environmental health & safety - prefix - becht engineering€¦ · organizational guide to the...

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Environmental Health & Safety - Prefix

Introduction ............................................................................................................ iv

Safety Statement .....................................................................................................v

Organizational Guide to the Safety Manual ........................................................ vi

Commitment to Safety ......................................................................................... viii

Drug and Alcohol Policy ....................................................................................... ix

Environmental Health & Safety Section 100 General Safety

EH&S 101 Safety Training ................................................................................................................... 1

EH&S 102 Company Safety Personnel Responsibilities ............................................................... 4

EH&S 103 Office Safety ....................................................................................................................... 7

EH&S 104 Fire Protection-Prevention ............................................................................................. 10

Environmental Health & Safety Section 200 Operation & Field Safety

EH&S 201 Assured Grounding & GFCI ........................................................................................... 14

EH&S 202 Confined Space Entry ..................................................................................................... 18

EH&S 203 Fall Protection .................................................................................................................. 22

EH&S 204 Personal Protection Equipment .................................................................................... 33

EH&S 205 Process Safety Management ......................................................................................... 42

EH&S 206 Electrical Practices .......................................................................................................... 58

EH&S 207 Respiratory Protection ................................................................................................... 74

Environmental Health & Safety Section 300 Health

EH&S 301 Injury and Illness Prevention Program ........................................................................ 92

EH&S 302 Access to Medical Records ........................................................................................ 101

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EH&S 303 Hazard Communication ................................................................................................ 105

EH&S 304 Hearing Conservation ................................................................................................... 110

EH&S 305 Medical Services and First Aid .................................................................................... 117

EH&S 306 Heat Stress Prevention ................................................................................................. 119

EH&S 307 Incident Reporting and Investigation ......................................................................... 125

EH&S 308 Injury/Illness Recordkeeping ...................................................................................... 130

EH&S 309 Pandemic Illness Preparedness Plan ........................................................................ 135

EH&S 310 Ergonomics Program.................................................................................................... 144

Environmental Health & Safety Section 400 Safety Awareness

EH&S 401 Asbestos Awareness .................................................................................................... 157

EH&S 402 Lead Awareness ............................................................................................................ 162

EH&S 403 Bloodborne Pathogens Awareness ........................................................................... 167

EH&S 404 Benzene Awareness ..................................................................................................... 170

EH&S 405 Compressed Gas Cylinders Awareness.................................................................... 173

EH&S 406 Mobile Equipment Safety Awareness ........................................................................ 178

EH&S 407 Scaffold and Ladder Safety Awareness .................................................................... 188

EH&S 408 Welding and Hot Work Safety Awareness ................................................................ 230

EH&S 409 Hand and Power Tool Safety Awareness .................................................................. 237

EH&S 410 Lock Out/ Tag Out Safety Awareness ........................................................................ 244

EH&S 411 Hydrogen Sulfide Awareness ...................................................................................... 256

EH&S 412 General Waste Management ....................................................................................... 260

EH&S 413 Short Service Employee Program .............................................................................. 265

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Appendices

Appendix A Field Safety Policies and Procedures ....................................................................... 275

Appendix B Back Injury Prevention ................................................................................................ 405

Appendix C Job Safety Risk Assessment ..................................................................................... 408

Appendix D Safety Organizational Chart ....................................................................................... 412

Appendix E Hazardous Waste Operations / Emergency Response ......................................... 413

Appendix F Hazardous Waste Operations / Resource Conservations ..................................... 422

Appendix G Safe Driving Policy ...................................................................................................... 434

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Introduction

The Becht Engineering Environmental, Health, and Safety manual is designed to provide safety policies and guidance which are generic to safe operations for all Becht Divisions. Policies and procedures specific to a division‘s operations should be established by each Division Manager. Becht Engineering personnel may be called on to perform work in the field: in plants, vendor shops, construction sites, etc. In transferring from the office to the field, you may be exposed to many hazards such as toxic chemicals, high temperatures, and be in close proximity to operating and construction equipment. To work safely in such environments you must develop a strong sense of AWARENESS to spot such unsafe conditions. You must abide by all existing local safety rules, but, as a minimum, follow these safety procedures and policies. Normally, the host company has responsibility for site safety. While all employees are responsible for safety, always ensure you are aware of who is legally responsible for site safety and that you have completed any required safety orientation and training. Any conflicts in this respect should be referred to your supervisor immediately. Throughout the manual we will to stress two key words: AWARENESS and DIFFERENCES. Awareness because it is critical that employees be aware of the potential hazards around them and differences because safety hazards are just that, differences in standard procedures which may cause injuries.

Note: This manual is intended to provide safety guidance and policy for Becht Engineering employees only. When Becht Employees visit a job site, the host company is normally legally responsible for complying with all applicable state and federal safety laws and requirements. In circumstances where there is no safety presence, such as building inspections, Becht Employees must make both a hazard assessment and an informed decision to either continue with the job requirement or request additional safety measures. Becht Engineering does not warrant any product or design as safe.

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Becht Engineering Co., Inc. Environmental, Health, and Safety Manual

SAFETY POLICY STATEMENT

“We Work Safely”

At Becht Engineering, we believe safety is a barometer of organizational health and excellence and that all accidents are preventable therefore

we work safety into everything we do.

The goals of the Becht Engineering Safety Program are: • To make safety awareness an integral part of our work ethic. • To define the minimum Becht Engineering Safety Standards. • To provide an injury free work environment.

Remember the ―Duck Rule.‖ If it looks like a duck and quacks like a duck it is probably a duck. So, if you see what seems like a safety hazard, it probably is one.

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Organizational Guide to the Becht Safety Manual

In addition to working in Becht Engineering Offices, Becht personnel may be asked to work in additional types of working environments. Generally there are four classes of assignments: 1) office; 2) consultation in the field accompanied by host personnel; 3) Advisors who work independently at a client site and 4) Advisors imbedded in a client organization for longer term assignments. Each of these classes will be exposed to different types of hazards. This manual is organized in a way that makes the information for each class of work and type of hazard readily available. All employees, including part-time advisors, need to be thoroughly familiar with the Becht safety organization, personnel responsibilities and training requirements listed in the first sections of this manual. In addition, a keen sense of safety AWARENESS is essential to achieve the goal of preventing all accidents at all sites. Office workers will primarily be interested in the General Safety Section 100. However, they should also be knowledgeable about Sections 302 Access to Medical Records and 305 Medical Services and First Aid. All employees who work at a client‘s site may be exposed to additional hazards. The JOB SAFETY AND RISK ASSESSMENT (Appendix C) should be used either before or after arrival to identify potential hazards associated with the assignment. Employees should receive appropriate training from the host organization and abide by those rules. However, if client practices seem lacking, those in this manual should be followed. Sections 200, 300, and 400 cover a multitude of possible hazards and recommended practices to provide safe working conditions. Becht employees who are accompanied by host personnel in the field or working solely in the client‘s office should be fully aware of potential hazards at the site, and pertinent alarm and evacuation procedures. Sound office safety procedures and the advice of their guides should be followed. In addition; they should study the FIELD SAFETY MANUAL (Appendix A) before going to the site.

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Becht employees working more independently at any site need to fully understand the practices described in this manual which may be pertinent to their assigned tasks. They need to ensure that their training, equipment and fit testing meet the standards listed. In no case is a Becht employees authorized to work in areas contaminated by lead, asbestos, benzene or other carcinogenic material.

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Commitment to Safety

At Becht Engineering we believe safety is a barometer of organizational health and excellence and that all accidents are preventable. Our goal is to make safety an integral part of our business ethic and personal values. Consequently, progress on any task is never so urgent as to require the use of unsafe practices. We recognize that achieving this goal is not possible without the full commitment from every employee to work safely and to help develop appropriate safety practices for each task. This is especially true because of the nature of Becht‘s business. Management makes the following commitments to help ensure continued improvement in safety standards:

We will provide a smoke free and safe work place at each of our offices.

We will educate and train each employee to work safely at all sites and to avoid injury in emergency situations.

We will make every effort to identify hazards at client sites before our employees arrive for an assignment and provide the appropriate protective equipment and training.

We will recognize employee contributions to the safety of any site.

We vow that safety suggestions, observations or other forms of feedback will be formally recognized and reviewed to help the company maintain exceptional safety performance.

We will communicate lessons learned from any incident promptly.

We expect the subsequent commitments from all employees in addition to following safe work practices individually:

To participate diligently in safety programs at client sites and observe their rules (unless they are in conflict with those in this manual).

To be aware of any potential hazards in their work area, and to report those immediately to their responsible supervision.

To be alert to help co-workers avoid unsafe situations.

To use their experience and observations to suggest improved safety practices.

Only by accepting our shared responsibilities and working together can we have a safe and healthy work environment for all. When giving safety primary emphasis both on and off the job, we will develop an attitude of safety awareness that will enhance our commitment to excellence in all aspects of our enterprise.

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BECHT ENGINEERING CO., INC. ALCOHOL, DRUG AND CONTRABAND POLICY

Becht Engineering is committed to maintaining a drug and alcohol free workplace.

DEFINITIONS

―Illegal drugs or controlled substances‖ Refers to but is not limited to all forms of narcotics, depressants, stimulants, hallucinogens, and other drugs whose use, possession or transfer is restricted or prohibited by law.

―Under the influence‖

means: (1) the presence of:

illicit or controlled drugs or mood or mind altering substances,

prescribed drugs that are used in a manner inconsistent with the prescription,

alcoholic beverages, or

metabolites of any of them in body fluids; and/or (2) the presence of any of those substances that affects an individual in any detectable manner. The symptoms of influence may be, but are not limited to, slurred speech or difficulty in maintaining balance.

―Workplace‖

Includes any office or structure on the Becht Engineering property, any office or structure when on a project at a client‘s location, and in any company car or truck on any date, and any time of day. This policy also is in effect any time an employee is away from the office and representing Becht Engineering.

PROHIBITIONS

Employees shall not be under the influence of, use, possess, distribute, or sell illegal drugs or drug paraphernalia while employed by Becht Engineering. Employees shall not be under the influence of or use alcohol prior to or during the performance of work-related activities. Alcohol is removed from the bloodstream by the liver at a relatively constant rate of 15 mg% (.015%) every hour or 1 drink per hour. A standard drink contains about .6 ounces of alcohol. This equates to a blood alcohol content (BAC) of .029 for a 150lb person. A confirmed alcohol concentration of 0.02 or higher

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will result in an individual being impaired. Employees must allow for at least one hour of sobriety for each drink consumed, so that prior to the inception of work, the employee has a 0.00 BAC. Noncompliant employees will be required to leave the firm‘s premises or the client site. Safe transportation will be arranged at the expense of the employee under the influence. Return to the workplace will be denied unless specific authorization is received from Becht Engineering and the Client, if the employee is providing services at a Client site. Switching or adulterating urine, blood, or any other sample used for testing purposes is also prohibited.

Becht Engineering personnel are prohibited from the following:

Using or possessing, while on or handling Client or Becht Engineering property or performing Third-Party Services, prescription drugs or over-the-counter medication that may cause impairment except when all of the following have been met:

i. Prescription drugs have been prescribed by a licensed physician for the person in possession of the drugs.

ii. The prescription was filled by a licensed pharmacist for the person possessing the drugs and for the period specified by the physician.

iii. The individual notifies their Becht and Client supervisor/contact that they will be in possession of or using impairment-causing prescription drugs or over-the-counter medication and appropriate steps will be taken to accommodate the possibility of impairment, including but not limited to, removal from work for the period of possible impairment.

Drugs prescribed by a physician or dentist should be used as directed for the purpose for which they were prescribed. If any prescription drug being used was obtained more than two years ago, follow-up with a treating physician is required, and a substance abuse evaluation may be necessary.

Employees are prohibited from using, possessing, selling, manufacturing, distributing, concealing, or transporting any contraband, including firearms, ammunition, explosives, and weapons.

SCREENING & TESTING

Employees on assignment at a client‘s location will be pre-screened for drugs and alcohol per that client‘s standards and consent to be entered into the DISA Contractors Consortium or ASAP Drug Solutions random testing pool. By signing the applicable consortium‘s authorization or membership form, employees consent to the transmission of their test results into the associated consortium‘s database. DISA and ASAP test employees for a minimum of nine illegal substances (ten at the ExxonMobil Beaumont site). These substances and confirmation levels are identified

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in Appendix A and Appendix B. Alcohol testing is performed by a breath, blood or saliva test. If an individual is using prescription medication, the MRO (medical review officer) for the applicable consortium should be contacted on the day of the test to disclose prescription information. The MRO‘s contact information will be provided by the Safety Coordinator. Testing will be repeated on an annual basis for long-term assignments. Post-incident testing and reasonable-suspicion testing also are requirements for employees on assignment at client locations. An employee removed from a site for reasonable suspicion or post-incident must complete a drug and alcohol test immediately following the removal. The employee must also sign a written certification permitting disclosure of test results to the client. Employees may renew onsite services at the client site only after a negative result is reported to the client, and the client approves the return. If impairment-causing prescription medication is detected in an employee‘s specimen and the medication was not previously reported to the employer‘s supervisor and client contact, the employee may be subject to termination due to violation of this policy.

