HYGIENE

Workplace factors may cause sickness, impaired health or significant discomfort. Reliable

information about the workplace is necessary to reduce or eliminate ergonomic problems, toxins,

radioactive materials and other agents.

A. IDENTIFYING AND REDUCING POTENTIONAL HAZARDS

Elements

The Safety Manager or Plant Supervisor will identify hazards by:

1. obtaining information on chemicals, exposures and monitoring data,

2. assessing processes and scope of work,





3. performing periodic walk-through surveys,

4. reviewing proposed projects, facilities, engineering plans and specifications,

5. reviewing customer-provided hazards inventory or tracking systems, and by

6. monitoring exposures for specific tasks.

Hazard Analysis

Use permissible exposure limits (PELs) established by the National Institute for Occupational

Safety and Health (NIOSH) to evaluate and determine exposures. For chemicals without assigned

PELs (such as some carcinogens) use relevant guidelines in work areas where entry and exit are

controlled due to chemical handling or storage. Chemical evaluations will be based on best

available information or industry practice. Threshold Limit Values (TLVs) developed by the

American Conference of Governmental Industrial Hygienists (ACGIH) may be used. For

assistance, consult the Safety and Health Department. Risks include but are not limited to:

1. Exposures exceeding the PELs for regulated chemicals and TLVs for unregulated

chemicals

2. IDLH and other confined space concentrations

3. Potential skin absorption and irritation sources

4. Potential eye irritation sources

5. Blood borne pathogens

6. Explosion sensitivity and flammability

7. Oxygen deficiency

8. Temperature extremes

9. Ergonomic issues

10. Ionizing and non-ionizing sources and other physical agents

11. Workers and crafts exposed

Exposure Monitoring

Titan America contracts with Sandler Occupational Medicine Associates (SOMA) to

coordinate its industrial hygiene sampling/monitoring program. In conjunction with Titan America

Safety Managers, SOMA will be responsible for industrial hygiene sampling, primarily for silica

dust and noise levels. SOMA will analyze tests, generate reports, assist in interpreting reports,

advise and act as necessary to mitigate any overexposures. SOMA will maintain and store data on

Titan America’s industrial hygiene history. Exposure monitoring shall be based on any one of the

following:

1. Regulatory requirement(s)

2. Determination of protection requirements

3. Exposure assessment

Control Measures will be implemented by site management when it determines that a hazard

exists in activities controlled by the company.

1. Use engineering controls, change operations or activities, or substitute materials to

minimize or prevent exposure levels.

2. If engineering controls are not feasible, use administrative controls and/or Personal

Protective Equipment (PPE). Use corrective measures when safety procedures are not

followed. If they involve a customer’s process, contact the customer to establish

control.

Periodic Reviews at each facility shall include monitoring, evaluation of controls and

communication on their adequacy.

Training for Titan America personnel shall cover:

1. Operations that may lead to exposure

2. Potential health effects of hazards


3. Content of applicable standards

4. Purpose and results of environmental monitoring

5. Use of Personal Protective Equipment

6. Proper work practices and precautions

7. Updates and repeat training as conditions change

B. PROGRAM PROCESSES

Hazard Communications for each project shall train and inform employees, contractors and

suppliers about exposure to chemical and physical hazards and about appropriate controls.

1. Follow all applicable hazard communication laws and requirements.

2. The Safety Manager or his designee shall ensure that a written Hazard

Communications Program is used, with procedures that:

a) label and list hazardous chemicals, and where they’re used and stored,

b) collect, ensure access to and distribute Material Safety Data Sheets,

c) inform personnel working with chemicals of hazards involved,

d) ensure that written programs are available to employees,

e) specify how Titan America informs contractors and equipment suppliers of

chemical locations and hazards they may be exposed to,

f) specify how those contractors and suppliers will inform Titan America of

hazardous chemicals they bring on site,

g) assign responsibility for implementing and maintaining the Hazard Communication

Program.

Material Safety Data Sheets The Hazard Communication Program shall include the following

requirements:

1. Those who buy chemicals shall ensure that each purchase contains an MSDS.

2. Those who receive chemicals shall insure that an MSDS is received and stored in the

appropriate location.

3. MSDSs (or equivalent) and lists of all hazardous chemicals shall be available to all

employees and contractors.

Labeling on containers, storage areas and locations shall identify the chemical and hazards. On

piping and transfer system labels, visibly identify the chemical and its direction of flow.

Supervisors, superintendents and foremen for each project shall ensure that employees

receive hazard communication training before working with hazardous chemicals. Continuing

education will repeat when new hazards appear.

1. Identify and train all employees who work with or near hazardous chemicals. Retrain

any employee who cannot demonstrate proficiency.

2. Project safety representatives shall conduct general orientations that include:

a. health and physical hazards employees may be exposed to,

b. labeling procedures

c. reading and understanding MSDSs, and

d. such protective measures as Personal Protective Equipment, work practices and

emergency procedures.

3. Specific orientation shall be conducted by an employee's direct supervisor and shall

include:

a. discussion of specific hazardous chemicals, and

b. an overview of controls: engineering, administrative and protective equipment

4. Plant Supervisors shall document and maintain training records


Definitions

“Chemical” – Any element, compound or mixture of elements and compounds.

“Container” – Any bag, barrel, bottle, box, can, cylinder, pipe, tank or similar device that contains

a hazardous chemical.

“Contractors” – A company or an individual who is not a Titan America employee but has been

engaged by Titan America to carry out specified work. This definition includes all levels of

subsequent Subcontractors.

“Hazardous Chemicals” – Any chemicals considered a physical or health hazard.

“Health Hazard” – A chemical for which there is significant evidence that exposure can cause

acute or chronic health problems. Examples are carcinogens, toxic or highly toxic materials,

reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins,

agents that act on the hematopoietic system, and agents that damage lungs, skin, eyes or mucous

membranes.

“Label” – Any written, printed, or graphic material displayed on or affixed to chemicals or

containers to identify contents and hazards.

“Material Safety Data Sheets” – Documents usually provided by a supplier with details about a

hazardous chemical, material, composition, chemical and physical properties, health and safety

information, handling, storage, disposal and emergency procedures.

“Physical Hazard” – Chemicals known to be a combustible liquid, compressed gas, cryogenic,

explosive, flammable gas, flammable liquid, flammable solid, organic peroxide, oxidizer,

phyrophoric, unstable (reactive), or water-reactive material.

“Point-of-Chemical-Use-Location” – Such locations as sinks, production equipment, cleaning

baths, degreasers, laboratory or cleaning hoods, dispensing cans, or any container other than an

original labeled container.

References: HazCom Standard, HazCom Compliance Poster - English and Spanish

See: www.msha.gov 47.1 - 92 or www.osha.gov 1910.1200 and 1926.59.

Hearing Conservation can minimize occupational and environmental noise and prevent hearing

loss. Titan America block plants and MSHA-governed operations will enroll all employees in a

Hearing Conservation Program (HCP). Programs at other locations will be determined by results

of industrial hygiene sample surveys performed by SOMA to determine if an HCP is required.

Noise Control Each project shall use procedures that minimize environmental and occupational

noise. At minimum, they shall:

1. Review and evaluate activities and equipment;

2. Use engineering controls to reduce noise levels wherever possible;

3. Survey initial and periodic levels:

a. of environmental noise,

b. of places that qualify as hearing conservation areas,

c. in response to employee or community concerns,

d. when changes in operation or machinery could affect noise exposures, and

e. when other changes could affect noise levels.


http://www.osha.gov/pls/oshaweb/owadisp.show_unique?p_table_name=STANDARDS&p_unique_file=1910_1200&p_anchor_name=



A Hearing Conservation Program shall be implemented at fixed facilities with potential for

exposure to noise at or above an 8-hour Time Weighted Average (TWA) of 85 dBA. The program

shall contain at least the following:

1. Identification of all affected employees

2. Annual audiometric exams reviewed by a licensed audiologist.

3. Personal Protective Equipment (PPE) for use in hearing conservation areas

4. Annual training so affected employees:

a. recognize the nature of noise and results of unprotected exposure,

b. learn the proper use and care of hearing protective devices, and

c. understand the purpose of audiometric testing and procedures.

Records related to noise control and the Hearing Conservation Program shall be maintained as

provided in Titan America record retention policies.

Notification. The Safety Manager shall identify hearing conservation areas with signs that warn

those who enter of prior and continued need for protection.


Heat Stress Guidelines help minimize employee exposure to stroke, exhaustion, cramps, collapse

and related effects. Guidelines shall follow applicable laws and regulations.

1. Each facility shall have a heat stress awareness program to inform employees of risks from

high air temperatures and humidity, radiant heat sources, physical contact with hot objects, or

strenuous physical activity.

2. Causal factors: Inform employees that heat stress disorders can be affected by age, weight,

physical fitness, acclimatization, metabolism, alcohol or drug use and such conditions as

hypertension.

3. First Aid requirements include moving the victim into shade, removing outer clothing, wetting

the skin, and moving air to improve evaporation until professional help arrives. Replace fluids

as soon as possible. Results of heat stroke depend on first aid and a victim's fitness. Even if a

worker resists, no employee considered ill from heat stroke should be sent home or left

unattended without approval of a physician.

Definitions

"Heat Stroke” occurs when temperature regulation fails and body temperature rises to critical

levels. Causes vary and are difficult to predict. Symptoms include confusion, irrational behavior,

loss of consciousness, convulsions, a lack of normal sweating, hot, dry skin and an abnormally

high body temperature of 41C (105.8-F). Death can follow a high temperature. Workloads and hot

environments can both contribute to heat stroke.

"Heat Exhaustion” symptoms include headache, nausea, vertigo, weakness, thirst, and giddiness.

"Heat Cramps” can occur in muscles and may be relieved by resting and drinking water.

"Heat Collapse" or fainting is caused by excessive pooling of blood in extremities. The brain

receives too little oxygen and victims lose consciousness. The reaction is rapid, unpredictable and

similar to heat exhaustion but does not affect the body heat.





Personal Protective Equipment (PPE)

1. Maintain and provide Personal Protective Equipment (PPE)

2. Train all employees in PPE, including care, storage, replacement and proper use.

3. A PPE assessment is required at each Titan America facility; reviewed annually.

4. Supervisors shall be familiar with PPE required for their sites and projects.

5. All contractors and/or visitors shall be required to use appropriate PPE.


Radiation (Ionizing) Program

To protect employees from ionizing radiation and keep exposure “as low as reasonably

achievable” (ALARA),

1. Review and approve all sources of ionizing radiation brought to the site.

2. Wherever sources of ionizing radiation are used, a written program shall address

inventories, hazard evaluation, employee training, Personal Protective Equipment and

medical surveillance radiation monitoring. Exposures shall meet the ALARA

philosophy (as low as reasonably achievable)

3. Designated, qualified Radiation Safety Officers (RSOs) shall administer the program,

which shall include training for employees subject to exposure that:

a) includes radiation types and hazards, how to minimize exposure, how to get

exposure reports and how to interpret them, and

b) documents initial and periodic training

4. RSO shall maintain all applicable records and exposure data.

Definitions

"Ionizing radiation" Includes alpha, beta, gamma and X-rays, neutrons, high-energy

electrons, high-speed protons and other atomic particles. Does not include sound or

radio waves, visible infrared or ultraviolet light.

"May be exposed to" shall be defined by industrial hygiene assessments and/or regulatory

requirements.

"RSO" The qualified Radiation Safety Officer administering the program.

References: Titan America Radiation Safety Program. Regulations of the Nuclear Regulatory

Commission, 10 CFR, Part 20. Contact the Corporate Safety and Health Department for assistance

with specific information and guidelines.

See: www.osha.gov 1910.97 and 1926.53.

Respiratory Protection

Protect employees from airborne contaminants during routine, periodic, dangerous and emergency

situations. Protection shall include chemical material selection, process design and engineering

controls. Respirators shall be used to reduce exposure only when other adequate means cannot be

provided.







A written program for projects using respirators shall address hazard assessment, fit testing,

types of respirators, storage, cleaning and medical monitoring. Review the program annually for

effectiveness. Safety Managers shall assess potential exposure and appropriate protection.

Procedures shall cover:

1. Determining the best respirator for the circumstances. Safety Managers shall evaluate

the respirator based on:

a) chemical, physical and toxic hazards, and

b) compatibility with the work performed

2. Annual medical evaluations and authorization of all respirators

3. Fit testing

4. Initial and annual training and certification of respirator users, and

5. Maintenance, cleaning, inspection, storage and use of respirators

Exposure Assessment Sequence to control effect of airborne contaminants:

1. First, use such engineering controls as less toxic materials, confinement of and local

ventilation of operation.

2. Safety and health professionals shall assist plant management in estimating exposure

to hazards. Consider both worst case and typical exposures in choosing an appropriate

dust mask.

3. When required, provide dust masks at no cost to the employee.

Voluntary Use of Dust Masks When exposure to contaminants does not exceed OSHA PELS or

ACGIH TLV levels, employees may request to use a dust mask on a “voluntary” basis. If so,

provide employee with training on use of the dust mask and complete Appendix D (OSHA). In

conditions other than “voluntary,” contact the Safety Manager to ensure employee is enrolled in

the written program to use any kind of dust mask.

Medical Certification: A physician or licensed health care professional (PLHCP) shall evaluate

each respirator user per the following requirements, as appropriate:

1. The Medical Evaluation Questionnaire from www.osha.gov 1910.134, Appendix C,

Sections 1 and 2, or one with similar content.

2. A medical evaluation before fit-testing and respirator use

3. Required further information shall be provided to the PLHCP before recommending

an employee wear a respirator.

4. PLHCP shall provide Titan America a written recommendation on the employee’s

ability to wear the respirator(s).

Fit Testing shall be performed on all employees required to wear respirators. Document the test

records and methods.

1. Repeat testing annually

2. Review program annually to determine effectiveness

3. Check self-contained breathing apparatus and emergency respirators monthly

Respiratory Protection Training shall be done for each type, style, manufacturer and model of

respirator used.

1. Teach maintenance, inspection, cleaning, storage, use, limitations and equipment

failure

2. Demonstrate successful fit-testing and face seal

3. Include emergency operations that require respirators

Maintenance, Cleaning, Inspection and Use

1. Inspect respirators before and after each use.





2. When not used, store respirators to protect from damage and contamination.

3. Clean and maintain respirators for safety and effectiveness.

Definitions

“Air Purifying Respirator” – A half mask or full face piece into which the wearer draws air

through filter media that trap or remove airborne irritants or contaminants by absorption or

adsorption. Filter media may trap single or multiple substances.

“Air Supplied Respirator” – A supply-air half mask, full face piece, hood or helmet in which

respirable air is supplied from a source other than surrounding atmosphere.

“Airborne Contaminants” – Hazardous respirable mists, vapors, gases, particles and fibers.

“Engineering Controls” – Protective measures built into equipment, workstations, work methods,

tools, furniture or other work place activities and processes that require no human intervention to

be effective.