SEARCHES & INSPECTIONS

Clients may, without prior notice, search Becht Engineering employees, their possessions, and vehicles at the client‘s location.

TREATMENT

Employees that are experiencing work related or performance issues from drug or alcohol use may request or be required to seek, counseling and/or rehabilitation treatment. Reimbursement for any counseling or rehabilitation will only be in accordance with the company‘s health insurance coverage. Any expense beyond insurance coverage will be the responsibility of the employee.

RECORDS RETENTION

Signed acknowledgement forms and results of all alcohol and drug screening will be maintained on file in Liberty Corner, New Jersey, for a period of five years.

COMPLIANCE

As a condition of employment, employees agree to abide by this policy and failure to do so will result in disciplinary action, up to and including removal from the client site

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and termination. Becht Engineering warrants that all personnel performing work have been fully informed of the requirements of this policy. Before beginning work, each employee must sign a written acknowledgement certifying that he/she has been informed of this policy and agrees to be bound by its requirements.

APPENDICES

Appendix A: North American Substance Abuse Program (DISA) Drug and Alcohol Panel Levels. Appendix B: LACC (ASAP) Drug and Alcohol Panel and Cutoff Concentration Levels. Appendix C: Becht Engineering Co., Inc. Drug and Alcohol Policy Receipt Acknowledgement

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Appendix A:

North American Substance Abuse Program (DISA – DCCHA Policy) Drug and Alcohol Panel Levels

DRUG AND ALCOHOL PANEL

DRUGS SCREENING LEVEL CONFIRMATION LEVEL

Amphetamines 300 (ng/ml) 300 (ng/ml)

Barbiturates 300 (ng/ml) 100 (ng/ml)

Benzodiazepines 300 (ng/ml) 100 (ng/ml)

Cocaine 300 (ng/ml) 150 (ng/ml)

Methadone 300 (ng/ml) 100 (ng/ml)

Opiates 2000 (ng/ml) 2000 (ng/ml) Morphine 2000 (ng/ml) Codeine

Cannabinoids 20 (ng/ml) 10 (ng/ml)

PCP 25 (ng/ml) 25 (ng/ml)

Propoxyphene 300 (ng/ml) 200 (ng/ml)

Alcohol 0.02% (BAC) 0.04% (BAC)

For ExxonMobil Beaumont Sites Only: Methaqualone

300 (ng/ml)

200 (ng/ml)

NOTE: Alcohol screening and confirmation methods are conducted according to DOT protocol. Substances and levels may be modified when applicable. Quest Diagnostics processes urine specimens for DISA and the NASAP consortium.

North American Substance Abuse Program Rev. 1, Approved June 27, 2006 Appendix II Page 1 of 1

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American Substance Abuse Professional Drug Solutions, Inc.

Appendix B: Drug and Alcohol Panel, and Cutoff Concentrations for Initial and Confirmation Tests

Type of Drug or Metabolite

Initial test [EMIT](ng/mL) Confirmation test [GC/MS](ng/mL)

Amphetamines: Amphetamine Methamphetamine (MDMA) Ecstasy

300

300

300 300

Barbiturates 300 100

Benzodiazepines 300 100

Cocaine metabolites 300 150

Opiates: Morphine Codeine

300

150 150

6-acetylmorphine (6-AM) - only when the specimen contains morphine at a concentration greater than or equal to 2000 ng/mL

Marijuana metabolites 20 10

Phencyclidine (PCP) 25 25

Methadone 300 100

Propoxyphene 300 200

Alcohol .02% (alcohol screening device ASD or EBT)

.04% (evidential breath testing device EBT)

A confirmed alcohol concentration of 0.04 or higher is a positive test. The employee must be immediately removed from owner sites, prohibited from performing his/her duties, and is subject to return-to-work (rehabilitation) provisions of the LACC Policy (Section 6.0 and Appendix 3). A confirmed alcohol concentration of 0.02 or higher, but lower than 0.04 [0.02-0.039] will result in the employee being immediately removed from owner sites and prohibited from performing his/her duties for a minimum of 24 hours. He/she cannot enter owner sites until a subsequent test (pre-access drug and alcohol test) is negative for drugs and documents an alcohol concentration of less than 0.02. **The employer must arrange for the employee‘s safe transportation home if his/her alcohol concentration is 0.02 or higher. Pacific Toxicology Laboratories is the authorized laboratory for ASAP and the LACC consortium.

LACC Policy (5

th

Rev. 08-30-2007)

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Becht Engineering Co., Inc. Employee Drug and Alcohol Policy Acknowledgment and Consent

By my signature below, I hereby acknowledge receipt of my copy of the Becht Engineering Co, Inc. Drug and Alcohol Policy and understand that it is my responsibility to read and understand the matters set forth in such document. I hereby consent to disclosure by Becht Engineering Co., Inc. and its agents, including, but not limited to, any collecting and testing agencies, of test or screen results and any related information to the applicable Client and it‘s authorized agents, assignees, or representatives. I understand and acknowledge that Becht Engineering has the right, without prior notice, to modify or amend the referenced policies and practices within the limits and requirements imposed by law. _____________________________ Name (Please Print) _____________________________ Signature _____________________________ Date

SAFETY TRAINING

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EH&S 101

1 PURPOSE AND SCOPE

Purpose

The purpose is to provide the knowledge necessary to perform a job safely by establishing expectations for employees on how to perform job tasks. Knowledge acquired by participation in training is one of the methods used to create a safe culture.

Scope

The scope is to train all new and continuing employees.

2 GENERAL

Employees shall receive safety training by a Safety Representative.

Definitions

None

Responsibilities

The Company Safety Manager is responsible for administering the procedure.

3 PROCEDURE

Safety Meetings: A portion of each quarterly meeting is devoted to Safety and highlights

recent Safety Industry Updates, Safety Alerts and Safety Policy Letters. Office staff should attend or participate via conference call.

Staff working at client sites should participate in appropriate facility,

project, turnaround, and/or maintenance activity safety meetings, including daily briefings.

Where a team of Becht Engineering personnel are assigned to the same project, turnaround or maintenance activity at a client site, the most senior member of the team will conduct, at a minimum, a monthly safety session to discuss and distribute safety information. Ad hoc meetings will be held, as required, following incidents and near misses to discuss cause, lessons learned, and corrective

SAFETY TRAINING

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EH&S 101

action. In addition to Becht monthly safety meetings, Becht Engineering personnel may be asked to participate in similar meetings at the client site and in accordance with site and project-specific practices. Documentation for ad hoc meetings includes topic, summary of discussion, and participation. Documentation is sent to the Company Safety Manager and is included in a Safety Alert for companywide distribution. Additional safety information distributed to all Becht Engineering personnel includes a monthly Safety Spotlight and a quarterly employee publication which includes topical safety information.

4 TRAINING

New Employee Safety Training:

All new employees will receive a safety orientation on the Becht

Engineering Safety Program within two weeks of their employment. All new employees will receive safety orientation and training related to field safety prior to their first job site visit.

All new employee‘s will receive an overview of their respective

Divisions‘ specific safety from their Division Manager within two weeks of their employment or prior to their first job site visit, whichever comes first.

Ongoing Safety Training:

The Company Safety Manager will publish and distribute safety

updates to all employees. Any significant safety incident will be reviewed and lessons learned will

be given to all employees.

New safety requirements/subjects that warrant a formal presentation will be given by the Company Safety Manager.

Safety Awareness Training:

Safety Industry Updates: As industry safety updates are published

from OSHA and other engineering safety organizations they will be incorporated into Becht Engineering safety program and disseminated to the division Managers for inclusion into their respective safety specific programs.

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EH&S 101

Safety Alerts: Safety alerts are designed to both provide employees

with lessons learned from safety incidents or near miss incidents and to periodically reinforce important safety procedures and policies.

Safety Policy Letters: When a safety issue is significant enough to

warrant it, we will publish an individual safety policy letter detailing the issue, the company‘s policy concerning the issue and the standards to which the policy will be enforced.

5 REFERENCES

None

6 APPENDICES

None

SAFETY PERSONNEL RESPONSIBILITIES

AUG./ 2010

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EH&S

102

1 PURPOSE AND SCOPE

Purpose

Purpose is to establish Personnel responsibilities for implementation of the Environmental, Health & Safety (EH&S) Program.

Scope

This procedure applies to Becht Engineering Company and all its‘ Division operations.

2 GENERAL

Definitions

None

Responsibilities

Company President:

Ultimately responsible for all aspects of safety within the company Delegates safety responsibility to the Division Managers within the

scope of the Company Safety Program Coordinates directly with the Company Safety Manager on all aspects

of the company‘s safety operations

Division Manager: Ultimately responsible for safety within their division Designates a Division Safety Officer to implement both the Becht

Engineering Safety Program requirements and to implement and monitor the requirements outlined in their respective Division Safety Standards.

Primary point-of-contact on all safety related issues for the division Coordinates directly with the Company Safety Manager on all safety

related policies, procedures and training Implements the Division Safety Training requirements outlined in the

Becht Engineering Safety Program Documents all safety training classes and briefings


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EH&S

102

Company Safety Manager:

Administers the Company Safety Program. Reports directly to Company President (or his designee) on safety

issues. Approves all safety related brochures and correspondence. Reviews specific Division Safety Programs for consistency with overall

EH&S program and compliance with regulations. Conducts periodic audits of training, documentation, and exercises. Communicates regularly to all employees on safety issues and

prepares ad hoc safety alerts when warranted.

Safety Coordinator Supports and coordinates directly with the Division Managers on all

aspects of company safety. Point of Contact for all safety coordination with outside agencies. Documents all safety training, classes, briefings and incidents. Administers Becht Safety Orientation.

Company Employees and Advisors:

Accepting individual responsibility for his or her safe behavior. Maintaining proactive role in the implementation of Becht‘s EH&S Plan

and the INCIDENT FREE philosophy. Working in a safe manner at all times. Learning and abiding by EH&S practices and procedures applicable to

their work tasks and for reporting substandard practices, conditions or behaviors to their supervisor.

Promptly reporting injuries to their supervisor and site first aid facility. Making safety suggestions. Refuse to undertake jobs he/she does not understand or deems

unsafe.

3 PROCEDURE

Non-applicable


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EH&S

102

4 TRAINING

None

5 REFERENCES

None

6 APPENDICES

None

OFFICE SAFETY

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EH&S

103

1 PURPOSE AND SCOPE

Purpose

These guidelines are to be used at all Becht Engineering Office facilities to develop location specific Office Safety Plans.

Scope

This procedure applies to all Becht Engineering offices.

2 GENERAL

Definitions

None

Responsibilities

The respective Office or Divisional managers will develop an Office Safety Plan with the help of the Company Safety Manager or Designee.

3 PROCEDURE

Office Safety Plan Requirements Office Safety Plans should be developed for each Becht Engineering

office location. The Office Safety Plans must be tailored to the specific requirements of the office and be both cost sensitive and site sensitive.

Office Safety Plans should address the following safety concerns: general office safety issues, evacuation, fire emergencies and medical emergency.

Site specific issues should also be included. The following provides guidance for developing a site specific Office

Safety Plan.

General Office Safety

General office safety plans should includes examples such as the following: Avoid paper cuts to the tongue when sealing envelopes by using

moisteners. Pass scissors handle first, with blades closed together.

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EH&S

103

Use a knife or blade with a handle for cutting and pasting work. Never use a double edged or unprotected razor blade.

All electrical equipment should be grounded. Worn or frayed electrical cables must be replaced and destroyed. Passageways and walkways must be kept clear to provide access and

egress in case or emergency. Never leave a desk or file cabinet with drawer open. Cables stretched across passageways or walkways are tripping

hazards and must be covered securely or removed. Never stand on swivel chairs or chairs fitted with castors. The chair

may roll or tip when your weight is applied. Store heavy files in the bottom of filing cabinets. Multiple filing cabinets should be bolted together. Practical jokes and horseplay are dangerous and forbidden. Fire/emergency doors must be kept closed when not in use. Do not block fire escape routes or passageways, etc. Know your escape routes from place of work. Know the nearest location of fire extinguishers and how to operate

them efficiently. Do not use elevators in event of emergency. Use stairs.

General Fire Safety

Procedures to be followed in the event of a fire in the building shall be developed for each office location. This procedure shall include the following: Designate fire wardens, if appropriate. Evacuation routes shall be developed and posting requirements

established. Provisions for training personnel on emergency fire procedures should

be addressed. This training should include location of fire extinguishers, fire notification for emergency response, evacuation routes, alarm signals, identification of fire wardens and assembly points.

A schedule for testing the fire alarm system shall be established.

Evacuation

Building evacuation plans shall be developed for each office location. Evacuation plans should include the following: Personnel notification (i.e. alarm).

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EH&S

103

Circumstances requiring evacuation i.e. Fire, Bomb Threat. Designate who is responsible for authorizing an evacuation. Designate evacuation routes and assembly areas. Provide general evacuation safety guidelines.