“Fit Testing” – A procedure to determine a respirator’s fit on someone’s face.

“Hazardous Materials” – Materials that presents a health or physical hazard.

“Health Hazards” – Chemicals that are carcinogenic, toxic, reproductive toxins, irritants,

corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents that act on the

hematopoietic system, and agents that damage lungs, skin, eyes or mucous membranes.

“Medical Evaluation” – Determination of pertinent health and physical conditions for

employees who may wear respirators. Includes pre-placement and medical monitoring to ensure

the worker can perform the job safely, the respirator will not cause special problems and the

worker is psychologically able to wear a respirator.

“Negative Pressure Fit Test” – Respirator wearers close off the inlet, covering it with the palms

and inhaling gently to collapse the face piece slightly, then hold their breath for 10 seconds. If the

face piece is slightly collapsed and no inward leaking of air is detected, the tightness of the fit is

satisfactory.

“Physical Hazard” – Risk of injury from work place tasks, tools or such hazards as noise, heat,

cold, repetitive motion, sharp edges, rough surfaces, weight, height, projectiles and poor

housekeeping.

“Physician or Other Licensed Health Care Professional” – An individual legally permitted by

license or registration to independently provide (or be delegated the responsibility to provide)

services medically required by the respirator protection standard. This status is determined by

respective states. These services are provided by SOMA.

“Positive Pressure Fit Test” – Respirator wearers close off the exhalation valve and gently exhale

into the face piece. Face fit is satisfactory if a slight positive pressure can be created without

evidence of air leaking at the facial seal.

“Pulmonary Function Test” – Determines lung capacity by measuring a single reparation.

“Qualitative Fit Test” – Uses validated data to determine adequacy of an employee’s respirator.

Only two tests are valid: the isoamyl acetate odor test and the saccharin mist test. These must


follow criteria in the ANSI Z88.10 standard.

“Quantitative Fit Test” – Measures actual leakage of a test gas, vapor or aerosol into a respirator

facepiece. Common test equipment includes sodium chloride and oil mist systems that measure

mass concentration of the test aerosol by sodium flame photometry or forward light scattering

photometry. ANSI standard Z88.10 has recommended specifications.

“Respirators" – Equipment that protects a person from airborne contaminants, dust or other

airborne irritants.

“SCBA” – Self-contained breathing apparatus with back-mounted cylinder of air.

See: www.msha.gov 56.5001, 56.5002, and 56.5005, or www.osha.gov 1910.134 and

1926.103.

Blood Borne Pathogens

Purpose: To minimize or eliminate employee exposure to blood borne pathogens including

Hepatitis B virus (HBV) and the human immune deficiency virus (HIV).

1. A Pathogens Control Plan shall minimize or eliminate employee exposure to blood borne

pathogens in the workplace, including Hepatitis B viruses and the HIV virus. The plan shall

identify and train employees potentially exposed to such pathogens about Personal Protective

Equipment, universal precautions, post-exposure treatment, decontamination procedures and

waste disposal.

2. Hepatitis B vaccinations shall be made available to Category I high hazard exposure groups,

with post-incident vaccinations available for Category II low hazard exposure groups.

Document all exposure incidents with incident reports.

3. First Aid kits shall include Personal Protective Equipment, which must be provided to

employees in the program.

4. Periodically evaluate elements of the control plan.

6. Employees performing Category I and II tasks shall receive initial and annual training

covering:

a. transmission patterns for the Hepatitis B virus (HBV) and human immune deficiency

virus (HIV),

b. respective Category I and II tasks and work practices, the protective clothing and

equipment required, its use and limitations,

c. where such protective items are kept, and proper disposal if contaminated,

d. appropriate action and persons to contact if unplanned Category I tasks occur,

e. corrective actions following spills or personal exposure to fluids or tissues, appropriate

reporting procedures, and medical monitoring recommended if parenteral (injection,

needle stick) exposure is suspected, and

f. how "Universal Protection Precautions" apply to work practices.

g. A tracking system shall verify that such employees receive the training.

7. Place contaminated articles in biohazard trash containers. Place soiled clothing in leak-proof

bags and launder per manufacturer's instructions. Attach biohazard warning labels to







containers of medical waste, refrigerators, freezers containing blood or other potentially

infectious material, and to other containers that store or transport contaminated materials.

Definitions

"Category I Tasks" involve potential exposure to blood, body fluids or tissue, such as tasks by

first responders.

"Category II Tasks" may involve exposure to blood, body fluids or tissues under special

circumstances.

"Exposure Incident" – Exposure of “open” skin or a mucous membrane surface to another’s

blood or potentially pathogenic body fluids.

“Medical Waste” – Material containing blood or potentially pathogenic body fluids.

"Occupational Exposure" – Potential exposure to blood or potentially pathogenic body fluids.

Considered normal for people who provide emergency first aid and CPR. The standard typically

excludes exposure to such body fluids as tears, sweat, saliva and urine. Persons who clean

restrooms normally are not considered occupationally exposed.

"Universal Protection Precautions" – A system of infectious disease control that assumes every

direct contact with human blood and certain body fluids is infectious and requires protection of all

employees exposed to direct contact with body fluids.

See: www.osha.gov 1910.1030 and Centers for Disease Control (CDC).

Crystalline Silica

Purpose: To minimize exposure to hazards of crystalline or free silica.

Follow all applicable laws and regulations.

1. Unless a more restrictive one applies, employees shall not be exposed to crystalline or free

silica above the following limit:

10 mg/m³ / [% Quartz + 2(% cristobalite) + 2(% tridymite) + 2]

2. Medical surveillance is required for all workers with known potential exposure to crystalline

silica, including those involved in operations listed below. Medical evaluation shall be

provided before employees are fit tested and required to wear respirators, as per 29 CFR

1910.134.

3. Typical industrial activities where potential exposure exists are:

a. Rock drilling, quarrying, aggregates operations

b. Jack hammering

c. Guniting

d. Repair/Replacement of Linings of Rotary Kilns

4. Perform medical examinations as determined by Primary Licensed Health Care Practioner

(PLHCP) or as recommended as required by a doctor.

Definitions


http://www.cdc.gov/niosh/docs/2007-157/




“Silicosis” – The fibrotic lung disease can be acute, accelerated or chronic. Crystalline silica has

been associated with silicosis, obstructive pulmonary disease, bronchitis, collagen vascular

diseases, granulomatous infections such as tuberculosis, and lung cancer.

“Crystalline Silica” – A colorless, odorless solid found in mineral dusts, absorbed into the body

mainly by inhalation. Also can be ingested by mouth.

“Respiratory Protection” – A respirator with a full face piece operated in a positive pressure

mode, or during emergencies, or any self-contained breathing apparatus with a full face piece

operated in positive pressure mode. For concentrations of crystalline silica at or below the PEL,

half mask air purifying respirators with high efficiency or P100 filters may be used.

See: www.msha.gov 56.5001, 56.5002, and 56.5005, or www.osha.gov 1910.1000 and 1926.55.

Asbestos

Purpose: To protect employees from hazards associated with asbestos. Follow all applicable laws

and regulations.

Assessing Exposure

1. Perform an Exposure Assessment on all project structures to determine if asbestos- containing

materials (ACM) are present.

a. On pre-1985 structures, all unidentified thermal system insulation (TSI) and surface

material is presumed to be ACM unless sampling or objective data prove otherwise.

b. If documentation justifies, an Exposure Assessment is unnecessary on new structures or

those with recent ACM removal.

2. If asbestos is present, develop and implement an asbestos control program that includes:

a. A periodic physical assessment of the material’s condition,

b. a periodic hazard assessment including air sampling, and

c. an Operations and Maintenance Plan with procedures for small scale, short duration

removal.

d. Address exposure assessment, air monitoring, respiratory protection, medical monitoring

and employee training.

3. Assessment criteria shall be 0.1 fibers per cubic centimeter (f/cc) of air as an eight (8) hour

time weighted average (TWA) and 1.0 f/cc as a 30-minute excursion limit.

4. Medical monitoring and assessment training shall be used with:

a. Employees possibly exposed to asbestos at 0.1 f/cc as an 8-hour time weighted average

more than 30 days per year and who are engaged in Class I, II or III work, and

b. all employees possibly exposed in excess of 0.1 f/cc as an 8-hour time weighted average.

5. Any work that will or potentially could disturb ACM, whether Operations, Maintenance or

other, whether short-term or full-scale, will require approval and a permit from a Competent

Person.

Medical Evaluations

1. Under guidance of a physician, or using physician-approved protocols, conduct pre-project

and annual medical evaluations of employees known to have been exposed to asbestos, and

notify employees in writing of results. Inform the physician of employee exposure to asbestos

prior to establishing medical protocols or conducting evaluations.

2. Use a tracking system to verify that all employees exposed to asbestos:

a. receive the pre-project and annual exams,







b. have access to information about health effects of asbestos,

c. receive adequate and documented training, including refresher training and that which

addresses work practices and related engineering controls.

Definitions

ACM – Asbestos-Containing Material

Class I – Activities involving removal of TSI and surface ACM or PACM (Presumed ACM)

Class II – Removal of ACM that is not TSI or surfacing materials

Class III – Repair and maintenance operations where ACM, TSI, surfacing ACM and PACM are

likely to be disturbed.

Class IV – Maintenance and custodial work where employees contact but do not disturb

ACM or PACM. Includes clean up of dust and debris from Class I, II or III work.

Exposed Employees – Those exposed to asbestos at or above an 8-hour time weighted

concentration of 0.1 fibers per cubic centimeter of air (f/cc) over 30 days per year or more if

wearing a negative pressure respirator. Includes those exposed in excess of a 30-minute excursion

limit of one (1.0) f/cc.

May be exposed to – As defined by industrial hygiene assessments and/or regulations.

Medical Examinations – Shall include a work-up and history with emphasis on respiratory and

cardiovascular systems, the digestive tract, a physical exam including chest X-ray, pulmonary

function test and laboratory reports as required by a physician. Exams shall be provided pre-

placement, annually and on termination of employment and shall include a smoking history, nasal

and skin exam, sputum cytology and other examinations the physician believes important.

TSI – Thermal System Insulation

TWA – Time Weighted Average

Qualified – As determined at each site by local regulations as applicable.

See: www.osha.gov 1910.1001 and 1926.1101.

Lead

Purpose: To protect employees by monitoring those exposed to levels of inorganic lead above an

airborne concentration of 30 micrograms per cubic meter of air (g/m3) for 30 days or more per

year. Follow all applicable laws and regulations.

Assessing Exposure

1. For all operations that might liberate lead, perform an initial (baseline) sampling per General

Industry Standards. Include at least one personal sample that reflects actual exposure for that

work shift.

a. For construction work, determine the presence of lead in materials or work procedures. If

present, standards presume exposure at predetermined levels.




2. If levels exceed 50 g/m3 as an 8-hour TWA, use a written program that covers exposure

monitoring, respiratory protection, compliance procedures, ventilation, protective clothing,

controls for engineering/work practices, training and medical monitoring.

a. Change levels per duration of exposure.

b. For exposures exceeding 8 hours, 400 g/m3 is allowed for that work day.

3. Inform employees in writing of their results. If above 50 g/m3 as an 8-hour TWA:

a. Specify corrective action to reduce exposure.

b. Supply protective clothing if skin or eye irritation is possible.

c. Document procedures for proper use, disposal and laundering of contaminated

clothing. If used, notify laundry service of contamination.

4. Regardless of airborne exposure, keep surfaces as free as possible from lead dust.

a. Use wet-wipes, HEPA vacuums or other methods that least disturb dust.

5. Identify employees who may be exposed to levels exceeding 30 g/m3. Refer them for

medical monitoring and lead hazard training.

6. Employees who may be exposed to lead:

a. Provide initial and refresher training on the health effects of lead.

b. Document those and other efforts, assuring that all affected employees are informed

and trained.

Medical Evaluations

1. Under guidance of a physician, or using physician-approved protocols, perform baseline and

periodic evaluations of employees exposed to lead.

a. Inform physician of employee exposure prior to evaluating or establishing protocols.

b. Notify employees in writing of their blood level results.

c. Employees with excessive levels shall be restricted from lead-exposure areas.

2. Use a tracking system to verify that:

a. All employees exposed to levels above an airborne concentration of 30 g/m3 for

thirty (30) days or more per year get baseline or 6-month evaluations.

b. Blood level examinations are done at least every 6 months.

c. Levels are examined every two (2) months for employees testing greater than 40

g/m3.

3. Perform site audits periodically to evaluate the Medical Evaluations program.

Definitions

TWA – Time Weighted Average

May be exposed to – As defined by industrial hygiene assessments and/or regulations.

Exposed employees – Those exposed to levels of inorganic lead above an airborne concentration

of 30 micrograms per cubic meter of air (g/m3) for thirty (30) days or more per year.

Medical evaluations – Detailed work-up and medical history, thorough exam, blood sample, zinc

protoporphyrin, blood urea nitrogen, blood creatinine, urinalysis and other tests conducted under

the guidance of a physician or following physician-approved protocols. Perform on all identified

exposed employees on initial assignment and whenever blood levels exceed 40 g/100g. The

physician shall be informed of employee exposure to lead prior to establishing medical protocols

or conducting evaluations.

Medical restriction – Employees with single blood levels of 60 g/100g or greater, or with an

average of 50 g/100g or greater over the last three assessments, shall be temporarily restricted


from lead exposure, with follow-up care by a physician. They may resume their normal jobs when

results of two consecutive exams show less than 40 g/100g.


Hexavalent Chromium and Contractors

Purpose: to protect contract welders and nearby workers at Titan facilities who burn, remove or

otherwise disturb dried paint and may be exposed to hexavalent chrome, also known as Chrome

Six. Follow all applicable laws and regulations.

Requirements

The minimum requirements for Chrome Six work at Titan America facilities do not relieve

contractors of compliance with OSHA and related regulations for hexavalent chromium.

Contractors should determine if their work may involve Chrome Six. If so, they must perform

work assessments, conduct air sampling, implement controls, provide personal protective

equipment (PPE), perform training and medical surveillance, keep records and otherwise satisfy

OSHA requirements.

Contractors with employees exposed to Chrome Six above the Action Level exposure limits

(see Definitions below) shall have a written program that explains their process for compliance

with applicable standards and with Titan’s requirements detailed herein. Regardless of exposure

limits, contractor:

1. Shall submit written notification of the scope of its Chrome Six work to the Titan

America Safety Department responsible for the work location at least two weeks

before beginning work, and

2. Confirm that its employees performing Chrome Six work, and those who enter a

marked work area, are trained on appropriate OSHA regulations.


Determining Chromium in Paint

Before disturbing paint, use one of the following methods to evaluate paint coating(s) and

determine chromium content:

1. A state-licensed inspector may use state-approved sampling methods.

2. An unlicensed person may take samples using guidelines in Appendix 4.

3. Contractors may rely on manufacturer’s (not supplier’s) statement that the paint is

chromium-free. If multiple types of paint, this is required for each layer.