Medical Emergency

Procedures to be followed in the event of a medical emergency shall be developed for each office location. This procedure shall identify the following:

On-site first aid responders, if appropriate Number and location of first aid kits, Notification of off-site emergency medical system (usually 911), Internal notification of medical emergency.

4 TRAINING

None

5 REFERENCES

None

6 APPENDICES

None

FIRE PROTECTION/PREVENTION

AUG./ 2010

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EH&S

104

1 PURPOSE AND SCOPE

Purpose

The purpose of this plan is to prevent potential injuries and deaths and to protect company property from damage or loss due to fire. This plan includes fire prevention, building exits, fire extinguishing, emergency evacuation, and employee training.

Scope

This procedure applies to all Becht personnel and subcontractors working on projects where fire protection and prevention requirements are applicable.

2 GENERAL

Our first line of defense against fire is to prevent it in the first place.

Definitions

None

Responsibilities

It is the responsibility of all employees to prevent fires. All employees will be apprised of the potential fire hazards in their work area and they will be trained in safe work procedures and practices. Employees are expected to follow proper procedures to prevent fires and to notify their supervisor or other management personnel if they observe any condition that could lead to the ignition of a fire or could increase the spread of a fire.

3 PROCEDURE

The following are some general fire prevention practices and procedures that should be followed:


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EH&S

104

Fire Prevention All ignition sources (i.e., open flames, spark producing equipment,

electric motors, heating equipment, etc.) should be controlled and contact with combustible and flammable materials must be avoided. Keep all combustible materials at least five feet from such ignition sources and all flammable liquids at least twenty feet away. Extensive use of electrical extension cords should be avoided. Any damaged or frayed electrical wiring, equipment cords, extension cords, etc. should be removed from service immediately and replaced or repaired.

Any use of flammable liquids must be done in a manner that prevents spills and prevents the flammable liquid or its vapor or spray from coming in contact with any ignition source. All flammable liquids must be stored in proper flammable liquid storage containers and kept in the proper storage cabinets.

Housekeeping and storage practices are critical to preventing fires. Any combustible materials must be stored in neat stacks with adequate aisle space provided to prevent easy spread of fire and to allow for access to extinguish any fire that may start. Trash, scrap, and other unnecessary combustibles must be cleaned up immediately and placed in proper disposal containers.

Smoking is prohibited in all Becht Engineering Buildings.

Building Fire Exits Each area of the building has at least two means of escape remote

from each other that are to be used in a fire emergency. The location of exits and the path of egress is shown on maps posted throughout the building.

Fire exit doors must not be blocked or locked to prevent emergency use when employees are within the building.

Exit routes from our building must be clear and free of obstructions. All exits are marked with signs designating exits from the building.

Fire Extinguishers Each area of our building has a full complement of the proper type of

fire extinguisher for the fire hazards present. Portable fire extinguishers are subjected to monthly visual checks and an annual maintenance check. If a fire extinguisher is used or discharged for any reason, it must be removed from service and replaced with another properly charged extinguisher while it is being recharged.


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EH&S

104

Employees who are expected or anticipated to use fire extinguishers will be instructed on the hazards of fighting fires, how to properly operate the fire extinguishers available, and what procedures to follow in alerting others to the fire emergency. These employees will attempt to extinguish only small incipient fires. If a fire cannot be immediately and easily extinguished with a fire extinguisher, the employees will evacuate the building rather than try to fight the fire. All employees who are not trained and designated to fight fires are to immediately evacuate the building at the first sign of fire or initiation of the fire alarm and are prohibited from using an extinguisher.

Emergency Evacuation

If any employee discovers a fire or smoke, the employee will

immediately alert the office via the phone intercom. If there is time and it is safe to do so, the employee will also call the Building Warren or Designee to report the fire. The Building Warren or Designee will call 911 and report the fire to the fire department. The Building Warren or Designee will then make an announcement over the public address system that there is a fire, give the location of the fire and instruct all employees to evacuate the building. The Building Warren or Designee will then exit the building.

When the fire alarm sounds or a fire is otherwise announced, all employees (except those designated and trained to use fire extinguishers) are expected to immediately exit the building by proceeding to the nearest exit in an orderly fashion. If the nearest exit is blocked by fire or smoke, the employees should proceed to an alternate exit. There should be no running, shouting, pushing, etc. A calm orderly evacuation is the safest for all concerned.

Upon exiting the building, all employees are to proceed to the designated meeting area. Supervisors and managers will account for all of their employees to ensure that no one is still in the building and unaccounted for.

Where needed, special procedures for helping physically impaired employees will be established. This will be done on a case by case basis when the employee is first hired or when the physical impairment first occurs.


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EH&S

104

4 TRAINING

Employee Training All new employees will receive fire prevention and emergency

evacuation training during their new employee orientation. All employees will receive refresher training and a review of this plan on an annual basis.

We will hold fire drills that will include a practice evacuation of the building at least annually. These drills will be used to evaluate employee response and behavior and will help us determine where more training is needed.

Those employees who are designated and authorized to use fire extinguishers to fight small fires will receive training in the proper use of extinguisher, how to extinguish a fire, the hazards involved in fighting fires, and when not to fight a fire and evacuate the area instead.

5 REFERENCES

None

6 APPENDICES

None

ASSURED GROUNDING & GFCI

AUG./ 2010

14

EH&S 201

1 PURPOSE AND SCOPE

Purpose

The purpose of this standard is to protect all Becht employees from the hazards of electrocution from unsafe electrical tools and extension cords.

Scope

The scope of the Assured Grounding program is to ensure that the black wires (hot), white wires (neutral), and, in particular, green wires (ground) of extension cords and power tool cords are properly connected. This is done by testing every extension cord and power tool when it is first put into service, following repairs, and every three months.

2 GENERAL

Definitions

Competent person means one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.

Responsibilities

Non-applicable

3 PROCEDURE

OSHA requires that employers shall use either ground-fault circuit interrupters or assured equipment grounding conductor program to protect employees on construction sites.

***NOTE*** All Becht Engineering employees shall use Ground-Fault

Circuit Interrupts as protection.


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EH&S 201

Ground-Fault Circuit Interrupters All 120-volt, single-phase 15- and 20-ampere receptacle outlets on

construction sites, which are not part of the permanent wiring of the building or structure and which are in use by employees, shall have approved ground-fault circuit interrupters for personnel protection.

Receptacles on a two-wire, single-phase portable or vehicle-mounted generator rated not more that 5kV, where the circuit conductors of the generator are insulated from the generator frame and all other grounded surfaces, need not be protected with ground-fault circuit interrupters.

Assured Equipment Grounding Conductor Program

Becht Engineering, when required by the client or the situation demands it, shall establish and implement an assured equipment grounding conductor program on construction sites covering all cord sets, receptacles which are not a part of the building or structure, and equipment connected by cord and plug which are available for use or used by employees. Assured equipment grounding conductor program shall comply with the following minimum requirements: A written description of the program, including the specific procedures

adopted Becht Engineering and/or Client. The description and procedures shall be available at the jobsite for inspection and copying by OSHA and any affected employee.

Becht shall designate one or more competent persons to implement the program.

Each cord set , attachment cap, plug and receptacle of cord sets, and any equipment connected by cord and plug, except cord sets and receptacles which are fixed and not exposed to damage, shall be visually inspected before each day's use for external defects, such as deformed or missing pins or insulation damage, and for indications of possible internal damage. Equipment found damaged or defective shall not be used until repaired.

The following tests shall be performed on all cord set, receptacles which are not a part of the permanent wiring of the building or structure, and cord-and plug-connected equipment required to be grounded.


AUG./ 2010

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EH&S 201

Equipment Testing All equipment grounding conductors shall be tested for continuity and

shall be electrically continuous. Each receptacle and attachment cap or plug shall be tested for correct

attachment of the equipment grounding conductor. The equipment grounding conductor shall be connected to its proper terminal.

All required tests shall be performed: a) Before first use. b) Before equipment is returned to service following any repairs. c) Before equipment is used after any incident which can be

reasonably suspected to have caused damage (for example, when a cord set is run over).

d) At intervals not to exceed 3 months, except that cord sets and receptacles which are fixed and not exposed to damage shall be tested at intervals not exceeding 6 months.

e) The employer shall not make available or permit the use by employees of any equipment which has not met these four requirements.

f) Tests performed as required in the preceding paragraph shall be recorded. This test record shall identify each receptacle, cord set, and cord- and plug-connected equipment that passed the test and shall indicate the last date it was tested or the interval for which it was tested. This record shall be kept by means of logs, color coding, or other effective means and shall be maintained until replaced by a more current record. The record shall be made available on the jobsite for inspection by OSHA and any affected employee.

One of the methods listed by OSHA as part of acceptable record keeping is to establish a color code for marking cord sets and cord- and plug-connected equipment. The table below lists a color code that is in wide use by electricians and contractors. Colored plastic or vinyl electrical tape is placed on one or both ends of cords and cord- and plug-connected equipment to denote the month that the tests were performed.


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EH&S 201

Assured Equipment Grounding Conductor Program Color Code

Quarter # Month Tested Color of tape(s) to apply to cord

1 January White

2 April Green

3 July Red

4 October Orange

As an easy reminder of the color of the tape to place on the newly tested cord, remember the color for the start of each calendar quarter by the season: White in January for Winter Green in April for Spring Red in July for Summer, or the 4th of July Orange in October for Fall, or pumpkins.

4 TRAINING

Each employee will receive training as required by the job location and the requirement of the client. Every employee will be trained on Assured Grounding and GFCI use during orientation and on an annual basis.

5 REFERENCE

Occupational Safety and Health Administration REGULATIONS (Standards - 29 CFR) 1926.404 - Wiring Design and Protection.

6 APPENDICES

None

CONFINED SPACE ENTRY

AUG./ 2010

18

EH&S

202

1 PURPOSE AND SCOPE

Purpose

This procedure provides the mandatory safety guidelines to enter and perform work within confined spaces.

Scope

This procedure applies to all Becht Engineering personnel and subcontractors working on projects where confined space entry safety requirements are applicable.

2 GENERAL

Definitions

Confined Space: A confined space has limited or restricted means of entry or exit. Is large enough for an employee to enter and perform assigned work. Is not designed for continuous occupancy by the employee. These

spaces may include, but are not limited to, underground vaults, manholes, tanks, storage bins, pits and diked areas, vessels, and silos.

Permit-Required Confined Space: A "permit-required confined space" is one that meets the definition of a confined space and has one or more of these characteristics: contains or has the potential to contain a hazardous atmosphere, contains a material that has the potential for engulfing an entrant, has an internal configuration that might cause an entrant to be trapped

or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross section, and/or contains any other recognized serious safety or health hazards.

Entry supervisor: The person (such as the employer, foreman, or crew chief) responsible for determining if acceptable entry conditions are present at a permitted confined space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry as required.

Attendant: An individual stationed outside one or more permit spaces who monitors the authorized entrants and who performs all attendant‘s duties assigned in the employer‘s permit space program.


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EH&S

202

Authorized entrant: An employee who is authorized by the employer to enter a permit

space.

Responsibilities

Non-applicable

3 PROCEDURE

Entry into Permit-Required Confined Spaces Prior to entry into any permit-required confined space, the entry supervisor will: Issue a permit that specifies the location, type, and duration of the

work to be done, and the date. Certify that all existing hazards have been evaluated by the supervisor

and that necessary protective measures have been taken for the safety of workers.

Provide documentation of the atmospheric testing that has been done. Assign entry and attendant duties to specific persons.

Before issuing an entry permit, the entry supervisor will be responsible for the following: Assure there are no dangers of explosion, asphyxiation, toxic

gases/fumes, engulfment or entrapment, electrical or mechanical hazards, etc.

Isolate the space from potential hazards, if possible, to provide for safe entry.

Purge, inert, flush, ventilate to eliminate atmospheric hazards. Provide external barriers and warning signs. Perform pre-entry oxygen, flammable gas and toxicity air tests. All test

results are to be recorded on the entry permit. If potential hazards cannot be isolated, continuous monitoring is required. If potential hazards can be isolated, periodic monitoring is required.

Provide at least one trained attendant outside of each confined space that will be entered.

Ensure that rescue and emergency services and equipment are in place as noted in this policy.

Ensure that all required equipment is provided, maintained and properly used. This includes air monitoring equipment, forced air ventilation equipment, communications equipment, personal protective equipment (PPE), lighting, external barriers and warning signs, ladders, and rescue equipment.


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EH&S

202

If hazardous conditions are detected during entry, employees will immediately leave the space and the supervisor will determine the cause of the hazardous atmosphere and take corrective actions before allowing re-entry.

Rescue & Emergency Services If proper protective measures are taken to eliminate and control any

possible hazards in the confined space (i.e., ventilation, purging, monitoring, lockout/tag-out, etc.), rescue operations should not be necessary. Nonetheless, we must be prepared for the worst case scenario.

When working at remote sites ensure you know the emergency procedures for that site. If you are not given guidance then request it before your begin work.

Under no circumstances is the attendant to enter the space to effect rescue; rescue operations must be left to trained Emergency Response Team personnel.

Subcontractors

Subcontractors shall be required to submit written policies and procedures for entry into permit-required confined spaces that are at least as stringent as our policies and procedures. Entry into confined spaces by the subcontractors must be coordinated with and approved by the entry supervisor in charge of the confined space.

Subcontractors will be responsible for providing all training, equipment, testing, personnel and emergency services, and permits for entry into confined spaces by their employees.

In cases where our employees and those of subcontractors may be entering the same confined spaces or where operations of subcontractors may impact the hazards involved in the confined spaces we must enter, the supervisor will coordinate our efforts and protective measures with those of the subcontractors.


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EH&S

202

4 TRAINING

Becht Engineering shall provide training so that all employees whose work is regulated by EH&S 202 acquire the understanding, knowledge, and skills necessary for the safe performance of the duties assigned under this standard. Training shall be provided to each affected employee: Before the employee is first assigned duties under this standard; Before there is a change in assigned duties; Whenever there is a change in permit space operations that presents a

hazard about which an employee has not previously been trained; Whenever the employer has reason to believe either that there are

deviations from the permit space entry procedures of this standard or that there are inadequacies in the employee‘s knowledge or use of these procedures.

The training shall establish employee proficiency in the duties required by this standard and shall introduce new or revised procedures, as necessary, for compliance with this section.

Becht Engineering shall certify that the training required by this standard has been accomplished. The certification shall contain each employee‘s name, the signatures or initials of the trainers, and the dates of training. The certification shall be available for inspection by employees and their authorized representatives.

5 REFERENCE

OSHA 29 CFR 1910.146 Permit-required confined spaces.

6 APPENDICES

None

FALL PROTECTION

AUG./ 2010

22

EH&S 203

1 PURPOSE AND SCOPE

Purpose

Purpose is to establish protective controls for personnel working at elevated heights and to establish a system for identification of areas requiring personnel to work at elevated heights of six (6) feet or greater.

Scope

This procedure establishes the minimum requirements and covers all Becht Engineering employees working at unguarded elevated work locations that are six (6) feet or more above floor or grade level. It also covers work sites adjacent to pits, trenches, docks, platforms and catwalks where is a fall potential of greater than (6) feet or more.

2 GENERAL

Definitions

Anchorage: A secure point of attachment, not part of the work surface, to which lifelines, drop-lines, or lanyards are affixed. An anchorage must be capable of supporting a minimum dead weight of 5,000 pounds (2,268 kilograms) for every person attached to it. An anchorage is often a beam, girder, column, or floor.

Anchorage connector: A component or device that is installed on an anchorage and is specifically intended for attaching a fall-arrest system to the anchorage. Anchorage connection straps, carabineers, and girder grips rated to support a minimum dead weight of 5,000 pounds (2,268 kilograms). Carabineer: A trapezoid or oval shaped connector component with a gate or similar arrangement that remains closed until it is intentionally opened for connection or disconnection.

Descent Device: A device or piece of equipment used to escape from an elevated structure such as a work platform, tower, column, or an overhead crane cab. Energy Shock Absorber: A device that limits shock-load forces on the body. Some lanyards have built-in shock absorbers. Most energy shock absorbers are made of webbing material with tear-away stitching designed to gradually absorb the fall-arrest load.

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EH&S 203

Fall-Arrest System: A system specifically designed to secure, suspend, or assist in retrieving a worker in or from a hazardous work area. A fall-arrest system may not prevent a fall, but it will reduce the fall distance and prevent or reduce injury. The basic components of a fall-arrest system include an anchorage, anchorage connector, lanyard, shock absorber, harness, and self-locking snap hook.

Fall Hazard: A condition or situation that could result in a fall.

Fallout: An unintentional separation of a person from a body-support component during or after fall arrest.

Fall Prevention: Eliminating fall hazards during all phases of work at heights, including access and egress. Examples of fall prevention measures include using complete scaffolds, aerial lifts, and secured ladders.

Free Fall: An un-arrested fall.

Harness (full-body): A device with straps that can be attached to a fall-arrest system. The straps are fastened around a person‘s body to contain the torso and distribute fall-arrest forces over at least the upper thighs, pelvis, chest and shoulders.

Lanyard: A flexible line that secures a person wearing a harness to an anchorage, anchorage connector, lifeline, or drop line. A lanyard must have a nominal breaking strength of 5,000 pounds (2,268 kilograms) and may be nylon or Dacron rope, flexible aircraft steel cable, or webbing.

Leading Edge: The edge of a floor, deck, or grating that changes location as additional floor or deck sections are placed.

Lifeline: A flexible vertical or horizontal line, secured to an anchorage or between two anchorages, to which a lanyard or harness may be attached. A Catenary lifeline is a lifeline used in a horizontal position that is secured between two anchorages. A lanyard can be attached to a catenary lifeline by using a sliding connection or by tying off. Positioning Device System: Equipment that allows a person to work with both hands free while standing in such a way (for example, leaning backward) that a fall could result. Positioning device systems are often used on framework construction and concrete rebar replacement.

FALL PROTECTION

AUG./ 2010

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EH&S 203

Retractable lifeline: A fall-arrest device that allows free travel without slack rope, but locks instantly when a fall begins. Retractable lifelines may be used when vertical movement is required but must be limited, such as in tanks, manholes, and pressure vessels, or on roofs.

Rollout: A process by which a snap hook or carabineer unintentionally disengages from another connector or object.

Rope Grabs (Fall-Arrester): Automatic lifeline devices that act by inertia to grab the lifeline if a fall should occur. Rope grabs are used when vertical movement is required, such as work from boatswain chairs or suspended scaffolds.

Self-locking Snap Hook: A hook-shaped connector with a gate or similar arrangement that remains closed and locked until it is intentionally opened for connection or disconnection. When the gate is released, it automatically closes.

Responsibilities

Non-applicable

3 PROCEDURE

Fall Hazard Identification and Evaluation: The senior Becht employee on each jobsite will be responsible for identifying fall hazards on their jobsite. He/she will evaluate each situation or work procedure where employees may be exposed to a fall of 6 feet or more. The senior employee will be responsible for developing a plan to eliminate the exposures, if possible, or to select the appropriate fall protection systems and/or equipment. When purchasing equipment and raw materials for use in fall protection systems applicable ANSI & ASTM requirements should be met. Examples of Situations Requiring Fall Protection: Becht Engineering is not a contracting company nor are we responsible for on site safety, we should be cognizant of the required fall protection safety requirements when we are out on a job. The following are examples of situations were fall protection would be needed. This listing is by no means complete, and there are many other situations where a fall of 6 feet or more is possible. It should be noted that ladders and scaffolding are not included in this list because they are covered by other OSHA standards and other requirements of our safety program.

FALL PROTECTION

AUG./ 2010

25

EH&S 203

Wall Openings Each employee working on, at, above, or near wall openings (including those with chutes attached) where the outside bottom edge of the wall opening is 6 feet (1.8 meters) or more above lower levels and the inside bottom edge of the wall opening is less than 39 inches (1.0 meter) above the walking/working surface must be protected from falling by the use of a guardrail system, a safety net system, or a personal fall arrest system. Holes Personal fall arrest systems, covers, or guardrail systems shall be erected around holes (including skylights) that are more than 6 feet (1.8 meters) above lower levels. Leading Edges Each employee who is constructing a leading edge 6 feet (1.8 meters) or more above lower levels shall be protected by guardrail systems, safety net systems, or personal fall arrest systems. Excavations Each employee at the edge of an excavation 6 feet (1.8 meters) or more deep shall be protected from falling by guardrail systems, fences, barricades, or covers. Where walkways are provided to permit employees to cross over excavations, guardrails are required on the walkway if it is 6 feet (1.8 meters) or more above the excavation. Formwork and Reinforcing Steel For employees, while moving vertically and/or horizontally on the vertical face of rebar assemblies built in place, fall protection is not required when employees are moving. OSHA considers the multiple hand holds and foot holds on rebar assemblies as providing similar protection as that provided by a fixed ladder. Consequently, no fall protection is necessary while moving point to point for heights below 24 feet (7.3 meters). An employee must be provided with fall protection when climbing or otherwise moving at a height more than 24 feet (7.3 meters), the same as for fixed ladders.

FALL PROTECTION

AUG./ 2010

26

EH&S 203

Hoist Areas Each employee in a hoist area shall be protected from falling 6 feet (1.8 meters) or more by guardrail systems or personal fall arrest systems. If guardrail systems (or chain gate or guardrail) or portions thereof must be removed to facilitate hoisting operations, as during the landing of materials, and a worker must lean through the access opening or out over the edge of the access opening to receive or guide equipment and materials, that employee must be protected by a personal fall arrest system. Ramps, Runways, and Other Walkways Each employee using ramps, runways, and other walkways shall be protected from falling 6 feet (1.8 meters) or more by guardrail systems. Low-slope Roofs Each employee engaged in roofing activities on low-slope roofs with unprotected sides and edges 6 feet (1.8 meters) or more above lower levels shall be protected from falling by guardrail systems, safety net systems, personal fall arrest systems or a combination of a warning line system and guardrail system, warning line system and safety net system, warning line system and personal fall arrest system, or warning line system and safety monitoring system. On roofs 50 feet (15.24 meters) or less in width, the use of a safety monitoring system without a warning line system is permitted. Steep Roofs Each employee on a steep roof with unprotected sides and edges 6 feet (1.8 meters) or more above lower levels shall be protected by guardrail systems with toe-boards, safety net systems, or personal fall arrest systems.

Controlled Access Zones A Controlled access zone is a work area designated and clearly marked in which certain types of work may take place without the use of conventional fall protection systems, personal arrest or safety net—to protect the employees working in the zone. Controlled access zones are used to keep out workers other than those authorized to enter work areas from which guardrails have been removed. Controlled access zones, when created to limit entrance to areas where leading edge work and other operations are taking place, must be defined by a control line or by any other means that restrict access.

FALL PROTECTION

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EH&S 203

Control lines shall consist of ropes, wires, tapes or equivalent materials, and supporting stanchions, and each must be:

Flagged or otherwise clearly marked at not more than 6-foot (1.8 meters) intervals with high-visibility material;

Rigged and supported in such a way that the lowest point (including sag) is not less than 39 inches (1 meter) from the walking/working surface and the highest point is not more than 45 inches (1.3 meters)--nor more than 50 inches (1.3 meters) when overhand bricklaying operations are being performed from the walking/working surface;

Strong enough to sustain stress of not less than 200 pounds (0.88 kilonewtons). Control lines shall extend along the entire length of the unprotected or leading edge and shall be approximately parallel to the unprotected or leading edge.

Control lines also must be connected on each side to a guardrail system or wall.

When control lines are used, they shall be erected not less than 6 feet (1.8 meters) nor more than 25 feet (7.6 meters) from the unprotected or leading edge, except when pre-cast concrete members are being erected. In the latter case, the control line is to be erected not less than 6 feet (1.8 meters) or more than 60 feet (18 meters) or half the length of the member being erected, whichever is less, from the leading edge.

Controlled access zones when used to determine access to areas where overhand bricklaying and related work are taking place are to be defined by a control line erected not less than 10 feet (3 meters) nor more than 15 feet (4.6 meters) from the working edge. Additional control lines must be erected at each end to enclose the controlled access zone. Only employees engaged in overhand bricklaying or related works are permitted in the controlled access zones.

On floors and roofs where guardrail systems are not in place prior to the beginning of overhand bricklaying operations, controlled access zones will be enlarged as necessary to enclose all points of access, material handling areas, and storage areas.

On floors and roofs where guardrail systems are in place, but need to be removed to allow overhand bricklaying work or leading edge work to take place, only that portion of the guardrail necessary to accomplish that day‘s work shall be removed.

FALL PROTECTION

AUG./ 2010

28

EH&S 203

Fall Protection Systems When there is a potential fall of 6 feet or more, we will utilize one or more of the following means of providing protection: Guardrail Systems Guardrail systems must meet the following criteria. The top edge height of top-rails or (equivalent) guardrails must be 42

inches (1.1 meters) plus or minus 3 inches (8 centimeters), above the walking/working level. When workers are using stilts, the top edge height of the top rail, or equivalent member, must be increased an amount equal to the height of the stilts.

Top-rails and mid-rails of guardrail systems must be at least one-quarter inch (0.6 centimeters) nominal diameter or thickness to prevent cuts and lacerations.

If wire rope is used for top-rails, it must be flagged at not more 6 feet intervals (1.8 meters) with high-visibility material. Steel and plastic banding cannot be used as top-rails or mid-rails.

Manila, plastic, or synthetic rope used for top-rails or mid-rails must be inspected as frequently as necessary to ensure strength and stability.

When mid-rails are used, they must be installed at a height midway between the top edge of the guardrail system and the walking/working level. When screens and mesh are used, they must extend from the top rail to the walking/working level and along the entire opening between top rail supports. Intermediate members, such as balusters, when used between posts, shall not be more than 19 inches (48 centimeters) apart.

Other structural members, such as additional mid-rails and architectural panels, shall be installed so that there are no openings in the guardrail system more than 19 inches (48 centimeters).