4. Absence of chromium on a Material Safety Data Sheet may not be used as evidence that

chromium is absent.

5. Analyze samples for total chromium; that value is considered to be the Chrome Six

content.

Work Areas

Contractors shall designate Chrome Six areas with ropes and signs for

1. Hot work jobs, and

2. Any mechanical removal including grinding, sanding, sawing and blasting.




Such areas shall be designated with yellow or white rope and with the black-on-white 15” x

30” sign illustrated below. Contractor will provide these devices.

1. Place rope to restrict all personnel crossing its boundary.

2. Signs shall be visible from any direction.

3. If feasible, use rope and signs to isolate an entire enclosed or confined space.

a. Otherwise, extend ropes at least five (5) feet from each area.

Entry is limited to personnel wearing appropriate personal protective equipment (PPE) who

are trained and have permission of the Prime Contractor and meet applicable requirements. They

are prohibited from having or using food, beverages, tobacco products, gum or cosmetics in work

area. Contractors shall ensure that employees wash hands and faces immediately after contact with

chrome-containing paint.

Engineering Controls

Use engineering controls to restrict potential employee exposure to Chrome Six and minimize

the need for employee manipulation of controls. As required, contractors shall:

1. Use ventilation to capture contaminants, and

2. Regularly inspect ventilation equipment for effectiveness.

a. If ineffective, stop Chrome Six work until repaired.

Chemical Cleaning Provide ventilation when using chemical paint removers and softeners that may contain toxins

and other hazards. If ventilation does not reduce solvent vapors to acceptable safe levels, provide

appropriate respiratory protection and notify the contract coordinator.

Power Tools When sawing painted surfaces, full-face negative pressure respirators must be worn. If

ventilated tools are used, a half-face respirator may be used, provided:

1. Power tools with ventilated shrouds or cups that capture dust and debris are used where

feasible, and

2. Shrouded tools are attached to an appropriate vacuum cleaner.

a. Ensure that minimum dust and debris escape from shroud and ventilation system

b. Ensure that the surface is visibly clean

c. If significant dust or debris escapes, stop operations immediately and correct.

Disposal

Gloves and other non-disposable personal protective equipment must be wiped clean and

removed before leaving the work area. Store reusable PPE separately from other clothing and

equipment.

Debris related to Chrome Six work, including contents of vacuum cleaners, shall be sealed in

properly-labeled bags and disposed per local and federal regulations.

Definitions

Abrasive Blasting – Removal with abrasive media dispersed under pressure. If used in Chrome

Six work, protection normally used in blasting provides adequate safety.

Chemical Cleaning – No power tools used.

Chromate – Chrome Six, a salt or ester of chromic acid when combined with other elements such

as lead, zinc, potassium, sodium, etc. to form Chrome Six.


Chrome – Chromium or an alloy or pigment containing chromium.

Chrome-containing metal – For this chapter, any metal that is greater than 2.5% chromium.

Chrome-containing paint – Primer or other paint with at least 0.05% chromium when dry.

Chrome Six – Chromium of valence state positive six, also called Hexavalent Chromium,

HexChrome, Chromium (VI), Cr(VI), Cr+6 or Cr6+.

Chrome Six Work – Activity that requires compliance with OSHA or with standards herein.

Chrome Six Work Area – As marked by ropes and signs per requirements. Some work may not

require such restraints.

Exposure limits - As established by OSHA:

1. Permissible Exposure Limit (PEL) – 5 micrograms of Chrome Six per cubic meter of air

averaged over eight (8) hours, or 5g/m3, 8-hr time weighted average (TWA).

2. Action Level – 2.5 g/m3, 8-hr TWA. Workers potentially exposed to this level at least 30

days per year must be placed in a medical surveillance program.

Hand Scraping – Removal without power tools.

Hand Sanding – Removal with abrasive pads or paper.

Hot Work – Using an electric arc of flame to heat, burn, cut or weld metal.

Paint removal – Removing dried paint by mechanical, chemical or other methods.

Power Sanding, Grinding and Sawing – Using power tools with abrasive disks/wheels or cutting

through paint surface with saw blade.

Welding, Cutting and Heating

Purpose: To protect employees from toxic emission in such operations. Follow all applicable laws

and regulations.

Typical hazards include:

1. fire and explosion

2. compressed gas

3. electricity

4. hand tool and portable equipment

5. material handling and storage

6. walking and working surfaces

7. toxicity and/or oxygen deficiency

8. non-ionizing radiation

This program addresses only the industrial hygiene issues of toxicity, oxygen deficiency and non-

ionizing radiation. Consult OSHA standards for loss prevention requirements and other safety

hazards of fire and explosion.

Engineering Controls Local exhaust and ventilation usually effectively captures welding, cutting

and heating emissions at their sources. Where ventilation is restricted, use engineering controls.


Respiratory protection must be worn where lead, cadmium, chromium, mercury, zinc,

decomposition products or toxic gases likely emit during welding and cutting, unless local exhaust

or mechanical ventilation have reduced concentrations to acceptable industry standards. For

details, contact Corporate Safety and Health.

Employees shall wear appropriate Personal Protective Equipment such as PPE-protective lenses

adequate for ultraviolet radiation, helmets, gloves, shoes and clothing.

See: www.msha.gov 56.5001, 56.5002, and 56.5005, or www.osha.gov 1910.251, 1910.254,

1926.350, 1926.354.

Section 4

SAFETY RECORDKEEPING AND ADMINISTRATION

Method of Investigating Serious Incidents

The company should investigate all serious incidents in order to:

1. Understand how the incident happened and to identify factors contributing to it;

2. Protect the interests of the company and prepare to defend the company against claims of

liability or wrongdoing.

On-site Coordination

The Safety Manager or other designated person shall:

1. Establish an investigation team at each facility.

2. Conduct investigations per Group guidelines.

3. Assist insurance company representatives in their investigation and ensure that their

activities are consistent with this procedure and respectful of all witnesses.

Photographs

Any injured person should be given appropriate first aid and then removed from the scene

of the injury before any photographs are taken.

Photographs should be taken with discretion.

Photographs should not include needless offensive visual details.

The photographs should not include any persons, equipment, or work areas not directly

involved in the incident or its investigation.

Attorneys or those investigators who do not represent the company should not be

permitted to take photographs without the approval of Titan America legal counsel.

Evidence

All documentary evidence of any kind relating to the incident (including notes, diagrams, tape

recordings, photographs, personnel files, and all other documents and relevant materials,

regardless of their type or origin) shall be identified and carefully preserved.









Such documentary evidence should not be released to anyone except in accordance with the

instructions of Titan America legal counsel.

Witnesses

It should be decided who will interview the witnesses: legal counsel, a representative of

the company's Corporate Safety and Health Department, or an investigator for the

company's insurance carrier.

All witnesses having knowledge of the incident, whether or not they saw it occur, should

be identified as quickly as possible once the scene has been secured.

The witnesses should be interviewed as soon as they have regained their composure after

the incident. Each witness should be asked separately and in private to relate the facts

about the incident to the investigator. The witnesses' comments should be noted and

statements from witnesses with particularly detailed or clear information should be

recorded (either in writing or using a tape recorder).

Independent testimony should be encouraged. Witnesses should be asked not to discuss

the incident with other witnesses since that might prevent them from giving an accurate

account based strictly on their own personal knowledge.

Written witness statements should be recorded on the Employee's Statement of Incident.

On tape-recorded statements, the witness must state his or her full name, the time, and date

of the recording and must expressly grant the company permission to record and transcribe

the statement.

Witness statements should be regarded as the property of the company obtained during the

course of the investigation and in preparation for possible litigation. Except on the specific

advice of Titan America legal counsel, copies of witness statements should not be released

either to the witnesses or to any other persons lacking authority to investigate the incident.

The Safety Manager or the Corporate Safety and Health Department can answer any

questions on who has the authority to obtain copies of witness statements or to investigate

the incident.

Counseling Witnesses

Employee witnesses should be informed that they may be contacted by governmental or private

investigators that want to question them about the incident. These employees should be informed

that they have the right not to discuss the matter except when company representatives and Titan

America legal counsel have the opportunity to be present and participate.

Supervisory Level Employees

Governmental agencies, such as OSHA, MSHA and DOT, may investigate a serious incident for

possible criminal violations. Supervisory personnel and other employees (with the authority to

speak for company management or to make decisions on behalf of company management

regarding the incident) should not make any statements to governmental investigators without first

conferring with the Corporate Safety & Health Director and/or Titan America legal counsel.

Other Employees

The company will not prevent a non-supervisory or non-management level employee from

granting interviews to persons with the authority to conduct a separate investigation of the

incident. However, the Safety Manager should confirm the authority of any such person (such as

government investigators who demonstrate their identity and authority) before they are allowed to

question employee witnesses.


Supervisor’s Incident Investigation Report

This procedure organizes a proactive program to identify causes of incidents, allowing

consistent and effective correction to prevent reoccurrence.

Definitions

"Incident" – An unplanned event that disrupts work flow, may cause injury or property damage,

or may be a near miss with no damage.

“Employee Exposure Records” contain any of the following:

1. Monitoring results of toxic substances (H2S, lead, etc.) and harmful chemical agents

(asbestos, silica, etc.),

2. Biological monitoring results,

3. Material Safety Data Sheets indicating a material may be hazardous, or

4. Chemical inventory or other records that reveal where/when used and identify a toxic

substance or biological agent.

"First Aid" – A one-time treatment and observation of minor scratches, cuts, bumps, splinters,

etc. that don’t ordinarily require medical care.

"Near Miss" – An unplanned work place event with no damage to property, product or personnel.

"Injury" – Damage to a person or body. May be classified as first aid, recordable injury, lost time

injury, permanent disability or fatality.

"Lost Workday Cases" – See appropriate MSHA/OSHA guidelines on Recordkeeping.

"Lost Workdays" – Workdays (consecutive or not) the employee would have worked, but could

not because of occupational injury, not including the day of injury.

"Medical Records" – Employee records containing medical history, reports of injuries and

illnesses, physical exams, physician documents, lab and test results, treatment and follow-up

records and notes, etc.

"Recordable Cases" – See appropriate MSHA/OSHA guidelines on Recordkeeping.

"Restricted Workday Cases" – See appropriate MSHA/OSHA guidelines on Recordkeeping.

"Restricted Workdays" – Workdays (consecutive or not) on which, because of injury: (1)

employee was assigned to another job temporarily, (2) employee worked at a permanent job less

than full time, or (3) employee worked at a permanently assigned job but could not perform all

normal duties, not including the day of injury.

Process

Employees will report incidents immediately to a supervisor, who then reports the event to

the safety manager or business unit safety manager.

In a serious injury, the employee is responsible for notifying their immediate supervisor of

the injury. See “Incident Reporting Procedures” in Appendix. Use the Titan America

“Supervisor’s Incident Investigation Report” to document the incident and investigation.

In the case of loss time injury or major property damage, the safety manager or designee,

and a member of operations will jointly conduct the investigation within 24 hours. Together they

will interview witnesses, take statements and review the incident scene as necessary. At the


conclusion of their investigation, the Safety Manager or designee, and a member of operations will

make recommendations to avoid similar events. Copies of any related documents will be attached

to the Titan America “Root Cause Analysis Form”. Related documents may include STA, Work

Permits and other relevant documents.

A post-incident Drug/Alcohol Test should be administered at the time of treatment or

within 24 hours of the incident. As necessary, state D.O.T. protocols will be followed.

The Titan America “Root Cause Analysis Form” and any other pertinent documentation

will be directed to the business unit safety manager, the Director of Corporate Safety and Health,

Director of Risk Management, and the Group Health and Safety Director. Details of the incident

will be distributed via Safety Alert to all Titan America personnel.

Records Retention

I. Policy Purpose

The purpose of this policy is to establish guidelines governing the retention and destruction of

safety documents and records. The policy is necessary to assure that Titan’s U.S. operations will

retain documents and records in compliance with various state and federal laws and regulations,

and at the same time, to minimize the Company’s document storage burden. The policy addresses

electronic and physical document storage and destruction procedures.

II. Policy Statement

It is Titan’s policy to retain safety records as necessary to comply with all applicable laws and

regulations, and to provide a reasonable history of the company, but not to retain documents and

records longer than necessary for those purposes, thereby minimizing storage space requirements

and expense. This policy is far-reaching and is intended to be a general guideline for each of

the Titan companies. There may be items that are not addressed here. In those instances,

please consult your Business Unit Safety Manager or the Corporate Director, Safety or Legal

Counsel for guidance.

III. Policy Provisions

A. General Overview.

1. Safety Records.

For the purposes of this policy, all safety-related records and documents created or received

in the ordinary course of Titan business are “safety records” governed by this policy. This

pertains to all forms of records, regardless of whether tangible (e.g., handwritten, typed, or

printed), electronic (e.g., e-mail, disks, CDs, databases), video, audio, or otherwise. Safety

records are the property of Titan.

2. Retention Periods – General.

Safety records will be kept, in general, for the period of time designated under applicable

federal and state laws. Those retention periods are set forth on Schedule 1 to this policy.

Safety records that are not subject to specific legal retention periods will be retained as

deemed necessary by the department manager. Note that records subject to litigation,

audit, or other investigation should be retained beyond the normal retention periods,

until such special circumstance is resolved.

3. Retention Periods – Email.

E-mails are treated as any other safety records. Use of e-mail is subject to Policy # MIS 2

and must conform to this policy.


B. Storage and Destruction.

1. Electronic Storage.

Except where explicitly stated in this Policy, safety records may be stored electronically as

deemed necessary by the department manager. For an electronic document to be “valid” it

must be shown that the integrity of the document has been maintained (i.e. not altered).

2. “Boxed” and File Cabinet Storage.

Periodically, and particularly when documents are being packaged for long-term storage,

files and boxes should be clearly marked with the time period to which the records apply,

the type of records contained therein, and if possible, the projected date for destruction or

marked “PERMANENT” if appropriate. The safety department should maintain an index of

the storage boxes for future retrieval and document destruction.

3. Records Review.

The safety department should schedule an annual record review. All records with an expired

retention period become eligible to be disposed of (destroyed) at that time. However, before

any documents are actually destroyed, a check should be made with Legal Counsel to

determine if destruction or disposition of the documents should be delayed due to a lawsuit,

government proceeding, audit, inquiry, or investigation.

4. Proper Disposition.

Records should be disposed of according to the level of confidentiality or content of

proprietary information.

a. Records with no personnel or proprietary information can be disposed of in the

trash.

b. Records containing personnel or proprietary information must be shredded,

incinerated, or disposed of through the use of a similarly permanent, confidential

manner. Our storage facilities may offer confidential destruction for records stored

there after the specific boxes have been authorized for destruction.

5. Oversight/Authority.

It is the responsibility of all supervisors and managers (operational and administrative) to

provide for the proper retention and destruction of documents and records pertaining to their

operations or under their control in accordance with this policy. Each operation should

arrange for appropriate secure storage of documents and records to be retained. Particularly

important records should be kept in fireproof facilities. Requests for clarification, direction

and checking before specific documents are destroyed should be submitted to the relevant

department manager.