The guardrail system must be capable of withstanding a force of at least 200 pounds (890 newtons) applied within 2 inches of the top edge in any outward or downward direction. When the 200 pound (890 newtons) test is applied in a downward direction, the top edge of the guardrail must not deflect to a height less than 39 inches (1 meter) above the walking/working level.

Mid-rails, screens, mesh, intermediate vertical members, solid panels, and equivalent structural members shall be capable of withstanding a force of at least 150 pounds (667 newtons) applied in any downward or outward direction at any point along the mid-rail or other member. Guardrail systems shall be surfaced to protect workers from punctures or lacerations and to prevent clothing from snagging. The ends of top rails and

FALL PROTECTION

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EH&S 203

mid-rails must not overhang terminal posts, except where such overhang does not constitute a projection hazard. When guardrail systems are used at hoisting areas, a chain, gate or removable guardrail section must be placed across the access opening between guardrail sections when hoisting operations are not taking place. At holes, guardrail systems must be set up on all unprotected sides or edges. When holes are used for the passage of materials, the hole shall have not more than two sides with removable guardrail sections. When the hole is not in use, it must be covered or provided with guardrails along all unprotected sides or edges. If guardrail systems are used around holes that are used as access points (such as ladder ways), gates must be used or the point of access must be offset to prevent accidental walking into the hole. If guardrails are used at unprotected sides or edges of ramps and runways, they must be erected on each unprotected side or edge. Personal Fall Arrest Systems Personal Fall Arrest Systems consist of an anchorage, connectors, and a body harness and may include a deceleration device, lifeline, or suitable combinations. If a personal fall arrest system is used for fall protection, it must do the following: Limit maximum arresting force on an employee to 900 pounds (4

kilonewtons) when used with a body belt; Limit maximum arresting force on an employee to 1,800 pounds (8

kilonewtons) when used with a body harness; Be rigged so that an employee can neither free fall more than 6 feet

(1.8 meters) nor contact any lower level; Bring an employee to a complete stop and limit maximum deceleration

distance an employee travels to 3.5 feet (1.07 meters); and Have sufficient strength to withstand twice the potential free fall impact

energy of an employee at a distance of 6 feet (1.8 meters) or the free fall distance permitted by the system, whichever is less.

The employer shall provide for prompt rescue of employees in the event of a fall or shall assure the employees are able to rescue themselves.

The use of body belts for fall arrest is prohibited and a full body harness is required. Personal fall arrest systems must be inspected prior to each use for wear damage, and other deterioration. Defective components must be removed from service. All accidents and serious incidents (near accidents) must be investigated, implementing

changes to the fall protection plan as necessary.

FALL PROTECTION

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EH&S 203

Positioning Device Systems These body belt or body harness systems are to be set up so that a worker cans free fall no farther than 2 feet (0.6 meters). They shall be secured to an anchorage capable of supporting a least twice the potential impact load of an employee‘s fall or 3,000 pounds (13.3 kilonewtons), whichever is greater.

Safety Monitoring Systems When no other alternative fall protection has been implemented, the employer shall implement a safety monitoring system. Employers must appoint a competent person to monitor the safety of workers and the employer shall ensure that the safety- monitor: Is competent in the recognition of fall hazards; Is capable of warning workers of fall hazard dangers and in detecting

unsafe work practices; Is operating on the same walking/working surfaces of the workers and

can see them; Is close enough to work operations to communicate orally with workers

and has no other duties to distract from the monitoring function. Mechanical equipment shall not be used or stored in areas where

safety monitoring systems are being used to monitor employees engaged in roofing operations on low-sloped roofs.

No worker, other than one engaged in roofing work (on low-sloped roofs) or one covered by a fall protection plan, shall be allowed in an area where an employee is being protected by a safety monitoring system.

All workers in a controlled access zone shall be instructed to promptly comply with fall hazard warnings issued by safety monitors.

Safety Net Systems Safety nets must be installed as close as practicable under the walking/working surface on which employees are working and never more than 30 feet (9.1 meters) below such levels. Defective nets shall not be used. Safety nets shall be inspected at least once a week for wear, damage, and other deterioration. Safety nets shall be installed with sufficient clearance underneath to prevent contact with the surface or structure below. Items that have fallen into safety nets including—but not restricted to, materials, scrap, equipment, and tools—must be removed as soon as possible and at least before the next work shift.

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EH&S 203

Warning Line Systems Warning line systems consist of ropes, wires, or chains, and supporting stanchions and are set up as follows: Flagged at not more than 6-foot (1.8 meters) intervals with high-

visibility material; Rigged and supported so that the lowest point including sag) is no less

than 34 inches (0.9 meters) from the walking/working surface and its highest point is no more than 39 inches (1 meter) from the walking/working surface.

Stanchions, after being rigged with warning lines, shall be capable of resisting, without tipping over, a force of at least 16 pounds (71 newtons) applied horizontally against the stanchion, 30 inches (0.8 meters) above the walking/working surface, perpendicular to the warning line and in the direction of the floor, roof, or platform edge.

The rope, wire, or chain shall have a minimum tensile strength of 500 pounds (2.22 kilonewtons) and after being attached to the stanchions, must support without breaking the load applied to the stanchions as prescribed above.

Rope, wire, or chain shall be attached to each stanchion in such a way that pulling on one section of the line between stanchions will not result in slack being taken up in the adjacent section before the stanchion tips over.

Warning lines shall be erected around all sides of roof work areas. When mechanical equipment is being used, the warning line shall be erected not less than 6 feet (1.8 meters) from the roof edge parallel to the direction of mechanical equipment operation, and not less than 10 feet (3 meters) from the roof edge perpendicular to the direction of mechanical equipment operation.

When mechanical equipment is not being used, the warning line must be erected not less than 6 feet (1.8 meters) from the roof edge.

Covers Covers located in roadways and vehicular aisles must be able to support at least twice the maximum axle load of the largest vehicle to which the cover might be subjected. All other covers must be able to support at least twice the weight of employees, equipment, and materials that may be imposed on the cover at any one time. To prevent accidental displacement resulting from wind, equipment, or workers‘ activities, all covers must be secured. All covers shall be color coded or bear the markings "HOLE" or "COVER."

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EH&S 203

Protection From Falling Objects When guardrail systems are used to prevent materials from falling from one level to another, any openings must be small enough to prevent passage of potential falling objects. No materials or equipment except masonry and mortar shall be stored within 4 feet (1.2 meters) of working edges. Excess mortar, broken or scattered masonry units, and all other materials and debris shall be kept clear of the working area by removal at regular intervals. During roofing work, materials and equipment shall not be stored within 6 feet (1.8 meters) of a roof edge unless guardrails are erected at the edge, and materials piled, grouped, or stacked near a roof edge must be stable and self-supporting.

4 TRAINING

Employees should be trained in the following areas: the nature of fall hazards in the work area; the correct procedures for erecting, maintaining, disassembling, and

inspecting fall protection systems; the use and operation of controlled access zones and guardrail,

personal fall arrest, safety net, warning line, and safety monitoring systems;

the limitations on the use of mechanical equipment during the performance of roofing work on low-sloped roofs;

Employees‘ role in fall protection plans. Retraining shall occur when there are work place changes or upgrades

in equipment. Becht Engineering will have written certification records showing who was trained, when, dates of training, signature of person providing training and the date Becht Engineering determined the training was deemed adequate. Becht Engineering shall provide re-training when the following are noted: Deficiencies in training. Work place changes. Fall protection systems or equipment changes that render previous

training obsolete.

5 REFERENCE

Title 29, Code of Federal Regulations, Parts 1910 and 1926, Occupational Safety and Health Administration (OSHA), U.S. Department of Labor.

ANSI A10.14 - Safety Belts, Harnesses, Lanyards, Lifelines and Drop

Lines for Construction and Industry

FALL PROTECTION

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ANSI Z359.1-1992

6 APPENDICES

None

PERSONAL PROTECTION EQUIPMENT

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1 PURPOSE AND SCOPE

Purpose

The purpose of this program is to protect our employees by ensuring that Personal Protective Equipment (PPE) is provided, used, and maintained in a sanitary and reliable condition whenever it is necessary due to hazards from processes or in the work environment. To the extent that it is possible and feasible, the company will remove or eliminate hazards or exposures through engineering means to eliminate the need for PPE.

Scope

This program covers eye and face protection, head protection, foot protection, hand protection, and electrical protection. Respiratory hazards and hearing hazards are covered by other programs, but they will also be included in the Hazard Assessment described below. This program covers the responsibilities of managers, supervisors and workers, assessment of hazards, selection and use of personal protective equipment (PPE), and training.

2 GENERAL

Definitions

None

Responsibilities

The senior advisor on site Will be responsible for assessing the hazards and exposures that may

require the use of PPE, determining the type of equipment to be provided, and purchasing the equipment. Input from managers, supervisors, and employees will be obtained and considered in selecting appropriate equipment.

Managers/supervisors Will be responsible for training employees in the use and proper care

of PPE, ensuring that all employees are assigned appropriate PPE, and ensuring that PPE is worn by employees when and where it is required.


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Employees Are responsible for following all provisions of this program and related

procedures. They are expected to wear PPE when and where it is required. Employee-owned equipment is permitted, however Becht must inspect it prior to its use to assure it is adequate, properly maintained & disposed of (when necessary).

3 PROCEDURE

Hazard Assessment The company will perform an assessment of the workplace to determine if hazards are present, or likely to be present, which necessitate the use of personal protective equipment (PPE). This assessment will consist of a survey of the workplace to identify sources of hazards to workers. Consideration will be given to hazards such as impact, penetration, laceration, compression (dropping heavy objects on foot, roll-over, etc.), chemical exposures, harmful dust, heat, light (optical) radiation, electrical hazards, noise, etc. Where such hazards are present, or likely to be present, we will: Select, and have each affected employee use, the types of PPE that

will protect the employee from the hazards identified in the hazard assessment.

Communicate equipment selection decisions to each affected employee.

Select PPE that properly fits each affected employee. Train employees in the use and care of PPE as described elsewhere in

this program. Defective or damaged equipment will not be used.

Selection of Personal Protective Equipment Personal protective equipment (PPE) will be selected on the basis of the hazards to which the workers' are exposed or potentially exposed. All selections will be made by with input from managers, supervisors and workers. Personal protective equipment will meet the following standards: Eye & Face Protection devices - ANSI Z87.1-1989 "American

National Standard Practice for Occupational and Educational Eye and Face Protection"


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Head Protection devices - ANSI Z89.1-1986 "American National Standard for Personal Protection - Protective Headwear for Industrial Workers"

Foot Protection devices - ANSI Z41-1991 "American National Standard for Personal Protection - Protective Footwear"

Hand Protection - No national standard available - selection will be based on task performed, conditions present, duration of use, and the hazards and potential hazards identified.

Electrical Protective equipment - No national standard - equipment will be tested electrically before first use and every 6 months thereafter or upon indication that insulating value is suspect.

Care of Personal Protective Equipment Whenever practical, PPE will be assigned to individual workers for their

exclusive use. Employees will be responsible for the PPE equipment assigned to them or used by them.

PPE will be regularly cleaned, inspected and stored according to instructions given during the training sessions or as directed by supervisors or managers. Defective or damaged PPE shall not be used. Employees are to report any defective or damaged equipment to their supervisor for repair or replacement.

Protective Clothing and Equipment Requirements Protective Clothing: Personnel exposure to potentially harmful

environments must be minimized before a job is started. Protective equipment is available to enable work to be carried on when there may be employee exposure. Experience tells us that approximately 15 percent of all accidents are caused by unsafe conditions. Most of these accidents can be eliminated or minimized by using personal protective equipment. This section describes the many types of personal protective equipment available and when they must be worn. PPE which has been changed in any manner, thus reducing its effectiveness, shall be repaired or destroyed.

Head Protection: A safety hat shall be worn in areas under

construction and in other areas where there‘s a potential hazard from falling or flying objects or from head-level obstructions. Such areas shall be posted. Only approved safety hats with properly installed headbands and support webbing shall be used in the situations described above. See OSHA 1910.135 and ANSI Z89.1-1969 for requirements. Electrically conductive hats shall not be worn by electricians or by others where electrical hazards exist.


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When visiting foreign locations that do not recognize OSHA safety requirements, an effort should be made to determine in advance the type of safety hat provided in that location. If there is any doubt as to the adequacy of the type of hat available, a safety hat should be obtained prior to departure from the home office.

Foot protection: There are few jobs, if any, where the protection of a

safety shoe is not advisable. They protect the toes from falling objects, being pinched between objects, etc. The safety shoe also offers additional slip resistance to those employees who work in oily areas. Safety shoes are recommended for operating, mechanical, shop general utility and other assignments which might subject the feet to potential injury. Sandals, open-toed, and backless footwear shall be avoided as they afford little foot protection against falling objects or spilled liquids. Rubber overshoes, boots, or shoes with soft rubber, spongy gum rubber, or composition insulation-type soles shall not be worn where a buildup of body static charges create a hazard since the higher electrical resistance of these materials retards dissipation of the static. Becht Engineering will reimburse $50.00 towards the purchase of steel tipped safety shoes.

Electrically-conductive soles may be required in conjunction with conductive, electrically grounded floors for work in certain explosion hazard areas. Rubber or insulating shoes shall not be permitted areas where conductive soles are required.

Nonconductive shoes may be required in conjunction with the work of the electricians.

Rubber boots or rubbers may be required in wet areas or where large quantities of corrosive materials are used.

Ear protection: In areas of high noise levels, the noise may cause

fatigue and distraction which could result in accidental injury. Excessive exposure to noise will cause hearing lose. Ear protectors should be worn when noise levels are over 90 decibels. There are a wide variety of such protectors available. The type supplied is governed by personal preference and/or by the job requirements. When the noise level is such that ordinary conversation is difficult, protection is recommended. Speech interpretation is easier in such


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areas with ear protection than without. Foam ear protection plugs are available at the Becht Engineering office and should be taken on trips where noise exposure is expected.

Hand Protection: Gloves of the correct type give protection from heat

and cold, corrosives, moisture, electricity, sharp or rough surfaces, flying fragments, etc.

Wear rubber gloves when handling corrosive chemicals or other hazardous liquids. Test your gloves for leaks by inflating with air and immersing in water. Do not use gloves which are perforated. Where protection hand is necessary and where extreme dexterity and sensitivity are important, special neoprene surgical or vinyl disposable gloves should be used. Always wash your gloves before removal. Clean them inside, too, before laying aside for future use. This precaution avoids the accumulation of hazardous materials inside the glove.

Some irritating chemicals are absorbed by rubber gloves; for example, acrylonitrile. Gloves used with this or similar materials shall be discarded after one week of actual use.

For wet work out-of-doors in cold weather, vinyl-coated lined gloves should be used.

Wear insulated gloves without cuffs when handling extremely cold materials such as dry ice, liquid nitrogen, etc., because cold burns are as serious as heat burns.

Terry cloth gloves should be used for protection against materials not at ambient temperatures. It is important to protect the forearm, too, when handling such objects.

Leather palm/canvas backed gloves should be used for protection against abrasions and lacerations when working with rough or sharp materials.

Body protection: Loose gloves, clothing or long, loose sleeves;

neckties; pendant jewelry; finger rings; open jackets; etc.; shall not be worn around moving equipment. Further, fingers rings, wristwatches, and other metallic jewelry shall not be worn around electrical equipment because accidental contact could cause a potentially serious personal injury.

Cotton clothing which covers the arms and body provides

considerable protection against flash burns, the sun=s rays,

insect bites, and poison ivy. Wool gives better protection from welder‘s flashes and splashed corrosive liquids. Tightly


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woven cloth gives better temporary splash protection than loosely woven materials.

Silk, light rayon, polyesters, and other synthetics or plastic materials, while sometimes more resistant to corrosive chemicals than cotton or wool, can melt or burn the skin when exposed to a flash and can contribute to the generation of static electricity. Their use shall be avoided in areas where flammable vapors or other materials can be ignited by a static discharge. Cotton is considered the best of untreated cloth or fabric for either flame resistance or static charge buildup generally loses its resistance upon contact with quantities of water, such as rain, severe sink splashes, laundering, etc

Specialized suits such as rubber and plastic aprons and acid suits for protection from chemical exposure are not normally required because Becht Engineering personnel are not expected to be exposed to such hazards. Should the potential for such exposure exist on an assignment, such protection and training shall be obtained from the host organization.

Safety Harnesses: Approved safety harnesses must be worn when

employees are exposed to falls from unprotected heights of 6 feet, or less, if required by the host plant safety rules. Life lines should be secured to an independent support located above the point of operation. Some of the situations in which safety harnesses must be worn are:

When working from scaffolds, platforms, piperacks or any other surface which may not afford sufficient protection against falling.

While working on any roof with a slope greater than one on four

When working within six feet of the edge of any roof.

Where an oxygen deficiency exists or where the surrounding atmosphere is immediately hazardous to life.

Life vests: Life vests are required when working on barges or directly

over water.

Eye Protection: Eye protective equipment adequate for the job or area shall be worn at all times in laboratory, shop, construction,


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maintenance, chemical transfer, compounding, processing, and testing areas; chemical and mechanical stock sections in stockrooms; and other areas specifically posted. Also, employees on field assignments where their work takes them into areas described above shall wear eye protection. Minimum eye protection, where required, is safety spectacles or visitor safety spectacles. When in doubt, protect your eyes. An employee working in an area in which eye protection is required is responsible to inform anyone entering the area without such protection of the requirement.

EYE PROTECTION IS NOT REQUIRED IN OFFICES, CAFETERIAS, RESTROOM, CORRIDORS, ELEVATORS, STAIRWELLS, SITE GROUNDS AND ON ROOFS, ETC., EXCEPT BY THOSE PERFORMING MECHANICAL OR LABORATORY TYPE WORK IN SUCH LOCATIONS.

Contact lenses do not constitute eye protection. If worn, a minimum of safety spectacles or visitor safety spectacles also must be worn in all situations where eye protection is required. Contact lenses shall not be worn when using a full face respirator breathing apparatus; working in dusty or chemical fume environments; working near electrical, electronic or arc welding activities. The National Society for the prevention of Blindness strongly recommends against contact lens use by industrial employees while at work.

Becht Engineering will reimburse employees for the cost of prescription safety glasses, paying up to $100.00 of the total expense.

Goggles: For many operations such as handling corrosives, etc.,

safety spectacles are not adequate; and splash goggles or face shields are needed. The need for such goggles will generally be identified by the host company and provided by them. Splash goggles shall be worn to protect against eye exposure to chemicals by splash, spray, mist, or dust.

Chippers Goggles shall be worn to protect against eye exposure to falling or flying particles or chips.

A Welders Shield shall be worn when performing or witnessing arc welding operations to protect both the face and eyes. Welders‘ goggles shall be worn for eye protection in gas welding and cutting operation, guarding against injurious ultraviolet and infrared radiation, and intense glare, as well as sparks or hot metal fragments. Darker shade lenses are required to protect the more intense glare of arc welding. Specialized lenses also are required in goggles for


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aluminum welding, brazing, glassblowing, and operations using sodium fluxes. See your supervisor for the proper protection

Removal of Acid Goggles (Splash goggles): If acid goggles are sprayed with acid or caustic, you must get under a shower as soon as possible. If necessary to remove the goggles to be able to see the way to the shower, special care must be taken to keep acid or caustic out of the eyes. The following procedure must be followed:

a) Bend over until looking directly at the ground. b) Pull goggles down and away from the face by

stretching the headbands and then slipping them over the top of the head.

c) Place a hand across the forehead and then straighten up and proceed to the shower. Goggles should not be removed before getting under the shower unless your vision is obstructed by the splashed material.

Face Shield: A face shield worn over safety spectacles not only

provides eye protection similar to goggles but also offers frontal and side protection of face and neck from splashing and flying fragments.

Respiratory System: Becht Engineering employees typically are not

required to use respiratory equipment, but in emergencies, or when feasible engineering or administrative controls are not effective in controlling toxic substances, appropriate respiratory protective equipment shall be provided by Becht and the client‘s respiratory program will be adopted. If the client‘s program is non-existent or inadequate employees shall use Becht‘s Respiratory Program.


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4 TRAINING

PPE Training is conducted at the division level. Each employee who is required to use PPE will be trained in the following: Why PPE is necessary When PPE is necessary What PPE is necessary and any alternative choices of equipment How to properly don, doff, adjust, and wear PPE The proper care, maintenance, storage, useful life, and disposal of

PPE The training will include an opportunity for employees to handle the

PPE and demonstrate that they understand the training and have the ability to use the PPE properly. The training will be provided by the manager or supervisor of the affected employees. The training will be documented in writing with the documentation including the names of each employee trained, the date(s) of the training, and the subject matter covered.

If an employee who has been trained demonstrates a lack of knowledge or behavior which leads the supervisor to believe the employee does not have a proper understanding of the PPE involved, that employee will be retrained. If there are changes in the workplace or processes that change the exposures or type of PPE to be used, all affected employees will be retrained.

5 REFERENCES

OSHA CFR 29 1926 Subpart E—Personal Protective and Life Saving Equipment

OSHA CFR 29 1910 Subpart I—Personal Protective Equipment

6 APPENDICES

None

PROCESS SAFETY MANAGEMENT

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1 PURPOSE AND SCOPE

Purpose

This procedure provides mandatory guidelines to protect the safety and health of all employees on Becht assignments where the potential exposure to highly hazardous chemicals exists and where the release of such chemicals would result in toxic, fire, or explosion hazards

Scope

This procedure applies to all Becht employees who provide services to facilities, which involve the following processes:

A chemical at or above the specified threshold quantities as listed in (29 CFR 1926.64 App A) (Note: The presence of a threshold quantity of a highly hazardous chemical in a process is to be at one point in time, not aggregate over a period of time.)

A process that involves a flammable liquid or gas on site, in one location, in a quantity of 10,000 lb (4535.9 kg) or more, except for:

Hydrocarbon fuels that are used solely for work place consumption as a fuel (e.g., propane used for comfort heating or gasoline for vehicle refueling), if such fuels are not a part of a process containing another highly hazardous chemical covered by this procedure.

Flammable liquids that are stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit of chilling or refrigeration.

This procedure does not apply to retail facilities, oil and gas well drilling or servicing operations, or normally unoccupied remote facilities.

2 GENERAL

Unexpected release of toxic, reactive, or flammable liquids and gases in processes that involve highly hazardous chemicals, which may be toxic, reactive, flammable, explosive, or may exhibit a combination of these properties. Regardless of the industry that uses these highly hazardous chemicals, there is a potential for an accidental release when they are not properly controlled. This, in turn, creates the possibility of disaster.

On February 24, 1992, the Occupational Safety and Health Administration (OSHA) published the Process Safety Management of Highly Hazardous Chemicals Standard. This law became fully effective on may 26, 1992. The


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purpose of this regulation is to establish procedures for process safety management that will protect employees by preventing or minimizing the consequences of chemical accidents that involve highly hazardous chemicals.

The original thrust of the regulation was aimed at chemical manufacturing. However, the scope was expanded beyond chemical manufacturing because potentially hazardous chemical releases are not limited to chemical manufacturing and similar precautions should be implemented in operations in which hazardous chemicals are used, mixed, stored, or otherwise handled.

Definitions

Atmospheric Tank: - A storage tank, which has been designed to operate at, pressures from atmospheric through 0.5 psig. (pounds per square inch gauge, 3.45 Kpa).

Boiling Point: - The boiling point of a liquid at a pressure of 14.7 psi (pounds per square inch absolute, 760 mm).

Catastrophic Release: - A major uncontrolled emission, fire, or explosion, involving one or more highly hazardous chemical that presents serious danger to employees in the work place.

Facility: - The buildings, containers, or equipment that contain a process.

Highly Hazardous Chemical: - substances that possesses toxic, reactive, flammable, or explosive properties and is present in quantities specified in the scope.

Hot Work: - Work involving electric or gas welding, cutting, brazing, or similar flame or spark-producing operations.

Flammable Gas: - A gas that, at ambient temperature and pressure, forms a flammable mixture with air at a concentration of 13 percent by volume or less; or a gas that, at ambient temperature and pressure, forms a range of flammable mixtures with air wider than 12 percent by volume, regardless of the lower limit.

Flammable Liquid: - Any liquid having a flash point below 100°F (37.8°C); except any mixture having components with a flash point of 100°F (37.8°C) or higher, the total of which make up 99 percent or more of the total volume of the mixture.

Normally Unoccupied Remote Facility: - A facility which is operated, maintained, or serviced by employees who visit the facility only periodically to check its operation and to perform necessary operating or maintenance tasks. No employees are permanently stationed at the facility. Facilities meeting this definition are not contiguous with, and must be geographically remote from, all other buildings, processes, or persons.


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Process: - Any activity involving a highly hazardous chemical, including any use, storage, manufacturing, handling, or onsite movement of such chemicals or a combination of these activities. For the purpose of this definition, any group of vessels which are interconnected and separate vessels which are located such that a highly hazardous chemical could be involved in a potential release shall be considered a single process.

Responsibilities

The Becht Division Safety Officers

Responsible for implementing and enforcing this procedure.

The Becht Company Safety Manager or designee

Responsible for monitoring compliance with this procedure.

3 PROCEDURE

The OSHA Process Safety Management standard clarifies the responsibilities of facility owners/operators and contractors involved in work that affects or takes place near covered processes to ensure that the safety of both plant and contractor employees is considered. The standard also mandates written operating procedures; employee training; pre-startup reviews; evaluation of mechanical integrity of critical equipment; and written procedures for managing change. Process Safety Management specifies a permit system for hot work; investigation of incidents involving releases or near misses of covered chemicals; emergency action plans; compliance audits at least every three years; and trade secret protection.

The key provision of Process Safety Management is process hazard analysis—a careful review of what could go wrong and what safeguards must be implemented to prevent releases of hazardous chemicals.

Process Safety Information

Facility owners/operators shall complete a compilation of written process safety information before conducting any process hazard analysis required by the OSHA standard. The compilation of written process safety information, completed under the same schedule required for process hazard analysis, will enable the facility owner/operator and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals.


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The process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.