C. Departmental Overviews.

1. Insurance and Risk Management.

All documents relating to insurance policies should be retained permanently. This includes

workers’ compensation claims, liability claims, etc.

Consult with the Titan Risk Management Department before destroying any records relating

to insurance matters. All such records should be submitted to the Director of Risk

Management for determination of permanent storage.

2. Other Records – Permanent Retention.

The following should be retained permanently:


a. Policy manuals;

b. Claim files

3. Other Documents – Retention Periods.

The attached Schedule 1 is a table indicating various categories of records and federally

mandated retention periods. Note that there are some records that are kept for research

purposes and not for compliance with record reporting for various enforcement agencies.

Examples of these records include internal audit reports, and various safety documents.

Schedule 1

The following is a list of files which should be retained according to the noted retention period.

Also listed is the department responsible for final approval of the documents destruction when the

destruction date has been reached. In addition, to comply with law we must ensure that no

records or documents are intentionally destroyed or concealed if they are relevant to a

pending investigation, government agency inquiry or audit, judicial proceeding, or civil

lawsuit.

A. SAFETY RECORDS Examples SAF

Administrative Files Memos; Correspondence; Expense

Reports

In accordance with

Policy# LGL 1

Workers’ Compensation Files Incident Reports; Medical Reports;

related documentation; etc.

Permanent

Commercial Automobile and

General Liability Files

Incident Reports; related

documentation; etc.

Permanent

Regulatory Agency Files –

Active

MSHA Forms 2000-7 and 7000-51;

MSDS

Permanent


Litigation

Inspections; Citations 6 years


Exposure Monitoring

Noise Exposure – Site Surveys –

Airborne Monitoring

30 years


Medical Surveillance

Audiometric Testing Employment +

1 year

Reports to Regulatory

Agencies

MSHA Forms 7000-1 and 7000-2;

OSHA Forms 300, 300A and 301

6 years

Safety Meeting Files Safety Meeting Sign-In Sheets;

STAs; related documentation; etc.

2 years

Safety Training Files Part 46 New Miner Training; related

documentation; etc.

Employment +

1 year


See: www.osha.gov 1904 and 1910.1020, www.msha.gov 46.9, 56.18002, 62.171(b) and 62.190.

Section 5

SAFETY AND HEALTH TRAINING

New Employee Orientation

All new employees will be trained on how to safely accomplish their assigned tasks and

responsibilities.

1. MSHA Mine-Specific Training Plans

a. New miner training

b. Task training

c. Site-Specific Hazard Training

d. Annual Refresher Training

2. OSHA Training

a. Ready-Mix employees

b. Block plant employees

c. New Hire Safety Orientation

3. New engineer orientation

4. Office and administrative orientation

5. New Driver Training Program for Ready Mix Drivers

Safety Meetings

Plant management will conduct safety meetings for all employees at that location at least

monthly; weekly safety meetings are preferred.

1. First Aid and doctor's cases that have occurred since the previous meeting:

a. Principal causes of incidents.

b. Better prevention methods for management.

2. Frequent serious, non-serious and repeat safety violations, including corrective action

needed to avoid recurrence.

3. Monthly discussion topics and handouts. Topics will target site-specific needs.

4. Resolution of valid safety suggestions.

Attendance is mandatory and attendance sign-up sheets and topics will be retained on site.

Meetings will encourage group discussion of methods, problems and solutions.

Safety Task Assessment Program

The Safety Task Assessment (STA) Program promotes discussion of safety practices when

assigning a task. Should the scope of work or conditions change, a revised or new STA must be

completed.

STA uses an awareness campaign to ensure that all employees responsibly analyze each

work assignment for hazards and identify sound safety practices before they start the task. This

proactive assessment is integral to Titan America’s safety process. It will be used on every Titan

America site.

An STA must be performed at the beginning of each shift and prior to beginning a non-

routine task. A non-routine task is a task performed infrequently or involves high risk activities.

http://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=STANDARDS&p_toc_level=1&p_keyvalue=1904




http://www.msha.gov/30CFR/62.171.htm

http://www.msha.gov/30CFR/62.190.htm


STA Process

The magnitude of a job determines the extent of the Safety Task Assessment. Before

starting a new task, each work group and its supervisor will analyze all jobs for hazards and

determine what safety measures to take. Complex tasks may require detailed measures and

explanations. Other tasks may need only brief descriptions.

Management will ensure that hazards and preventive measures are explained and

understood by each employee involved.

1. Employees will be able to demonstrate a thorough understanding of all safety

instructions.

2. Management will encourage employee participation and solicit their input.

3. Management will ensure that needed safety procedures, equipment and training in its

proper use are provided to employees as discussed during the Safety Task

Assessments.

STA Implementation

New employees—The STA policies and procedures will be included in each job site's New

Employee safety orientation. Management will discuss a task's potential safety hazards and

precautions before beginning new work or whenever tasks change.

NOTE: If not already supplied, the employee should ask for the STA before beginning work.

New supervisors/management—On assignment to a job site, each new supervisor or member of

management will get an orientation fully explaining the principles of the STA process provided by

a designated representative with guidance from site safety or management.

Pledge Poster—Upon completion of the STA orientation, each supervisor or member of

management will sign and date a Pledge Poster for the department or facility and place it in a

conspicuous location. A STA Procedures Poster will also be given at this time.

Promoting Safety

Each facility will:

1. Maintain an STA pledge poster signed by each supervisor or member of management.

2. Maintain an STA procedures poster.

Follow-up

Each facility will develop a plan for monitoring the STA Process to ensure the procedure

is fully implemented. Facilities will continually stress the concept, procedures and importance of

STA in safety meetings.

Section 6

INTRA-PLANT RAIL SWITCHING PROCEDURES

This supplement to other plant safety rules outlines procedures for safe movement and storage of

railcars within plant areas using switch crews who ensure safe movement.

Responsibility: Before using these procedures, Shift Supervisors or Department Managers shall

ensure that all affected team members are trained and that employee signatures are documented.


Definitions

“Switching” – movement of switching vehicles and railcars on exterior tracks within the plant and

on shipping tracks, as well as line pulls within buildings.

“Exterior Track” – all tracks outside a building.

“Load Out” – tracks in buildings on which regularly scheduled load out of railcars is performed.

“Three Point Protection” – precautions taken by the switch vehicle operator to ensure protection

of grounds persons during switching operations. Three point protection of the switch engine

requires applying the emergency brake, putting the transmission into Neutral and placing the

run/start switch in the Start position.

The forward end of switching vehicles shall display a graphic letter “F”. The direction opposite

forward shall be referred to as “back”.

During all switching activities a designated grounds person shall use the switching terminology

below. During long backward movement of railcars without coupling, the grounds person shall

protect the end opposite the switching vehicle and every fifteen (15) seconds shall communicate to

switch operator that everything is okay, to continue coming back. When back-most car gets to

three (3) car lengths of a pad or a car to be coupled, the grounds person shall begin announcing the

following sequence:

“You have three (3) cars”

“You have two (2) cars”

“You have one (l) car”

“You have half (1/2) a car”

“Give me ten (10) feet”

“Give me five (5) feet”

“Give me four (4) feet”

“Give me three (3) feet”

“Give me two (2) feet”

“Give me one (l) foot”

“Good! / Contact!”

Authorized Equipment and Team Members: 1. Only trained employees are authorized to operate switching vehicles or act as switch

crew personnel.

2. Use only designated vehicles for all switching. Use of equipment other than a switch

engine shall be done only under the direction of the Department Manager/Shift

Supervisor.

Equipment Preparation

Before each shift, the switch crew shall make a mechanical and visual check of the

switching vehicle to ensure it is working. Crew shall complete the checklist and report problems to

management before switching.

1. Defective switches or track in bad repair must be reported immediately.

2. Switch crew shall check for obstructions and remove from the rails.

Radio Communications:

1. At the start of each shift, the switch crew must verify that all radios work.


2. The switch crew must maintain radio or visual contact at all times. Unclear or

improper radio transmissions or hand signals, or absence of signals, shall be regarded

as a Stop signal.

3. If an operator loses contact with a switchman, stop the switch vehicle until contact is

re-established.

4. Only a supervisor or member of management may communicate with switch crew by

radio. The supervisor or member of management must wait 10-15 seconds to ensure

switch crew is not interrupted during a move.

5. All movement commands shall contain a direction of travel—only “Forward” or

“Back”.

Operating Switches

All manual switches must be thrown for movement in the intended direction.

1. Grounds person shall visually check switch to ensure a tight point.

2. Grounds person shall visually check railcars and switching vehicle to ensure intended

movement.

Safe Movement – Responsibility and Teamwork Safe movement of rail cars is the sole responsibility of the switch crew, shared by each

individual and the whole team. A crew typically involves ground personnel and engine operators.

1. Before switching, crew members must ensure that railcars and the general area are

clear of people, derailers and such objects as tools or equipment that could obstruct the

track.

a. If area cannot be cleared, crew shall immediately report conditions to

management.

2. Switch vehicle operator shall begin movement only after receiving appropriate radio

or hand signals from the grounds person.

3. Switch vehicle horn must be sounded before starting a move, or when entering or

exiting buildings, approaching crossings and where personnel are working. Continue

to sound horn through all crossings.

a. Prior to entering a doorway, operator must stop switching vehicle and proceed

only after entry has been cleared by grounds person.

4. Grounds personnel have primary responsibility to maintain a clear area while rail cars

are moving. All ground crew shall stay a minimum of four (4) feet or more away from

moving rail cars.

5. The switch crew must maintain rail car movement at a controlled speed, and is

responsible for safety of vehicles and loads.

a. Unstable loads must be reported to management immediately and shall not be

moved until stabilized.

6. While the switching vehicle is pushing cars, grounds person shall ride on the side of

the rail car. When pulling cars, riding on the trailing end or a side is acceptable.

Loadout Switching

Grounds person must enter the building on foot and clear the line before authorizing

switch engine operator to sound warning horn to enter building.

1. Grounds person shall be on the ground whenever switch engine is in the building.

2. Grounds person must ensure all doors are fully open and appropriate signals are

sounded.

3. A person may cross a line during switching only when directed by the switch crew.

Coupling, Uncoupling, & Chocking

When coupling railcars, switch crew shall confirm the couple by stretching out each

railcar before proceeding. Coupling or uncoupling moving railcars or drifting is prohibited.


1. Hand brakes or chocks shall be applied to prevent cars from drifting.

2. Chocks shall be placed on the hand brake side of the railcar when inside a building.

3. Grounds person must never cross between couplers of any railcars during switching.

To get to the opposite side:

a. If equipped, climb up the ladder and across the walkboard.

b. If the railcar lacks ladders or walkboard, go to the end of the train to cross. Ensure

a minimum of one car length between cars to cross.

4. While coupling or uncoupling, grounds person shall maintain a parallel line of sight in

both directions down the sides of the railcars.

5. Placing any part of the body between a coupler or another pinch point is forbidden.

Align or adjust coupler from the side, or after eliminating the pinch point.

6. When railcars are spaced or uncoupled for rework or inspection, use the BLUE FLAG

procedure:

a. Distance between couplers must be at least 36 inches.

b. When positioned, immediately set hand brake or chocks.

c. Place chocks on hand brake side of the railcar to allow inspection or re-work.

Mounting and Dismounting Moving Vehicles Mounting and dismounting shall be done only while vehicles are moving at a normal

walking speed. Grounds person shall not attempt a mount or dismount on uneven surfaces or

during bad weather, to avoid tripping or slipping.

1. Mounting moving railcars or switch vehicles

a. When mounting a moving switch vehicle, grounds person shall advise the switch

vehicle operator to maintain a slow speed.

b. As the approaching car reaches arms length, the grounds person shall grab ladder

or handholds on each side of the rung with both hands.

c. Place a foot into corner on ladder of approaching car (as if to “stop” it) to prevent

foot from sliding across the step or ladder.

d. Place other foot into the same ladder. Establish a wide stance.

e. If riding the side of the railcar any distance, pass one arm through the ladder rung

and hold at the elbow. If the arm cannot pass through, maintain both handholds at

all times, except when using radios or dismounting.

f. When mounting a railcar at a switch or near other obstructions, you must mount

car on the end moving away from the obstruction to prevent tripping or serious

injury.

2. Dismounting moving railcars or switch vehicles

a. When dismounting a moving car, advise the switch vehicle operator to maintain a

slow speed.

b. When nearing the dismount, the trailing foot in the direction of travel shall touch

the ground first.

c. The hand diagonally across from the trailing foot shall release the handhold and

the other foot shall be placed on the ground at a walking pace.

d. The other hand now shall release its grip. Continue at a walking pace, away from

the vehicle.

Operating in Severe Weather

The switch crew is responsible to notify management or the Safety Manager of hazardous

weather, e.g. lightning, high winds or icy conditions. Management or Safety Manager shall

determine when to halt and resume switching.


Safety and Training

Safety Managers shall provide rail safety training for all appropriate employees.

Management is responsible to ensure all such employees are trained.

1. Management shall review these procedures when new railcar types are produced.

Involve the Safety Department as necessary.

2. Management is responsible to provide switch procedure training for employees

operating such vehicles.

3. Hardhat and hand protection may be removed in the switch vehicle cab.

4. Switch crew must report all derailments, equipment damage, near misses, and

incidents to management, who shall complete an incident report. Safety Manager shall

investigate.

5. Never go under any rail car or locomotive unless the car is isolated, disconnected and

wheels are chocked. A derailer must be at least 50 feet from the railcar.

Appendix

Incident Reporting Procedure

REPORTING

Employees: Report incidents, in writing, to your Supervisor prior to the end of your work shift on

the day of the occurrence.

Supervisors: Notify the appropriate Safety Manager via cellular phone immediately, compile the

required forms and fax them to the Safety Department within 24 hours.

REQUIRED FORMS

INJURY, ILLNESS, AND PROPERTY DAMAGE

1. Employee Statement of Incident

Employee, fill out this form when an incident that results in injury, illness, or property

damage occurs.

2. Supervisor’s Incident Investigation Report

Supervisor, fill out this report when an incident that results in injury, illness, or property

damage has been reported to you.

3. Medical Provider Authorization

Supervisor, fill out this form whenever you refer an employee for medical treatment

and/or a drug test. Give a copy of the form to the employee to present upon arrival at the

clinic and/or drug testing site.

4. Safety Task Assessment (STA)

Supervisor, obtain a copy of the STA form that was completed for the day and/or work

activity in which the injury, illness, or property damage occurred.

NEAR MISS

1. Near Miss Incident Notice


Employee, fill out this form when a near miss incident occurs.

LOCATING FORMS

Electronic Copy: Electronic copies of the above forms are available on Insight. Click on the Safety

link located on the left-hand side of the homepage under the Departments section heading. On the

Safety homepage, click on the Safety Forms tab located on the right-hand side. Alternatively, you

may access the forms directly by clicking on the following link: Safety Forms.

Hard Copy: Hard copies of the above forms are available at your Supervisors office.

RETENTION, STORAGE, AND DESTRUCTION OF RECORDS

The retention, storage, and destruction of incident forms and associated documentation are

governed by Policy # SAF 11–Safety Records Retention. For further information, refer to the Titan

America Safety and Health Reference Manual. Access it on the Safety page in the Departments

section of Insight.

Roanoke Cement Outage Best Practice

1. The plant holds a pre-outage meeting in which it discusses contractors that will be onsite and

ensures that they have all been pre-qualified.

2. Based on the start date of the outage, contractor site specific classes are scheduled to ensure

ALL outage contractors (even if they have already been trained) receive site specific training

prior to setting up onsite and prior to beginning work. The training session lasts 45 minutes.

3. Contractor site specific classes are held daily starting at 7:00 am and as needed thereafter until

all contractors have been trained. Off-shift classes are held as needed.

4. Contractors are trained on safety procedures at the plant, emergency procedures, no tolerance

policies (Lockout Tagout, Fall Protection, Red Danger Tape, etc.), and parking procedures.

Training verification is conducted to ensure that contractors meet all MSHA and State required

training prior to beginning work. Plant supervisors or project managers then address any

additional site specific requirements with contractors at their work location.

5. Contractors are allowed to set up at specified locations where they have been designated after

meeting the above requirements. Any electrical hook-ups are done by Titan America electrical

personnel. Contractors are required to have conductivity testing completed on all hand tools

prior to use. Conductivity can be done by contractors or by Titan America electrical personnel.

6. Safety professionals (minimum of 4) that consist of a combination of business unit safety

managers, cement plant safety managers, and regional safety managers will be on site for the

first week of all Titan America cement plant full outages.

7. Contractor equipment and facilities will be inspected by Titan America safety personnel, and

any deficiencies corrected immediately, during the first week of the outage.

8. Titan America supervisors responsible for outage projects will also have safety oversight for

their projects. They are required to do continuous walkthroughs of the work areas to ensure

safe work practices.

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9. Safety professionals will be onsite during ALL critical operations and will have 24-hour

coverage during the first week of outage. They are required to do continuous walkthroughs of

the work areas to ensure safe work practices.

10. Daily outage meetings are held to address any concerns involving operational or safety

matters. A safety professional will attend ALL outage meetings to ensure any safety issues are

addressed and any corrective actions are implemented.

11. All safety issues during outage are corrected immediately. Contractors violating company

rules or engaged in unsafe work practices are both counseled and corrective action taken or if

necessary removed from the property and banned from returning. (Violation of no tolerance

policy or violation deemed serious.)

12. Post-outage meetings are held to discuss any operational or safety related issues, address any

contractor issues, and identify any changes to improve future outages.

Sampling Paint to Determine Chromium Content

1. Obtain three (3) samples of each color of paint from each functional area and do not combine

them. To determine Chrome Six impact, use results from the sample having the highest

percentage of chromium. A single sample of each color is sufficient for contiguous areas of

approximately ten (10) square feet or less.

2. Samplers shall wear impermeable gloves. Coveralls may be necessary if collecting many

samples or overhead samples. At a minimum, face shields or goggles are required for overhead

work.

3. No food, drink, tobacco products, cosmetics or personal items shall be stored or used in areas

where paint samples are taken, or elsewhere if they could be contaminated.

4. Procedures for sampling:

a. Mark off an area that provides enough paint to analyze, based on laboratory requirements

to detect limits of 0.05%. Avoid areas where rust has caused blisters or paint does not

adhere to the surface.

b. Using a knife, score paint around the edge to define area, then remove paint inside area

down to bare metal.

c. Collect chips and shavings of all paint from each layer in a sample bag.

d. Identify each sample location and its bag with matching numbered stickers.

e. Remove paint chip residue from disposable coveralls, gloves and other PPE, then dispose

as non-hazardous waste.

f. Maintain and leave area as free as possible of chip debris and other contamination. Collect

debris for hazardous waste determination.

g. After all sampling, personnel shall wash hands and faces.


h. Analyze paint chip samples at a laboratory accredited by the American Industrial Hygiene

Association (AIHA) to analyze lead.

Chemical Inventory Form Example

Plant: Date:

Manufacturer Product Name Trade or Common Name Area Used


CONFINED SPACE ENTRY PERMIT EXAMPLE

GENERAL INFORMATION

Space to be entered: Purpose of entry:

Location/Building: Authorized Duration of Permit (hr/min):

Time In: Time Out:

PERMIT SPACE HAZARD EQUIPMENT REQUIRED FOR ENTRY AND WORK

Oxygen deficiency (< 19.5%) Specify as required:

Oxygen enrichment (<23.5%)

Gases or vapors (> 10% of LFL) Personal Protective Equipment:

Airborne combustible dust (meets or exceeds LFL)

Toxic gases or vapors (> than PEL) Respiratory Protective Equipment:

Mechanical Hazard

Electrical Shock Atmospheric Testing/Monitoring:

Hot Work

Materials harmful to skin Communication:

Engulfment

Other Rescue Equipment (harness, lifeline retrieval equipment):

PREPARATION FOR ENTRY COMMUNICATION PROCEDURE

Notification of affected departments of service interruption: Method to be used by attendants and entrants:

Isolation Methods AUTHORIZED ENTRANTS

Lockout Purge/Clean Inert

Blind/Blank Barriers Ventilate

Atmosphere Test

Personal Awareness AUTHORIZED ATTENDANTS

Pre-entry briefing on specific hazards and control methods

Notify contractor(s) of permit and hazard conditions

Other:

Communication: EMERGENCY SERVICES

Additional permits required and/or attached: Telephone:

Hot work Line Breaking Other Method of Contact:

TESTING RECORD


Acceptable Conditions

Results AM/PM

Results AM/PM

Results AM/PM

Results AM/PM

Results AM/PM

Results AM/PM

Results AM/PM

Oxygen – Min. >19.5%

Oxygen – Max. <23.5%

Flammability <10% LEL/LFL

H2S <10 ppm

Toxic (Spec.)

CL2 <0.5 ppm

CO <35 ppm

SO2 <2 ppm

Heat F/C

Other

Tester’s Initial

AUTHORIZATION BY SUPERVISOR

I certify that all required precautions have been taken and necessary equipment is provided for safe entry and work in this confined space.

PRINT NAME SIGNATURE DATE TIME

THIS PERMIT MUST BE POSTED ON THE JOB SITE (IT IS GOOD FOR THE DATE INDICATED ONLY)

Permit-Required Confined Space Reclassification Form

Name of Confined Space:

Location of Confined Space (be specific):

Description of work activity:

Minimum Conditions for Reclassification

If conditions are not met, then an entry permit is required.

Oxygen Minimum 19.5% and Maximum 23.5%

Flammable gases No greater than 10% of LFL

Carbon monoxide (CO) No greater than 50 ppm

Hydrogen sulfide (H2S) No greater than 10 ppm

Other toxic substances No greater than PEL for substance

Flammable dusts Must not reduce visibility to <5’

Engulfment hazards No engulfment hazard may be present

Hazardous flows Must be secured and locked/tagged out

Hazardous energies Must be secured and locked/tagged out

External hazards External hazards must be controlled

Certification of Hazard Elimination

Hazard Verification of Hazard Elimination

Hazardous atmosphere Eliminated Yes [ ] No [ ]

Entrapment hazard Eliminated Yes [ ] No [ ]

Engulfment hazard Eliminated Yes [ ] No [ ]

Hazardous energies Eliminated Yes [ ] No [ ]

Other serious hazards Eliminated Yes [ ] No [ ]

Work-created hazards Eliminated Yes [ ] No [ ]


Reclassification of a permit-required confined space requires a minimum of three (3)

separate entries with three (3) readings per entry.

Record of Confined Space Air Testing

Date Time Instrument % Oxygen % LFL ppm CO ppm H2S

Record of Confined Space Air Testing

Date Time Instrument % Oxygen % LFL ppm CO ppm H2S

Note: If there are any changes in the use or configuration of this Non-Permit Required Confined Space

that may increase the hazards to entrants, it must be re-evaluated. Introducing hazards (i.e. welding,

cutting, electrical components) will automatically mandate an entry permit.

I certify that all known or potential hazards have been appropriately eliminated prior to entry into the

above confined space, thereby allowing for the reclassification of the space as a Non-Permit Required

Confined Space:

Reclassification Authorized By: Date:

Safety Manager


Emergency Contact Information:

HOT WORK PERMIT Issue Date: Expiration Date:

Building / Room / Location:

Description of “hot work” or spark producing work:

Name and Company of hot-work operator:

Is a fire-watch required? Yes _____ No _____ A fire-watch should be posted if:

Combustible materials within a 35-foot radius cannot be removed

Wall or floor openings within a 35-foor radius expose combustible materials, including concealed spaces in walls or floors

It is deemed necessary by the Permit Authorizing individual. If a fire-watch has been posted during hot work operations, it must remain for 30 minutes after work has been completed.

N/A Yes No

1. Has a Non-Routine STA been completed and available?

2. Have all affected personnel been notified? (Permits To Work)

3. Has Lockout / Tagout and Blinding procedures been followed?

4. Have combustible / flammable materials been removed from area?

5. Has equipment flushed / drained / vented / purged?

6. Has equipment been grounded / inspected?

7. Is spark containment adequate / required for area?

8. Is there a fire extinguisher in area of hot work?

9. Will vehicle entry be needed in area? (Aerial Platform, forklift, etc.)

10. Is all required PPE available for task? (Shields, Goggles, Gloves, etc.)


Additional Safety Precautions:

Gas Detection Time % PPM Time % PPM Time % PPM Time % PPM

Oxygen

LEL

CO2

Supervisor Approval:

Permit Issued By:

Work Completed: Date: Time: am / pm

Crane Inspection Form Example

ITEM GOOD NOTE COMMENTS OR AMOUNT ADDED

Engine Oil

Fuel

Hydraulics

Coolant

Cylinders

Transmission

Blocks

Hoist Cable

Aux. Cable

Anti-Two Block

Booms

Cable Drums

Sheaves

Glass

Lights

Mirrors

Wipers

Swing Brake

Boom Rotation

Outriggers

Floats

Load Charts

Oper. Manual

Backup Alarm


Fire Ext.

Steering

Tires

Cab/ Clean

Pins/ Mount

General Cond.

Hr. Meter

Jib

Date:

Lift Assigned:

Operator:

Hepatitis B Vaccine Declination Form Example

I understand that due to my occupational exposure to blood or other potentially infectious

materials, I may be at risk of acquiring Hepatitis B Virus (HBV) Infection. I have been given the

opportunity to be vaccinated with Hepatitis B vaccine at no charge to myself. However, I decline

Hepatitis B vaccination at this time.

I understand that by declining this vaccine, I continue to be at risk of acquiring Hepatitis B, a

serious disease. If in the future I continue to have occupational exposure to blood or other

potentially infectious materials and I want to be vaccinated with Hepatitis B vaccine, I can receive

the vaccination series at no charge to me.

Employee Name (Print) Social Security Number

Employee Signature Date

Supervisor Name (Print) Location

Supervisor Signature Date

Lockout/Tagout Inspection Checklist Example

Plant Name: Plant:

Inspection conducted by: Date:

Machine or equipment being repaired or serviced:

Type of work being done:


List employees performing the work and whether or not they were following proper procedures

according to their instructions and training:

Name Yes No Name Yes No

List any deficiencies noted and any retraining that was given:

Signature

PPE Hazard Assessment Form Example

Date: Location:

Job title: Conducted by:

Specific task performed for this job at this location:

Hazard assessment and selection of Personal Protective Equipment (PPE)

I. Overhead Hazards

Hazards to consider

include:

Suspended loads that could fall

Overhead beams or loads that could be struck against

Energized wires or equipment that could be struck against

Employees working at elevated heights that could drop

objects on others below

Sharp objects or corners at head level

Hazards identified:

Head Protection

Hard Hat Yes No

If yes, what type:

Type A (impact and penetration resistance, plus low-voltage electrical insulation)

Type B (impact and penetration resistance, plus high-voltage electrical insulation)

Type C (impact and penetration resistance)

II. Eye and Face Hazards

Hazards to consider

include:

Chemical splashes

Dust

Smoke and fumes

Welding operations

Lasers/optical radiation

Bioaerosols

Projectiles

Hazards identified:

Eye Protection


Safety glasses Yes No

Safety goggles Yes No

Face shield Yes No

SOMA Medical Standards Program

All documents and forms are available on Insight. Click on the Safety link located on the left-hand

side of the homepage under the Departments section heading. On the Safety homepage, click on

the SOMA Medical Standards Program tab located on the right-hand side. Alternatively, you may

access the forms directly by clicking on the following link: SOMA Medical Standards Program.

Miscellaneous Safety Documents and Forms

All other safety documents and forms not found in this reference manual are available on Insight.

Click on the Safety link located on the left-hand side of the homepage under the Departments

section heading. You may access Insight by visiting the following link: Safety Forms.

Letter of Thanks

Titan America wants to thank Michael T. Heenan and his publisher MineWorks Media for

permission to use/reproduce/incorporate his suggestions and practices for identifying and

preventing hazards in the workplace.

As an accomplished attorney and an acclaimed author and speaker on pertinent safety

issues, Mr. Heenan is prominent among today’s authorities on workplace safety. Titan America,

it’s Department of Corporate Safety and Health, and its employees and associates are indebted to

Mr. Heenan for his generous cooperation in developing critical/certain portions of the Appendix in

this Safety Manual.

Mr. Heenan enjoys an esteemed reputation among safety managers, domestic and foreign,

and we are pleased and honored to incorporate concepts that may help Titan America

develop/create the industry’s best safety-first culture and a safer working environment for all.

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Safety and

Health at

Mines A Manual for Operators and Contractors

SECOND EDITION

Surface Metal and Nonmetal Operations


By

Michael T. Heenan, Esq.


SECOND EDITION

Safety and Health at Mines A Manual for Operators and Contractors

Surface Metal and Nonmetal Operations

By

Michael T. Heenan, Esq.

SECOND EDITION 2003

This edition has been revised and updated for consistency with new HSHA regulations at 30

C.F.R. Part 46 (Training and Retaining of Miners Engaged in Shell Dredging or Employed at

Sand, Gravel, Clay, Colloidal Phosphate or Surface Limestone Mines), 30 C.F.R. Part 47

(Hazard Communication-HazCom) and 30 C.F.R. part 62 (Occupational Noise Exposure)

PUBLISHER’S NOTE: The original approach has been continued in this revised and

updated edition of Safety and Health at Mines. This manual is designed to make the

requirements of mine safety and health law readily accessible and manageable for

supervisors and contractors at mines. It focuses on day-to-day requirements. To set up

required comprehensive programs for training, hazard communication or noise control,

the official text of the regulation must consulted.


Copyright © 2003 MineWorks Media and Michael T. Heenan, Esq.