Information on the hazards of the highly hazardous chemicals in the process shall consist of at least the following:

Toxicity

Permissible exposure limits

Physical data

Reactivity data

Corrosivity data

Thermal and chemical stability data and hazardous effects of inadvertent mixing of different materials

Information on the technology of the process shall include at least the

following:

A block flow diagram or simplified process flow diagram

Process chemistry

Maximum intended inventory

Safe upper and lower limits for such items as temperatures, pressures, flows, or compositions

An evaluation of the consequences of deviations including those affecting the safety and health of employees.

Where the original technical information no longer exists such information may be developed in conjunction with the process hazard analysis in sufficient detail to support the analysis.

Information on the equipment in the process shall include the following:

Materials of construction

Piping and instrument diagrams (P&IDs)

Electrical classification

Relief system design and design basis

Ventilation system design

Design codes and standards employed

Material and energy balances for processes built after May 26, 1992

Safety systems (e.g., interlocks, detection or suppression systems)


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The facility owner/operator shall document that equipment complies with recognized and generally accepted good engineering practices. For existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, the employer shall determine and document that the equipment is designed, maintained, inspected, tested, and operated in a safe manner.

Process Hazard Analysis

The facility owner/operator shall perform an initial process hazard analysis (hazard evaluation) on processes covered by the OSHA standard. The process hazard analysis methodology selected must be appropriate to the complexity of the process and must identify, evaluate, and control the hazards involved in the process.

The facility owner/operator shall determine and document the priority order for conducting process hazard analysis based on a rationale that includes such considerations as the extent of the process hazards, the number of potentially affected employees, the age of the process, and the operating history of the process.

The process hazard analysis shall be conducted as soon as possible, but not later than the following schedule:

No less than 25 percent of the initial process hazards analyses shall be completed by May 26, 1994.

No less than 50 percent of the initial process hazard analyses shall be completed by May 26, 1995.


All initial process hazards analyses shall be completed by May 26, 1997.

Process hazards analyses completed after May 26, 1987, which meet the requirements of the OSHA process safety management standard, are acceptable as initial process hazards analyses. All process hazards analyses shall be updated and revalidated based on their completion date, at least every 5 years.


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The facility owner/operator shall use one or more of the following methodologies that are appropriate to determine and evaluate the hazards of the process being analyzed:

What-If

Checklist

What-If/Checklist

Hazard and Operability Study (HAZOP)

Failure Mode and Effects Analysis (FMEA)

Fault Tree Analysis

An Appropriate Equivalent Methodology

The process hazard analysis shall address the following:

The hazards of the process.

The identification of any previous incident that had a potential for catastrophic consequences in the work place.

Engineering and administrative controls applicable to the hazards and their interrelationships, such as appropriate application of detection methodologies to provide early warning of releases. Acceptable detection methods might include process monitoring and control instrumentation with alarms and detection hardware such as hydrocarbon sensors.

Consequences of failure of engineering and administrative controls.

Facility siting.

Human factors.

A qualitative evaluation of a range of the possible safety and health effects on employees in the work place if there is a failure of controls.

The process hazard analysis shall be performed by a team with

expertise in engineering and process operations, and the team shall include at least one employee who has experience and knowledge in the specific process hazard analysis methodology being used.

The facility owner/operator shall establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance, and other employees whose work assignments


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are in the process and who may be affected by the recommendations or actions.

At least every 5 years after the completion of the initial process hazard analysis, the process hazard analysis shall be updated and revalidated by a team meeting the OSHA standard's requirements to ensure that the hazard analysis is consistent with the current process.

Facility owners/operators shall keep on file and make available to OSHA, on request, process hazard analyses and updates or revalidation for each process covered by the process safety management, as well as the documented resolution of recommendations, for the life of the process.

Operating Procedures

The facility owner/operator shall develop and implement written operating procedures, consistent with the process safety information, that provide clear instructions for safely conducting activities involved in each covered process. The operating procedures must address at least the following elements:

Steps for each operating phase:

a) Initial startup b) Normal operations c) Temporary operations d) Emergency shutdown, including the conditions under

which emergency shutdowns are required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner

e) Emergency operations f) Normal shutdown g) Startup following a turnaround or after an emergency

shutdown

Operating limits:

a) Consequences of deviation b) Steps required to correct or avoid deviation

Safety and health considerations:

a) Properties of, and hazards presented by, the chemicals used in the process

b) Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment


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c) Control measures to be taken if physical contact or airborne exposure occurs

d) Quality control for raw materials and control of hazardous chemical inventory levels

e) Safety systems (e.g., interlocks, detection or suppression systems) and their functions

Operating procedures shall be readily accessible to employees who

work in or maintain a process.

The operating procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The facility owner/operator shall certify annually that these operating procedures are current and accurate.

The facility owner/operator shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. The safe work practices shall apply to facility employees and contractors' employees.

Contractors

Application

This procedure applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process.

This procedure does not apply to contractors providing incidental services which do not influence process safety, such as janitorial work, food and drink services, laundry, delivery, or other supply services.

Facility Owner/Operator Responsibilities

The facility owner/operator, when selecting a contractor, shall obtain and evaluate information regarding the contractor's safety performance and programs.

The facility owner/operator shall inform contractors of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process.


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The facility owner/operator shall explain to contractors the applicable provisions of the emergency action plan required by this procedure.

The facility owner/operator shall develop and implement safe work practices to control the entrance, presence, and exit of contractors and contractors' employees in covered process areas.

The facility owner/operator shall periodically evaluate the performance of contractors in fulfilling their obligations and responsibilities.

The facility owner/operator shall maintain a contractor employee injury and illness log related to the contractor's work in process areas.

Contractor Responsibility

Becht shall assure that each employee is trained in the work practices necessary to safely perform his/her job.

Becht shall assure that each employee is instructed in the known potential fire, explosion, or toxic release hazards related to his/her job and the process, and the applicable provision of the facility's emergency action plan.

Becht shall document that each employee has received and understood the required training. Becht must prepare a record which contains the identity of each employee, the date of training, and the means used to verify that the employee understood the training.

Becht shall assure that each employee follows the safety rules of the facility, including the safe work practices.

Becht shall advise the facility owner/operator of any unique hazards presented by Becht‘s work or of any hazards found by Becht employees.


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Pre-Startup Safety Reviews

The facility owner/operator shall perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information.

Prior to the introduction of a highly hazardous chemical to a process, the pre-startup safety review must confirm the following:

Construction and equipment are in accordance with design specifications.

Safety, operating, maintenance, and emergency procedures are in place and are adequate.

A process hazard analysis has been performed for new facilities and recommendations have been resolve or implemented before startup, and modified facilities meet the management of change requirements.

Training of each employee involved in operating a process has been completed.

Mechanical Integrity

The process safety management mechanical integrity requirements apply to the following equipment:

Pressure vessels and storage tanks

Piping systems (including piping components such as valves)

Relief and vent systems and devices

Emergency shutdown systems

Controls (including monitoring devices, sensors, alarms, and interlocks)

Pumps

The facility owner/operator shall establish and implement written procedures to maintain the ongoing integrity of process equipment.

The facility owner/operator must train each employee involved in maintaining the ongoing integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee's job task to assure that the employee can perform the job tasks in a safe manner.


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Inspection and testing shall be performed on process equipment, using procedures that follow recognized and generally accepted good engineering practices. The frequency of inspections and tests of process equipment shall conform with manufacturers' recommendations and good engineering practices, or more frequently if determined to be necessary by prior operating experience. Each inspection and test on process equipment shall be documented, identifying the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.

The facility owner/operator shall correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information) before further use or in a safe and timely manner when necessary means are taken to assure safe operation.

In constructing new plants and equipment, the facility owner/operator shall ensure that equipment, as it is fabricated, is suitable for the process application for which it will be used. Appropriate checks and inspections must be performed to ensure that equipment is installed properly and is consistent with design specifications and the manufacturer's instructions.

The facility owner/operator shall also ensure that maintenance materials, spare parts, and equipment are suitable for the process application for which they will be used.

Hot Work Permits

The facility owner/operator must issue a hot work permit for hot work operations conducted on or near a covered process.

The permit shall document that the fire prevention and protection requirements in 29 CFR 1910.252 (a) have been implemented prior to beginning the hot work operations; it shall indicate the date(s) authorized for hot work; and it shall identify the object on which hot work is to be performed. The permit shall be kept on file until completion of the hot work.


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Management of Change

The facility owner/operator shall develop and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures and change to facilities that affect a covered process. The written procedures must ensure that the following considerations are addressed prior to any change:

The technical basis for the proposed change

Impact of the change on employee safety and health

Modification to operating procedures

Necessary time period for the change

Authorization requirements for the proposed change

Facility employees involved in operating a process and maintenance and contractors' employees whose job task will be affected by a change in the process shall be informed of, and trained in, the change prior to startup of the process or affected part of the process.

If a change occurs that affects the process safety information and/or the operating procedures, such information shall be updated accordingly.

Incident Investigation

The facility owner/operator shall investigate each incident which results in, or could reasonably have resulted in, a catastrophic release of highly hazardous chemical in the work place.

The incident investigation shall be initiated as promptly as possible, but not later than 48 hours following an incident.

An incident investigation team shall be established and consist of at least one person knowledgeable in the process involved, including a contractor's employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident.

A report shall be prepared at the conclusion of the investigation which includes, at a minimum:

Date of incident

Date investigation began


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Description of the incident

Factors that contributed to the incident

Recommendations resulting from the investigation

The facility owner/operator shall establish a system to promptly address and resolve the incident report findings and recommendations. Resolutions and corrective actions shall be documented.

The report shall be reviewed with all affected personnel whose job tasks are relevant to the incident findings, including contractors' employees where applicable.

Incident investigation reports shall be retained for five years.

Emergency Planning and Response

The facility owner/operator shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38 (a). In addition, the emergency action plan must include procedures for handling small releases. Facility owner/operators covered under process safety management may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR 1910.120 (a), (p) and (q).

Compliance Audits

To be certain process safety management is effective, facility owners/operators shall certify that they have evaluated compliance with the provisions of the OSHA standard at least every 3 years. This will verify that the procedures and practices developed are adequate and are being followed.

The compliance audit shall be conducted by at least one person knowledgeable in the process.

A report of the findings of the audit shall be developed and documented, noting deficiencies that have been corrected.

The two most recent compliance audit reports must be kept on file.


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205

Trade Secrets

Facility owners/operators shall make available all information necessary to comply with process safety management to those responsible for compiling the process safety information, those developing the process hazard analysis, those responsible for developing the operating procedures, and those performing incident investigations, emergency planning and response, and compliance audits, without regard to the possible trade secret status of such information.

Nothing in the OSHA standard, however, precludes the facility owner/operator from requiring those persons to enter into confidentiality agreements not to disclose the information.

Subject to the rules and procedures set forth in 29 CFR 1910.1200(i)(1) through 1910.1200(I)(12), employees and their designated representatives shall have access to trade secret information contained within the process hazard analysis and other documents required to be developed by process safety management.

4 TRAINING

Initial Training

Each facility employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures as specified in Section 5.3 of this procedure. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job task.

In lieu of initial training for those facility employees already involved in operating a process on May 26, 1992, the facility owner/operator may certify, in writing, that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as specified in the operating procedures.


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Refresher Training

Refresher training shall be provided at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process.

The facility owner/operator, in consultation with the employees involved in operating the process, shall determine the appropriate frequency of refresher training.

Training Documentation

The facility owner/operator shall ascertain that each employee involved in operating a process has received and understood the training required by the OSHA standard.

The facility owner/operator shall prepare a record which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.

5 REFERENCES


OSHA Instruction CPL 2-2.45A, September 28, 1992, Process Safety Management of Highly Hazardous Chemicals, Compliance Guidelines and Enforcement Procedures.

6 APPENDICES

None

ELECTRICAL PRACTICES

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1 PURPOSE AND SCOPE

Purpose

To provide the guidelines for personnel who work on or around electrical systems. To prevent employee injury, illness or death from exposure to electrical energy hazards. To establish appropriate practices for work on or near electrical systems and equipment that uses electrical energy. To provide procedural controls that assures the effective use of safety-related practices.

Scope

This procedure applies to all Becht personnel and subcontractors working on projects where electrical safety requirements are applicable.

2 GENERAL

The specific safety-related work practices used must be consistent with the nature and extent of the associated electrical hazards.