All rights reserved. No portion of this book may be reproduced or used in any form of by any

other means-graphically, electronically or mechanical, including photocopying, recording,

taping or information storage and retrieval systems-without the written permission of the

author or publisher.

Printed in the United States of America

ISBN 0-9742054-0-0

Published by MineWorks Media

MineWorks Media is a publishing company and marketing enterprise specializing in print and

electronic information services for the mining industry.

For additional copies, please e-mail [email protected] or go to

www.mineworksmedia.com.

Price per copy is $24.95

$21.95 for 4-6 copies

$17.95 for 7 + copies


Table of Contents

PREFACE………………………………………………………………....…....i

INTRODUCTION…………………………………………………...…...……1

PART I- REMEMBER THE FOLLOWING………………………...………2

Chapter 1 - Make the MSHA Connection..................................................….....3

Chapter 2 – Establish a Safety Program……………………………………..…5

Chapter 3 – Perform Training………………………………………………..…7

Chapter 4 – Perform Work-Area Examinations……………………………….10

PART II – ESTABLISH PRUDENT PRACTICES

Chapter 5 – Control Ground Conditions…………………………………….…14

Chapter 6 – Prevent Fires……………………………………………………....16

Chapter 7 – Maintain Air Quality……………………………………………...18

Chapter 8 – Limit Noise………………………………………………………..20

Chapter 9 – Use Caution with Explosives……………………………………...22

Chapter 10 - Be Careful with Drilling Equipment…………………..………….25

Chapter 11 – Take Care with Mobile Equipment……………………......……..27

Chapter 12 – Make Travelways Safe…………………………………………...30

Chapter 13 – Be Cautious with Electricity……………………………………..32

Chapter 14 – Make Machinery and Equipment Safe…………………………...34

Chapter 15 – Avoid Danger from Materials…...………………………………..37

Chapter 16 – Maintain a Safe Work Environment……………………………...39

Chapter 17 – Use Personal Protective Equipment………………………………41

Chapter 18 – Maintain Sanitary Conditions……………………………………..43


TABLE OF CONTENTS (cont.)

PART III – LAW AND ADMINISTRATION……………………………..45

Chapter 19 – Report Accidents………………………………………………46

Chapter 20 – Report Occupational Injuries and Illnesses……………………48

Chapter 21 – Keep Records………………………………………………….50

Chapter 22 – Protect Miners’ Rights ………………………………………...52

Chapter 23 – Understand Enforcement………………………………………54

Chapter 24 – What is Criminal Conduct?........................................................57

Chapter 25 – Know Your Rights…………………………………………….59

Chapter 26 – Recognize the Supervisor’s Responsibility……………………61

Chapter 27 – Develop a Workplace Culture of Safety………………………63

CONCLUSION………………………………………………………………65

BIBLIOGRAPHY……………………………………………………………66

APPENDIX

CONTRACTOR INFORMATION AND ACKNOWLEDGEMENT FORM…………………………………...70


PREFACE

Safety at mines depends upon three things: 1) elimination of conditions that may cause injury

or illness, 2) training and encouraging employees to be careful, and 3) meeting the

requirements of law. The Federal Mine Safety and Health Act is the primary governing law.

It is enforced by the Mine Safety and Health Administration (MSHA). As directed by

Congress, MSHA has promulgated a full spectrum of rules to foster safety at mines.

Given the “legalese” that is so often encountered in regulations, and the myriad interpretations

by MSHA and the courts, it is hard to know and keep track of all that must be done.

Moreover, there are special concerns related to independent contractors who come on mine

property to do specialized work. If focused attention is given to safety, the possibilities of

costly MSHA enforcement actions, workers’ compensation claims and civil liability suits can

all be minimized. MSHA enforcement brings with it a variety of serious problems.

Violations of law may lead to government investigations. These, in return may result in civil

and criminal penalties against whoever is responsible. This may be either the operator or an

independent contractor on the property or both. Moreover, operator and contractor agents

may be prosecuted personally in serious cases. Even though contractors may not be doing

anything related to mining, they are still subject to MSHA enforcement. Indeed, by reason of

their performing services or construction at mines, contractors are by law “operators” directly

subject to MSHA enforcement.

Many mine operators have expressed a need for a way to communicate to contractors (and

their own employees) the breadth of their responsibilities under federal law. This book makes

the law accessible even to persons who do not work regularly at mines. It provides

information on critical federal safety requirements. For ease of use, the text is straight

forward and no legal citations are included, except generally in the Bibliography.

The introduction to this manual (and occasionally the text) is directed to the “first time

contractor.” However, the book is for everyone at mines. It will aid in compliance, work

inspections and training. It is intended to help mine operators and contractors.


INTRODUCTION

To the first-time contractor:

You are entering “MSHA-land.” It is unlike any place you have worked before. The rules are

serious and the federal government checks on you no less than two to four times per year. In

MSHA-land, you are an “operator” and therefore have direct and immediate responsibility to

comply with the law.

Surprise inspections may occur at any time. Employees may bring charges against you.

Special investigations for “knowing” or “willful” violations are commonplace. Managers and

supervisors have gone to jail to such violations. Contractors have faced hundreds upon

hundreds of thousands of dollars in fines – as have the mine owners who engaged them.

Private lawsuits may follow.

This book explains what you should do to comply. Even experienced mine operators know

that learning the requirements is a continuing and frequently confusing process. But

regardless of whether you are going to be on mine property for day, months or years, you must

comply.


PART I

REMEMBER THE FOLLOWING

The Mine Safety and Health Administration (MSHA) is an agency of the federal

government that regulates the safety and health of “miners.”

You and your employees are “miners” if and when any of you go on mine property to do

any kind of work.

Moreover, you are an “operator” at the mine subject to MSHA regulations. If you do not

comply, you will risk substantial civil and criminal penalties.


CHAPTER 1

Make the MSHA Connection All mines must register with MSHA and obtain a “Legal Identification Number.”

Independent contractors working at mines do not have to register, but if a contractor is

cited by an MSHA inspector for a violation, a legal identification number will be

assigned to the contractor at that time.

Many Independent Contractors voluntarily register with MSHA as soon as they are

going to begin work on mine property. Sometimes registration with MSHA is a

condition of the contract with the mine operator. In other cases, contractors register

with MSHA so that they can obtain a legal identification number that can be used at

every mine. It is a good way to establish a basic qualification for mine work.


CHAPTER 1

MAKE THE MSHA CONNECTION

The first steps toward compliance with MSHA are as follows:

Obtain the MSHA Regulations.

Ask the mine operator for the local MSHA office.

Obtain an identification number from MSHA.

Find out from MSHA what else you need to do.

Find out what training your employees will need.

Find out what records and reports are needed.

NOTE: Although it is not mandatory for contractors to register with MSHA,

establishing an independent relationship with MSHA from the beginning will facilitate

compliance and avoid problems.


CHAPTER 2

Establish a Safety Program

MSHA Regulations do not mandate affirmative safety programs, but safety programs

are a way to take control of safety and manage compliance with MSHA requirements.


CHAPTER 2

ESTABLISH A SAFETY PROGRAM

Create your own safety program. This is the first step to managing safety and health.

Indentify the greatest hazards in your work.

Decide how you will minimize them.

Indentify the MSHA regulations that apply to your work.

Decide how you will comply.

Train employees regarding requirements.

Remind employees of requirements regularly.

Make sure supervisors comply with the requirements.

Correct any employee who acts unsafely.


CHAPTER 3

Perform Training

In every fatal accident investigation, MSHA checks to see if employees were fully and

properly trained. MSHA has policies related to contractor employee training. You need

to check with MSHA as to how they apply to you and your employees.


CHAPTER 3

PERFORM TRAINING

There are five basic types of training required by MSHA.

1. HAZARD TRAINING

Everyone who goes onto mine property needs to be briefed on the hazards they may

encounter.

2. NEW EMPLOYEE INDOCTRINATION

Persons who are newly hired for work on mine property must be indoctrinated in safety rules

and safe work procedures.

3. COMPREHENSIVE MINER TRAINING

Contractor employees who are exposed to mine hazards for frequent or extended periods must

be fully trained by an approved instructor under an MSHA approved training program. Also,

refresher training must be provided every 12 months.


CHAPTER 3

PERFORM TRAINING

4. TASK TRAINING

Persons must be trained before they perform new tasks. Some persons who may have

received prior training in a task may nevertheless not be deemed qualified. Prior task training

will only be acceptable to MSHA if the individual has demonstrated safe work procedures in

the task within the preceding 12 months.

5. FIRST AID TRAINING

Selected supervisors must be trained in first aid and such training must be also available to all

other interested employees.

NOTE: With the exception of training regarding site specific hazards, training obtained

to qualify for work at one mine will meet requirements for other mines as well. All

training should be documented. In every case where MSHA has enforcement authority,

required records must be available to MSHA inspection.


CHAPTER 4

Perform Work-Area Examinations

Very often, when MSHA inspectors find violations at mines, they conclude that required

safety examinations have not been properly conducted by company personnel. MSHA

citations and orders have been issued for failure to examine, failure to respond to

conditions found and failure to record examination. A more serious problem is

presented in any record is falsified. Falsification is grounds for criminal prosecution of

the persons involved.


CHAPTER 4

PERFORM WORK-AREA EXAMINATION

There are critical examinations and inspections that must be regularly made in connection

with work at mines. They include the following:

1. WORKPLACE EXAMINATION a. Each workplace must be examined at least once each shift by a “competent person” (one

who is fully qualified to perform the duty)

b. A record that the inspection was made must be retained for one year.

2. GROUND CONDITIONS a. Ground conditions must be examined by a designated, experienced person prior to work

commencing.

b. Ground conditions must be checked after blasting- more often if necessary.

c. Highwalls and banks near travelways mustbe examined weekly- more often if ground

conditions are changing.


CHAPTER 4

PERFORM WORK-AREA EXAMINATIONS

3. MOBILE EQUIPMENT INSPECTION a. All mobile equipment must be inspected each shift before being put into operation.

b. “Hazardous equipment” (poses a threat of injury) must be taken out of service immediately.

c. A record must be maintained of any defect affecting safety until it is corrected.

4. OTHER EXAMINATIONS

MSHA also requires examinations related to chemical hazards, excessive noise, air

contaminants, grounding systems, firefighting equipment, compressed air, welding, drilling,

blasting, hoisting, conveyors and tramways. If your work involves any such conditions,

equipment or activities, check the regulations and consult with the mine operator.


PART I

ESTABLISH PRUDENT PRACTICES Contractors who come onto mine property are subject to MSHA safety standards in the same

way as the mine operators. The process of assimilating all of the requirements can be

overwhelming. To facilitate compliance, the following chapters list prudent practices that

conform to MSHA regulations. Adopting these precautions should result in compliance with

most of MSHA’s safety requirements.


CHAPTER 5

Control Ground Conditions

Excavations at mines alter natural ground support. Resulting walls, slopes,

embankments and waste piles can be very dangerous to persons above and below.

Contractors who have control over ground need to take the same precautions as the

mine operator.

If you or your employees work near excavations, make sure your presence is known to

everyone who can affect your safety. Make sure the ground is stable and do not let

anyone go anywhere that may be questionable. Barricade dangerous areas.


CHATPER 5

CONTROL GROUND CONDITIONS

o Establish a plan for ground control.

o Make sure persons are not exposed to unstable ground.

o Examine ground each shift before commencing work.

o Examine after blasting.

o Examine when changing conditions may affect ground.

o Place barriers to prevent entry to hazardous areas.

o Take down unsafe ground.

o Scale from safe positions.

o Use appropriate scaling equipment.

o Perform secondary breakage from a safe place.


CHAPTER 6

Prevent Fires

Fires are surface mines, while infrequent, can occur so quickly that escape from

equipment or an enclosed workplace may be impossible. The rules for fire prevention at

mines are much like rules elsewhere.

If you believe that you are exposed to a fire hazard that you cannot control, consult with

the mine operator. Do not permit your employees or anyone else to be exposed to a fire

hazard.


CHAPTER 6

PREVENT FIRES

o Be careful with flammable materials.

o Post warning signs.

o Turn off gasoline engines when fueling.

o Do not let waste accumulate.

o Keep combustibles 25 feet from electrical stations.

o Have appropriate fire extinguishers handy.

o Have fire extinguishers on mobile equipment.

o Establish fire alarm and evacuations procedures.

o Store combustible liquids in marked containers.

o Keep combustible materials away from heat sources.

o Be careful with pressure gauges and regulators.

o Clear away combustibles before welding.

o Ventilate battery charging stations.

o Monitor conveyor belt systems.

o Prevent belt slippage friction.


CHAPTER 7

Maintain Air Quality

Increasingly, MSHA is focusing on airborne hazards. A special campaign has been

initiated to reduce silica exposure. MSHA is very concerned about toxins and other

health hazards. Anyone who has workers at a mine needs to be attentive to air quality

and MSHA requirements.


CHAPTER 7

MAINTAIN AIR QUALITY

o The American Conference of Governmental Industrial Hygienists has established limits for

airborne contaminants.

o These threshold limit values (TLVs) are published and are available from MSHA.

o Do not permit employees to be exposed to levels higher than those established by the TVLs.

o Conduct dust, gas, mist, and fume surveys as necessary to ensure employees are not

endangered.

o When excessive contaminants are found, take corrective action immediately.

NOTE: MSHA requires elimination of the exposure – by engineering changes for

example. Masks and respirators, if properly fit, reduce severity of exposure, but they

often do not eliminate a violation.


CHAPTER 8

Limit Noise

Studies have shown that, on average, persons who have been exposed to loud noise over

time are more likely to have hearing loss than persons of the same age who were not

exposed. MSHA has set limits on noise exposure to protect everyone working at mines.


CHAPTER 8

LIMIT NOISE

o Do not permit noise exposure over 115 dBA.

o Use hearing protectors as a precaution.

o Limit noise exposure as follows:

dBA MAXIMUM

LEVEL HOURS 90………………………………………………………….8.0

92………………………………………………………….6.0

95………………………………………………………….4.0

97………………………………………………………….3.0

100………………………………………………………...2.0

102………………………………………………………...1.5

105……………………………………………………...…1.0

110………………………………………………………...0.5

115………………………………………………………..0.25

NOTE: At 85 dBA, noise is the “action level.” Affected miners must be enrolled in a

hearing conversation program that complies with MSHA regulations. Hearing

protectors are important. They will not prevent an excess noise violation, but failure to

provide then may be a separate violation of MSHA’s hearing conversation regulations.

MSHA requires the eliminations of excess noise through “all feasible engineering and

administrative controls.” If engineering controls (walls, insulation, mufflers,

compartments) do not adequately reduce noise, administrative action (limiting working

time in affected areas) must be taken to ensure each person’s noise exposure does not

exceed the prescribed limits.


CHAPTER 9

Use Caution with Explosives

In 1996, MSHA introduced comprehensive new explosives regulations. Anyone using,

carrying or storing explosives at mines must comply. The following prudent practices

encapsulate much of what is mandated by the regulations.


CHAPTER 9

USE CAUTION WITH EXPLOSIVES

STORAGE

o Store explosives in an organized fashion.

o Protect explosives from heat and dampness.

o Store detonators and explosives properly.

o Store so as to use oldest explosives first.

o Keep blasting agents separate.

o Do not store detonators with explosives.

o Keep combustibles 50 feet from storage locations.

o Post warning signs at storage locations.

TRANSPORTATION

o Transport explosives without delay.

o Use suitable powder chests (day boxes).

o Transport detonators separately.

o Use marked vehicles designed for explosive transport.

o Only permit necessary persons to travel with explosives.

o Secure vehicles from movement – chock wheels.

LOADING OF BLASTHOLES

o Use only trained and experienced persons.

o Ensure blastholes are unobstructed before loading.

o Follow proper procedures for priming and loading.

o Do not drive vehicles over explosives.

o Do not drive over initiating systems.

o Do not permit activities in a blast site while loading.


CHAPTER 9

USE CAUTION WITH EXPLOSIVES

BLASTING

o Evacuate blast area before connecting initiating systems.

o Fire blasts without undue delay.

o Give warning before blast is fired.

o Allow ample time for all persons to be evacuated.

o Provide clear exit routes for persons doing the firing.

o Guard or barricade all access to the blast area.

AFTER BLAST

o Do a post-blast examination before resuming work in area.

o If a misfire is suspected, wait 30 minutes.

o Do not do any work until the misfire is remedied.

o Post and prohibit entry pending removal of misfire.

o Check regulation regarding electric/non-electric shots.

PARTICULAR PRECAUTIONS

o Use only non-sparking tools on explosives containers.

o Do not weld or cut on explosives vehicles until washed.

o Do not use black powder.

o Do not permit smoking within 50 feet of explosives.

o Prohibit open flames within 50 feet of explosives.

o Suspend operations if electrical storm detected.

o Withdraw persons from blast area on detection of a storm.


CHAPTER 10

Be Careful with Drilling Equipment

Drilling at mine operations poses multiple hazards. Not only is it necessary to make sure

the ground above, below and beside is safe, it is also necessary to avoid hazards from

mobile equipment and moving machinery parts.


CHAPTER 10

BE CAREFUL WITH DRILLING EQUIPMENT

DRILL OPERATION

o Correct equipment defects before operating.

o Inspect drilling area before operating.

o Stay with drill whenever operating.

o Do not permit anyone on a drill mast while operating.

o Keep crews clear of drill stems and augers in motions.

o Keep hands away from operating drilling equipment.

o Cover drill holes to avoid hazards.

o Do not leave loose objects on drill.

o Store drill steel and tools in appropriate racks.

o Maintain secure footing and good access to controls.

o Do not risk drilling into a misfire.

o If power failure occurs, place controls in neutral.

DRILL MOVES

o Before moving drill, bleed air from hoses.

o When moving, secure all parts of drill, mast and tools.

o Keep continual communication with helpers during moves.


CHAPTER 11

Take Care with Mobile Equipment

Contractors frequently bring mobile equipment onto mine property. Sometimes, they

operate mine equipment. Haul trucks, loaders, excavators and other self-propelled

equipment must be inspected before use. (See Chapter 4) Regardless who owns

equipment, the contractor who uses such equipment needs to take specific precautions.


CHAPTER 11

BE CAREFUL WITH MOBILE EQUIPMENT

INSPECTION

o Inspect equipment each shift before operating.

o Take unsafe equipment out of service.

o Record any defect until corrected.

OPERATION

o Comply with traffic signs and warnings.

o Keep equipment under control.

o Use cautious operating speeds.

o Do not transport persons on forks, buckets or beds.

o Do not transport persons on loads or out of cabs.

o Do not permit loose materials in cabs.

o Secure loads from shifting or falling.

o Do not load oversize materials.

o Make sure equipment operator has good visibility.

o Notify operator before getting on or off equipment.

o Do not pass under suspended loads.

o Do not get on or off moving equipment.


CHAPTER 11

BE CAREFUL WITH MOBILE EQUIPMENT

ROADS, DUMPS AND CHUTES

o Make sure berms or guardrails are provided at drop offs.

o Take precautions to prevent overtravel when dumping.

o Ensure ramps and dumping facilities can support loads.

o Visually inspect dumping locations prior to work.

o Reinspect ground conditions after rain, freeze or thaw.

o Dump a safe distance from any problem areas.

o Establish procedures to keep truck-spotters in the clear.

o Make sure loading chutes are safe.

o Ensure safe procedures when clearing jammed chutes.

o Clear roadways of hazardous water and debris.

o Make sure stockpiles and muck piles are trimmed.

o Make sure dust is controlled.


CHAPTER 12

Make Travelways Safe

Contractors will often have designated travelways – to and in – their workplaces.

MSHA requires that travelways be safe. Sometimes, this means there must be a fall

protection if the area is elevated (high places on trucks and mining equipment for

example). MSHA standards are aimed particularly at preventing harmful slips and falls.


CHAPTER 12

MAKE TRAVELWAYS SAFE

o Provide safe access to all working places.

o Provide hand rails and toe boards to eliminate hazards.

o Make sure ladders are on good footing.

o Barricade openings to prevent fall hazards.

o Place prominent warnings for unresolved hazards.

o Cross conveyor belts only at designated points.

o Clear snow, ice and debris off walkways.

o Make scaffolds and work platforms sturdy.


CHAPTER 13

Be Cautious with Electricity

There was a case in which a contract electrician asked a mine employee to signal that a

conveyor belt should be started. The electrician was electrocuted after the belt was

started. The independent contractor was prosecuted because its electrician worked on

energized equipment. The mine operator was also charged because the company

employee signaled for the belt start. There can be serious implications when contractor

and mine operator personnel become involved in each other’s duties and responsibilities.

In any event, contractors, like mine companies, should make sure that the areas where

they work are electrically safe.


CHAPTER 13

BE CAUTIOUS WITH ELECTRICITY

SYSTEM DESIGN

o Protect circuits with proper fuses or circuit breakers.

o Provide switches for all circuits.

o Label power switches to show what they control.

o Use proper size electrical conductors.

o Protect electrical conductors from damage.

o Protect wires from damage where they enter metal frames.

o Keep high voltage well separated from low voltage.

o Make sure all circuit enclosures are grounded.

o Place protective guards on exposed lights.

SYSTEM OPERATION AND MAINTENANCE

o Do not break power connections when the power is on.

o De-energize equipment before adjustments or maintenance.

o Lock out equipment before work is performed.

o Keep key with the person who is doing the work.

o Restrict electrical installations to authorized persons.

o Use suitable danger signs.

o Test grounding systems on installations and after repair.

o Retest grounding systems annually.

o Record results of ground checks.

o Keep covers on electrical equipment.

o Use caution around overhead power lines.

NOTE: MSHA regulations and enforcement policies sometimes refer to requirements in

the National Electric Code (NEC) or the National Electrical Safety Code (NESC). If you

are uncertain about a particular installation, it is helpful to check these codes.


CHAPTER 14

Make Machinery and Equipment Safe

Accidents involving mobile equipment and machinery are of great concern in the mining

industry. MSHA has repeatedly stressed the importance of maintaining equipment in

good condition, including brakes, lights, backup alarms and other safety features.

Moreover, persons at mines must be protected from moving machine parts. Every year,

the greatest number of violations cited are for failure to properly guard machinery.


CHAPTER 14

MAKE MACHINERY AND EQUIPMENT SAFE

INSPECTIONS

o Inspect mobile equipment before use on every shift.

o Correct defects promptly to prevent hazards.

o If a hazard exists, take equipment out of service.

o Make sure unsafe equipment cannot be used.

o Make a written record of any uncorrected defect.

o Keep the record until the defect is corrected.

o Make sure all brakes are working fully.

o Ensure working horns and backup alarms.

o Ensure equipment has seatbelts and rollover protection.

o Make sure equipment has falling object protection.

OPERATION AND MAINTENANCE

o Maintain brakes in fully effective condition.

o Keep windshields and mirrors in good condition.

o Make sure visibility is not obstructed.

o Keep cabs free of loose material.

o Perform tire repair in accordance with the regulations.

o Block machinery against hazardous motion before repair.

o Block equipment when not in use, drop blades.

o When parked on a grade, chock wheels or turn to bank.

o Use visible warnings for equipment shutdown in traffic.

o Use safe procedures and equipment for towing.

o Prohibit dippers, buckets, booms, and loads over drivers.


CHAPTER 14

MAKE MACHINERY AND EQUIPMENT SAFE

GUARDING AND WARNING

o Guard moving machine parts to protect persons.

o Place emergency stops on unguarded conveyors.

o Protect persons from flying or falling materials.

o Keep all guards securely in place while machinery is on.

o Sound alarm before starting machinery.

NOTE: Guarding violations are often considered by MSHA inspectors to be

“unwarrantable,” “knowing” or even “willful.” All such findings can lead to very

serious enforcement, especially if someone is injured. The types of moving machine

parts that are to be guarded include: gears, sprockets, chains, drive, head, tail, and

takeup pulleys, flywheels, couplings, shafts, fan blades, and similar moving parts that

can cause injury. Do not do maintenance while equipment is energized or moving.


CHAPTER 15

Avoid Danger from Materials

Mining is replete with stockpiles, waste piles, bines, hoppers, conveyors, supplies storage,

gas storage and equipment for moving suspended loads. There are also chemical

hazards. All such materials, facilities and equipment can become dangerous if

precautions are not taken.


CHAPTER 15

AVOID DANGER FROM MATERIALS

AVOID MATERIALS AND CONTAINER HAZARDS

o Keep persons away from potential caving materials.

o Recognize dangers entering bins, hoppers and silos.

o Use safety lines to enter such confined spaces.

o Have a helper tend safety line.

o Store hazardous materials in secure containers.

o Secure compressed gas cylinders.

o Use valve covers when tanks are not in use.

o Barricade potentially hazardous areas.

TAKE CARE WITH SUSPENDED LOADS

o Rig suspended loads carefully.

o Use tag lines to steady and guide loads while suspended.

o Keep persons clear of suspended loads.

o Do not ride on suspended loads.

o Follow safety procedures for cranes and lift trucks.

o Ensure personnel hoists meet standards.

EXERCISE CAUTION REGARDING CHEMICAL HAZARDS

o Examine for hazardous chemicals.

o Develop a hazard communications program.

o Label containers.

o Maintain Material Safety Data Sheets (MSDS).

o Make information available to miners.

o Conduct training on hazards, information and responses.


CHAPTER 16

Maintain a Safe Work Environment

Workplace inspections by each contractor/operator are integral to safety compliance.

Employer communications with employees regarding safety practices are vital.

Informing employees as to job-specific requirements will enhance safety and increase

compliance.


CHAPTER 16

MAINTAIN A SAFE WORK ENVIRONMENT

EXAMINATIONS

o Assign a competent examiner.

o Examine for safety and health each shift.

o Resolve and safety or health defects.

o Make a record of each exam.

o Keep record for one year.

EMPLOYEE COMMUNICATIONS AND SAFETY

o Indoctrinate new employees in safety procedures.

o Provide for emergency communications and transport.

o Do not work alone where there may be hazards.

o Follow regulations for elevators and personnel hoists.

o Do not permit alcohol or narcotics on the job.

o Make sure working areas and travelways are well lit.

o Keep work areas, passageways and storage areas clean.

o Keep areas as dry as possible.

o Eliminate protruding nails, splinters, holes and hazards.

o Make sure warning signs give adequate instructions.

o Label toxins to describe hazards and emergency responses.

o Post warnings for hazards not immediately obvious.

o Barricade hazards for extra protection.


CHAPTER 17

Use Personal Protective Equipment

The failure to provide personal safety devices (such as safety belts and eye protection) is

often a violation of the law. In some cases, even personal protective equipment will not

prevent a violation if the hazard remains in the environment. As notes in Chapter 8,

excess noise will typically be a violation even if hearing protection is worn, but it is not

usually considered as serious a violation. In any event, personal protection is vital.


CHAPTER 17

USE PERSONAL PROTECTIVE EQUIPMENT

o Keep a supply of first aid materials handy.

o Have persons on each shift who are trained in first aid.

o Wear hard hats.

o Wear protective footwear.

o Wear eye protection.

o Use eye protection.

o Use safety belts and lines with any risk of falling.

o Use a lifeline with attendant to enter enclosures.

o Use protective wear for chemical hazards.

o Use face shields and goggles when welding.

o Use goggles when grinding.

o Wear life jackets when working around water.


CHAPTER 18

Maintain Sanitary Conditions

MSHA requires basic health measures be taken for all persons at mines. Such measures

include providing potables water, toilet facilities, clean spaces and eliminating

contaminants.


CHAPTER 18

MAINTAIN SANITARY CONDITIONS

o Supply drinking water and sanitary cups.

o Provide sanitary toilet facilities for employees.

o Cover waste receptacles used for food waste.

o Empty waste containers frequently.

o Do not permit food or beverages in toilet areas.

o Do not permit food or beverages around toxic materials.


PART III

LAW AND ADMINISTRATION

The law requires that every violation found by an inspector shall be cited. It further requires

that every citation shall result in civil penalty. More serious consequences are specified for

more serious violations.

In addition to the actual safety standards, contractors/operators must be aware of

administrative regulations and MSHA enforcement procedures. The following chapters cover

basic administrative obligations and legal considerations.


CHAPTER 19

Report Accidents

MSHA investigates all fatal accidents and other accidents as well. MSHA expects to be

notified immediately when an accident occurs. When operators fail to notify MSHA,

there are often serious consequences. Every contractor/operator must know what

constitutes as “accident” for MSHA purposes.


CHAPTER 19

REPORT ACCIDENTS

All of the following surface mine events are categorized as “accidents” and must be reported

to the mine operator and MSHA immediately.

1. Any death on mine property.

2. Any injury with a reasonable potential to cause death.

3. Any equipment of an individual for more than 30 minutes.

4. Any unplanned flood of liquid or gas.

5. Any unplanned ignition of gas or dust.

6. Any unplanned fire not extinguished within 30 minutes.

7. Any unplanned ignition of blasting materials.

8. Any rock outburst that causes withdrawal of miners or disrupts activity for more than one

hour.

9. Any unstable impoundment.

10. Any event at a mine that causes death or bodily injury to persons off mine property.

Reports to MSHA should be made by telephone as the surest, fastest communication. If the

local MSHA office cannot be reached, there is a toll free number to MSHA headquarters 800-

746-1553

NOTE: Unless permission is expressly granted by MSHA, the accident site may not be

disturbed except to rescue persons or prevent destruction of mining equipment.


CHAPTER 20

Report Occupational Injuries and

Illnesses

In addition to the immediate reporting of accidents, all accidents, injuries and

occupational illnesses must be reported to MSHA in writing within 10 days of

occurrence of diagnosis.


CHAPTER 20

REPORT OCCUPATIONAL INJURIES AND ILLNESSES

1. Maintain a supply of official report forms. These may be obtained from MSHA.

2. File reports within 10 days of occurrence of injury or diagnosis of illness.

3. Report: Any accident.

Any injury at a mine that requires medical treatment or that results in loss of

consciousness, subsequent inability to perform job duties, or temporary assignment to another

job.

Any illness which may have resulted from work at a mine.


CHAPTER 21

Keep Records

MSHA will issue citations any time required records are not maintained and provided

for inspector review. Serious charges may result in the records are inadequate or

incorrect. Criminal charges may be initiated if records are found to be false.


CHAPTER 21

KEEP RECORDS

All records and reports mandated by the regulations must be maintained for inspection by

MSHA. These include:

Designation of employee safety representative.

Contractor legal identity information.

Records of employee training.

Records of accident, injury and illness.

Records of accident/injury investigations.

Records of electrical grounding system checks.

Records of uncorrected mobile equipment defects.

Records of workplace examinations.

Records of examinations of hoisting equipment.

Records related to hearing conservation.

Records related Hazard Communication (HazCom).


CHAPTER 22

Protect Miners’ Rights

A miner is anyone working in a mine. Contractor employees have the same rights as

everyone else on mine property. These rights must be respected.


CHAPTER 22

PROTECT MINERS’ RIGHTS

Everyone working at a mine site has rights, including:

Right to be protected from unsafe conditions.

Right to make safety complaints.

Right to refuse work believed to be dangerous.

Right to request MSHA inspections.

Right to have representative participate in inspections.

Right to have paid safety and health training.

Right to be paid if idled by an MSHA order.

Right to give testimony as a witness in investigations.

Right to participate in litigation related to MSHA.

Right to be free from discrimination for safety activity.

Right to access required records and notifications.

NOTE: Where a miner’s rights are violated, the miner may be represented in legal

proceedings against the company by attorneys for the Secretary of Labor.


CHAPTER 23

Understand Enforcement

MSHA inspectors have a right of entry to virtually all areas of any mine. Citations

result in civil penalties, but often there are more serious consequences. Sometimes,

individual managers, supervisors and officers are charged and fined personally. Even

imprisonment might result.


CHAPTER 23

UNDERSTAND ENFORCEMNT

To enforce the law, MSHA conducts inspections and investigations. There are important

differences between the two procedures.

MSHA INSPECTIONS

MSHA Inspectors visit surface mines twice a year.

MSHA visits underground mines four times a year.

Many mines are inspected more often.

Inspections are conducted without advance notice.

Inspectors have and absolute “right of entry” to mines.

Inspections may last days, weeks or months.

Contractor work is inspected along with mine work.

Inspectors issue citations for violations.

Each citation sets a deadline for correction.

If not corrected, a closure order will be issued.

There are also closure orders for “imminent dangers.”

There are other types of closure orders.

Most serious are those for “unwarrantable failure.”

All citations and orders result in civil penalties.

Civil penalties may be as high as $60,000 per violation.

Orders are typically the subject of high penalties.

Maximum penalties are increasing.


CHAPTER 23

UNDERSTAND ENFORCEMNT

MSHA INVESTIGATIONS

MSHA Investigators conduct investigations into serious matters including the following:

o Accidents

o High negligence imminent dangers

o Unwarrantable failure citations and orders

o Possible “knowing” or “willful” violations

o Refusal or failure to correct cited violations

o Employee hazard complaints

o Employee complaints of discrimination related to safety activity

Investigations typically involve interviews, written statements and collection of documents

Unlike an inspection, investigation interviews may be postponed at a witness’ request until

the witness has representation

No person may interfere with a witness who desires to participate in an MSHA

investigation.

Investigation may result in referral for civil or criminal prosecution against a contractor, the

mine operator or both.

Also, officers, directors or agents of a corporation may be held personally liable.

Another type of liability may arise if you interfere with anyone’s safety rights at a mine

site. For example, you may have to rehire a person found by MSHA to have been wrongfully

discharged. You may also have to pay back pay benefits, attorney fees and civil penalties.

NOTE: Foreman and other job supervisors are agents subject to personal liability. Over

the years, many supervisors have been charged personally.


CHAPTER 24

What is Criminal Conduct?

Criminal cases represent the worst repercussions of MSHA enforcement. They may be

brought against individual management representatives as well as the company.

Criminal proceedings are typically brought when a person makes a knowing choice to

disregard or violate the law.


CHAPTER 24

WHAT IS CRIMINCAL CONDUCT?

The Federal Mine Safety and Health Act as applied under Federal Sentencing Guidelines,

makes certain actions criminal and subject to imprisonment and fines up to $250,000 per

offense ($500,000 with a fatality). Included are:

Willful violations of any safety or health standard.

Knowing refusal to comply with an MSHA order.

Giving advance notice of an MSHA inspection.

Making a false statement or certification.

Willfully violating smoking prohibitions.

Falsely representing equipment as approved by MSHA.

In addition, other laws make it a criminal act to assault an inspector or lie to a government

representative acting in an official capacity.


CHAPTER 25

Know Your Rights

For every MSHA enforcement action there are corresponding rights available to the

contractor/operator being inspected. These begin with the right to accompany the

inspector, the right to discuss citations and orders with the inspector, and the right to

have a higher level MSHA review. Separately, each contractor/operator is entitled to

challenge MSHA enforcement before the Federal Mine Safety and Health Review

Commission.


CHAPTER 25

KNOW YOUR RIGHTS

Each contractor/operator has a right to have a management representative accompany an

MSHA inspector during inspection of the work place.

Each contractor/operator has a right to be served with citations and orders in writing.

Each contractor/operator has a right to talk to the inspector about any citations or orders.

Each contractor/operator has a right to seek review of any citation or order by the MSHA

district office – provided a conference request is communicated to MSHA within ten days of

the citation or order.

Each contractor/operator has the right to contest and have a hearing on any citation or order

with an independent adjudication agency called the Federal Mine Safety and Health Review

Commission – provided a notice of contest is filled within thirty days of the citation or order.

Similarly, each contractor/operator has the right to contest and have a hearing on any

proposed civil penalty. Such contest must be filed within thirty days of the date notice of the

penalty is received.

Each contractor/operator has a right to seek modification of any safety standard if:

o Application of the standard to the contractor/operator’s work would result in a diminution of

safety, or

o The contractor/operator has another way of achieving the safety goal with no less protection

to the workers.

Each contractor/operator has a right to obtain public records from MSHA, including records

relating to enforcement.

Each contractor/operator has a right to counsel.


CHAPTER 26

Recognize the Supervisor’s Responsibility

The greatest mistake a supervisor can make is to set a wrong example. Often,

supervisors feel that it is acceptable for them to take risks as long as none of the

employees are exposed. Nothing could be farther from the truth. MSHA will prosecute

supervisors and managers for knowingly endangering themselves.


CHAPTER 26

RECOGNIZE THE SUPERVISOR’S RESPONSIBILTY

The law places heavy responsibility on supervisors of persons working in mines. Serious

liabilities may follow supervisor failures.

REPSONSIBILITES

Supervisors must take care to protect all persons.

Supervisors are responsible for their own safety as well.

Supervisors must set a proper example.

Supervisors must obey and enforce safety requirements.

Supervisors must make sure workers are properly trained.

Supervisors must make sure workers have proper equipment.

Supervisors should always show commitment to safety.

LIABILITIES

Supervisors may be personally liable for violations.

Supervisors who knowingly allow violations are prosecuted.

An injury-related violation could prompt a civil lawsuit.

Crew members may be prosecutor or plaintiff witnesses.

Words or conduct with crew members will be evidence.


CHAPTER 27

Develop a Workplace Culture of Safety

The keys to safety are communication and commitment. Employees need to know that

their employer wants them to be safe, does not want them to short cut safety procedures,

and does want them to comply with the law. Employees always have a sense of whether

or not there is a culture of safety in the workplace.


CHAPTER 27

DEVELOP A WORKPLACE CULTURE OF SAFETY

Safety does not just happen.

Neither does legal compliance.

The stakes are high.

Safety and health on the job must be managed.

Every contractor/operator needs a safety program.

Every contractor/operator needs to plan injury avoidance.

Every contractor/operator needs a program for new employee safety indoctrination.

Every contractor/operator needs a program for employee safety and job training.

Every contractor/operator needs to make required examinations, make required reports and

keep records.

Every contractor/operator must make safety and legal compliance a prerequisite for all

work.


CONCLUSION

The goal of this book has been to present a simplified guide to legal requirements for Safety

and Health at mines. The focus has been on the requirements at surface metal/nonmetallic

mines, but the principles apply equally to underground metal/nonmetallic mines (which are

subject to a greater number of requirements) and also coal mines (which have separate, but

often similar safety and health requirements). The succinct presentation of information was

designed for contractors so that they can quickly learn a lot about MSHA. However, it is not

just contractors who can benefit from this presentation. This information is for everyone

subject to MSHA, including mine management and mine employees.


BIBLIOGRAPHY

There are many sources of information of MSHA related issues. The wide variety of materials

published by MSHA are free for the asking. Since the purpose of this book is to succinctly

present a large amount of information, the text is not burdened by cross-references to laws and

regulations.

Nevertheless, those sources are vitally important since full compliance with the law cannot be

assured without consideration of the specific legal requirements governing whatever type of

work is being performed. Thus, this bibliography provides, for each chapter, basic references

to the Federal Mine Safety and Health Act (Act) and the Code of Federal Regulations

(C.F.R.). Where particularly useful, MSHA policy handbooks are also referenced.

Introduction:…………………………….

Chapter 1:

MSHA Connection……………………

Chapter 2:

Safety Program…………………………

Safety Training………………………….

Federal Mine Safety and Health Act of 1977, 30 U.S.C. 801-960.

30 C.F.R. Parts 41 and 45.

30 C.F.R. Part 56

30 C.F.R. Part 46 and 30 C.F.R. 56 18006 and 56.18010. MSHA Compliance for Part 46

Training Regulations (May 28, 2001)


Chapter 4:

Workplace Examinations

Chapter 5:

Ground Conditions

Chapter 6:

Fire Prevention

Chapter 7:

Air Quality

Chapter 8:

Noise

Chapter 9:

Explosives

Drilling

Chapter 11:

Mobile Equipment

Chapter 12:

Travelways

Chapter13:

Electricity

Chapter 14:

Machinery and Equipment

30 C.F.R. 56.18002, 56.3401, 56.14100.


30 C.F.R. Part 56, 3000 series.



30 C.F.R. Part 62

30 C.F.R. Part56, 6000


30 C.F.R. Part 56, 9000 series and 30 C.F.R. 56,14100


30 C.F.R. part 56, 12000 series.

30 C.F.R. Part 56, 14000 series. MSHA’s Guide to Equipment Guarding for Metal and

Nonmetal Mining, Mine Safety and Health Administration (Revised, 1992).


Chapter 15:

Materials & Suspended Loads………….

Chapter 16:

Safe Environment……………………….

Chapter 17:

Personal Protective Equipment…………

Chapter 18:

Sanitation……………………………….

Chapter 19:

Accident Reporting…………………….

Chapter 20:

Injury/Illness Reporting………………...

Chapter 21:

Required Records……………………….

Chapter 22:

Miner’s Rights………………………….

30 C.F.R. Part 56, 16000 series and 30 C.F.R. Part 47 MSHA HazCom Compliance Guide

(September 2002).


30 C.F.R. Part 56, 18000 and 20000 series; 30 C.F.R. 56.17001.



30 C.F.R. Part 50. Report on 30 C.F.R. Part 50, Mine Safety and Health Administration

(December 1986).

30 C.F.R. Part 50.

30 C.F.R. 45.4, 48.9, 50.10, 50.11, 50.20, 56.18002, 56.18009, 56.12028, 56.14100, 56.19023.

Federal Mine Safety and Health Act, 105(c); 30 U.S.C. 815.


Chapter 23:

MSHA Enforcement……………………

Chapter 24:

Criminal Conduct……………………….

Chapter 25:

Contractor/Operator Rights……………

Chapter 26:

Supervisors’ Responsibilities…………...

Chapter 27:

Workplace Safety……………………….

Federal Mine Safety and Health Act, 104; 30 U.S.C. 814.


Federal Mine Safety and Health Act, 110; 30 U.S.C. 820.

Federal Mine Safety and Health Act, Title 1: 30 U.S.C. 811-825.

30 C.F.R. Part 56; Federal Mine Safety and Health Act 110; 30 U.S.C. 820.

30 C.F.R. Part 48 and 30 C.F.R. 45.4, 48.9,50.10, 50.11, 50.20, 56.12028, 56.14100,

56.18002, 56.18006, 56.19023.


APPENDIX

CONTRACTOR INFORMATION AND ACKNOWLEDGEMENT FORM MSHA requires each mine operator to maintain information on each independent contractor at

the mine. This is because independent contractors are responsible for compliance with MSHA

requirements. The following information is required when a contractor begins work. It

should be updated promptly in any changes occur.

REQUIRED INFORMATION

1. Contractor Identification Contractor’s Trade Name:_____________________________

Contractor Representative:____________________________

Business Address:___________________________________

Business Telephone:__________________________________

2. Contractor Activity Work to be Performed:________________________________

Site of Work on Mine Property:_________________________

3. MSHA Identification Status (check one)

o Contractor has an MSHA Identification Number, which is:__________________________

o Contractor does not have an MSHA Identification Number.

4. Service on Documents (check one)

o Address above is for Receipt of MSHA Documents.

o Contractor has a separate address for receipt of MSHA documents as

follows:_____________________________________________________________________

________________________________________________________


ACKNOWLEDGEMENT The contractor hereby acknowledges receipt of “Safety and Health at Mines: A Manual for

Operators and Contractors,” which provides information regarding worker safety and health at

mines. The contractor further acknowledges that it has been made aware of MSHA Safety and

Health Standards in the Code of Federal Regulations, Title 30, Part 56 (Surface Metal and

Non-Metallic operations) and MSHA Administrative Regulations in Title 30, Parts 40 through

50, and MSHA Civil Penalty Regulations in Title 30, Part 100.

The contractor also acknowledges that its employees have been trained with respect to

potential mine hazards at the mine where work is to be performed. The contractor understands

the importance of safety and health on the job and the need to avoid injury to any person.

Moreover, the contractor is aware of obligations to comply with all legal requirements for

safety and health at mines.

_________________________________________________

Signature of Contractor Representative

_________________________________________________

Name and Title


NOTES


ABOUT THE AUTHOR

Michael T. Heenan, Esq. is a preeminent authority on mine safety law. He is a managing

shareholder of the Washington, D.C., office of Ogletree Deakins – a national employment

law firm with offices throughout the county.

Mike Heenan represents mining companies in virtually every state. He is a veteran of

many precedential cases and author of numerous published works. He is also the Legal

Editor and monthly columnist for Pit & Quarry magazine.

Questions or comments may be directed to:

Michael T. Heenan

Ogletree Deakins, Nash, Smoak & Stewart, P.C.

Washington, D.C. 20037

Phone: 202-887-0855

Fax: 202-887-0866

E-Mail: [email protected]