Definitions

Accessible: (as applied to equipment) Admitting close approach; not guarded by locked doors, elevation, or other effective means. [OSHA]

Approved: Acceptable to the authorities enforcing this subpart. [OSHA]

Tested and accepted for a specific purpose by a nationally recognized agency. [UL],[MSHA]

Approved for the purpose: Approved for a specific purpose, environment, or application described in a particular standard requirement. [OSHA]

Authorized Person: A person approved or assigned by management to perform a specific type of duty or duties or to be at a specific location or locations. [MSHA]

Barricaded: Obstructed to prevent the passage of persons, vehicles, or flying

materials. [MSHA]

Conductor – bare: A conductor having no covering or electrical insulation whatsoever. [OSHA]


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Conductor – covered: A conductor encased within material that is not recognized as electrical insulation. [OSHA]

Conductor – insulated: Conductor encased within material that is recognized as electrical insulation. [OSHA]

Dead Front: Without live parts exposed to a person on the operating side of the equipment. [OSHA]

Enclosed: Surrounded by a case, fence, or walls, which will prevent persons from accidentally contacting energized parts. [OSHA]

Exposed - as applied to live parts: Capable of being inadvertently touched or approached nearer than a safe distance by a person. It is applied to parts not suitably guarded, isolated, or insulated. [OSHA]

Externally operable: Capable of being operated without exposing the operator to contact with live parts. [OSHA]

Guarded: Covered, shielded, fenced, enclosed, or otherwise protected by means of suitable covers or casings, barriers, rails, screens, mats, or platforms to remove the likelihood of approach to a point of danger or contact by persons or objects. [OSHA]

Qualified Person: One who is trained in and familiar with the construction, operation and safety hazards of the equipment upon which they are permitted to work.

Qualified persons are intended to be only those who are well acquainted with and thoroughly conversant in the electric equipment and electrical hazards involved with work being performed.

Only qualified persons may be permitted to work on or near exposed energized parts. Such persons are required to have been trained in three specific areas: [1910.332(3)(i);(ii);(iii)]

Qualified persons shall be capable of working safely on energized circuits and must be familiar with the proper use of special precautionary techniques, personal protective equipment, insulating and shielding materials, and insulated tools. [1910.333(c)(2)]

Qualified persons are expected to be able to evaluate unknown situations and adjust their activities in such a way that only safe work


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practices are used. Such behavior is the responsibility of the qualified person.

It is possible and likely for an individual to be ‗qualified‘ with regard to certain equipment in the work place, and unqualified as to other equipment.

An employee who is undergoing on-the-job training, who, in the course of such training, has demonstrated an ability to perform duties safely at his or her level of training, and who is under the direct supervision of a qualified person is considered to be a qualified person for the performance of those duties. [OSHA]

Resident Expert: A person who is on site and has detailed knowledge of the procedures and the hardware.

Unqualified Person:

One who is not trained in and familiar with the operation and safety hazards associated with electrical systems and equipment. Unqualified persons must be trained in those practices, which are necessary for their safety. Unqualified persons will not be permitted to enter spaces that are required to be accessible to qualified employees only, unless the electric conductors and equipment involved are in an electrically safe work location.

Responsibilities

Non-applicable

3 PROCEDURE

Work Practices

Safety-related work practices must be employed to prevent electric shock or other injuries resulting from either direct or indirect electrical contacts when work is performed near or on equipment or circuits which are or may be energized. [OSHA 29 CFR 1910.333] Becht Engineering will advise the host company/client of the following, when present: Any unique hazards presented; Any unanticipated hazards found during the course of work that the

client did not point out; The measures Becht employees took to correct any hazards reported

by client to prevent such hazards occurring in the future.


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Use of Equipment Safe practices relating to portable electric equipment, electric power and lighting circuits, test instruments and equipment, flammable or ignitable materials must be used. [OSHA 29 CFR 1910.334]

Personal Protection

Employees working in areas where there are potential electrical hazards must be provided with, and use, electrical protective equipment that is appropriate for the specific parts of the body to be protected and for the work to be performed. [OSHA 29 CFR 1910.335]

Electrical Installations / Construction Sites Light bulbs for general illumination must be protected from breakage,

and metal shell sockets must be grounded. [1926.405(a)(2)(ii)(E)]

Temporary lights must not be suspended by their cords, unless they are so designed. [1926.405(a)(2)(ii)(F)]

Portable lighting used in wet or conductive locations, such as tanks or boilers, must be operated at no more than 12 volts or must be protected by GFCI‘s. [1926.405(a)(2)(ii)(G)]

Extension cords must be of the three-wire type. Extension cords and flexible cords used with temporary and portable lights must be designed for hard or extra hard usage (for example, types S, ST and SO). [1926.405(a)(2)(ii)(j)

Worn or frayed electric cords or cables shall not be used. [1926.416(e)(1)]

Extension cords shall not be fastened with staples, hung from nails, or suspended by wire. [1926.416(3)(2)]

Working On or Near Exposed De-energized Parts This applies to the following: Work being performed on exposed, de-energized parts; Or, work being performed close enough to de-energized parts to present potential exposure to electrical hazards. [1910.333(b)] The following is required:


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Live parts above 50 volts to ground and to which an employee may be exposed must be de-energized before the employee works on them, unless de-energizing introduces additional or increased hazards, or de-energization is infeasible due to equipment design or operational limitations.

Conductors and parts of electric equipment that have been de-energized but have not been properly locked and tagged out must be treated as energized parts.

Before any circuits or equipment can be considered and worked as de-energized, a qualified person, as defined in this procedure, must make suitable tests to verify de-energized.

―Lockout / Tagout Procedure‖ must be used to provide procedural controls for personnel working on or around equipment with hazardous electric energy. Becht will follow the site LOTO procedure:

Implementation of any ―tag without lock‖ must be authorized by the

Client‘s Supervisor or Manager. Note: If a lock cannot be applied, a tag may be used without a lock. A

tag used without a lock must be supplemented by at least one additional safety measure that provides a level of safety equivalent to that obtained by the use of a lock. An example of additional safety measure is the removal of an isolating circuit element. [1910.333(b)(iii)(D)]

Only qualified persons may lockout / tagout hazardous electrical energy.

Verification of de-energization is mandatory. A qualified person must do this verification.

Before re-energization, a qualified person must conduct tests and visual inspections, as necessary, to verify that all tools, electrical jumpers, shorts, grounds, and other such devices have been removed so that the circuits and equipment can be safely energized.

Working On or Near Exposed Energized Parts This applies to work performed on exposed live parts or near enough to them for employees to be exposed to any hazard they present. [1910.333(c)]. The following is required:

A Job Hazard Analysis (JHA) should be completed prior to the start of

work. The JHA should contain event severity, frequency, probability and avoidance to determine the level of safe practices employed.


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Only qualified persons, as defined in this procedure, are to be allowed to work on electric circuit parts or equipment that have not been de-energized. [1910.333(c)(2)]

For work on live parts that are not de-energized, suitable safe work practices for the conditions under which the work is to be performed must be provided in written procedures via a work permit and strictly enforced.

A job briefing shall be held prior to the start of work and should include all employees. The briefing should cover hazards associated with the job, work procedures involved, special precautions, energy source controls and PPE requirements.

If work is to be performed near overhead lines, the lines must be de-energized and grounded, or other protective measures must be provided before work is started. Protective measures used must prevent employees from contacting the lines directly with their body parts or indirectly through conductive tools and equipment. [1010.333(c)(3)]. The following is required:

When an unqualified person is working in an elevated position near overhead lines, the location must be such that the person and the longest conductive object being used is incapable of coming closer to any unguarded energized overhead line than the following distances:

a) Less than 50kV = 10 Feet b) More than 50kV = 10 Feet plus 4 Inches for every

10kV over 50kV

When an unqualified person is working on the ground in the vicinity of overhead lines, the person must not bring any conductive object closer to unguarded, energized overhead lines than the distances given in the preceding paragraph. [1910.333(c)(i)(B)]

When a qualified person is working in the vicinity of overhead lines, whether in an elevated position or on the ground, the person must not approach or take any conductive object without an approved insulating handle closer to exposed energized parts than approach distances shown below in Table S-5 unless:

a) The person is insulated from the energized part, or


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b) The energized part is insulated from all other conductive objects at a different potential and from the person, or

c) The person is insulated from all conductive objects at a potential different from that of the energized part. [1910.333(c)(3)(ii)]

Table 5-S APPROACH DISTANCES FOR QUALIFIED EMPLOYEES

Voltage Range (AC phase-to phase voltage)

Minimum Approach Distance

300 V and less

Avoid contact

Over 330 V, not over 750 V

1 ft. 0 in. (30.5 cm)

Over 750 V, not over 2 kV

1 ft. 6 in. (46 cm)

Over 2 kV, not over 15 kV

2 ft. 0 in. (61 cm)


3 ft. 0 in. (91 cm)

Over 37 kV, not over 87.5 kV

3 ft. 6 in. (107 cm)

Over 87.5 kV, not over 121 kV

4 ft. 0 in. (122 cm)


4 ft. 6 in. (137 cm)

Any vehicle or mechanical equipment capable of having parts of its structure elevated near energized overhead lines must be operated so that a clearance of 10 ft. is maintained. If the voltage is higher than 50 kV, the clearance must be increased 4 in. for every 10 kV over that voltage. [1910.333(c)(3)(iii)]

If the vehicle is in transit with its structure lowered, the clearance may

be reduced to 4 ft. If the voltage is higher than 50 kV, the clearance must be increased 4 in. for every 10 kV over that voltage.

If proper insulating barriers are installed, clearance may be reduced to

a distance within the designed working dimensions of the insulating barrier.


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If the equipment is an aerial lift insulated for the voltage involved, and if the work is performed by a qualified person, the clearance may be reduced to the distance given in Table S-5. The following is required:

Employees standing on the ground may not contact the vehicle or equipment unless protective equipment rated for the voltage is used, or Table S-5 approach distances are not violated.

If the vehicle or equipment capable of having parts elevated near energized overhead lines is intentionally grounded, employees working on the ground near the point of grounding may not stand at the grounding location whenever there is a possibility of overhead line contact.

Employees must not enter spaces containing exposed energized parts

unless illumination is provided that enables the employees to perform the work safely. [1910.333(c)(4)]

When an employee works in a confined or enclosed space (such as a

manhole or vault) that contains exposed energized parts, the employee must use protective shields, protective barriers, or insulating materials as necessary to avoid inadvertent contact with these parts. [1910.333(c)(5)] Confined Space Entry Procedure must be used in conjunction with this procedure.

Conductive materials and equipment that are in contact with any part

of an employee‘s body must be handled in a manner that will prevent them from contacting exposed energized conductors or circuit parts. [1910.333(c)(6)]

Portable ladders must have nonconductive side rails if they are used

where the employee or the ladder could contact exposed energized parts. [1910.333(c)(7)]

Conductive articles of jewelry and clothing must not be worn if they

might contact exposed energized parts. However, such articles may be worn if they are rendered nonconductive by covering, wrapping, or other insulating means. [1910.333(c)(8)]

Where live parts present an electrical contact hazard, employees must

not perform housekeeping duties at such close distances to the parts that there is a possibility of contact, unless adequate safeguards are provided. Electrical conductive cleaning materials must not be used in proximity to energized parts unless procedures are followed which will prevent electrical contact. [1910.333(c)(9)]


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Only a qualified person, following proper requirements, should defeat

an electrical safety interlock, and then only temporarily while working on the equipment. The interlock system must be returned to its operable condition when this work is completed. [1910.333(c)(10)]

Use of Portable Electric Equipment

This applies to the use of cord- and plug-connected equipment, including flexible cord sets (extension cords). [1910.334(a)] The following is required:

Handling of portable electric equipment must be done in a manner that

will not cause damage to the equipment. Visual inspection of portable electric equipment must be made, before

use, for external defects and for evidence of possible internal damage.

A flexible cord used with grounding type equipment must contain an equipment-grounding conductor.

A GFCI shall be used on all outside work or in any area that has

potential for shock (e.g., a wet area).

Portable electric equipment used in highly conductive work locations, or in job locations where employees are likely to contact water or conductive liquids, must be approved for those locations.

If energized equipment is involved, employees‘ hands must not be wet

when plugging or unplugging flexible cords.

Use of Electric Power and Lighting Circuits

[1910.334(b)] The following is required:

Only approved equipment must be used for routine opening and closing of circuits.

After a circuit is de-energized by a circuit protective device, the circuit

must not be manually reenergized until it has been determined that the equipment and circuit can be safety energized.

Over-current protection of circuits and conductors must not be

modified, even on a temporary basis, beyond that allowed by Design Safety Procedure and the associated standards.


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Use of Testing Instruments and Equipment

[1910.334(c)] The following is required:

Only qualified persons should perform testing work on electric circuits or equipment.

Test instruments and equipment must be visually inspected before the

equipment is used.

Test instruments and equipment must be rated for the circuits and equipment to which they will be connected and must be designed for the environment in which they will be used.

Test instruments, equipment and their accessories shall meet the

requirements of ANSI/ISA-61010-Safety Requirements for Electrical Equipment for Measurement, Control and Laboratory Use- Part 1 General Requirements, for rating and design requirements for voltage measurement and test instruments intended for use on electrical systems 1000 Volts and below.

When test instruments are used for testing for the absence of voltage

on conductors or circuit parts operating at 50 volts or more, the operation of the test instrument shall be verified before and after an absence of voltage test is performed.

Occasional Use of Flammable or Ignitable Material

[1910.334(d)] The following applies:

Electrical installation requirements for locations where flammable

materials are present on a regular basis are covered by 29 CFR 1910.307.

Where flammable materials are present only occasionally, electric

equipment capable of igniting them must not be used, unless measures are taken to prevent hazardous conditions from developing.

Use of Personal Protective Equipment

[1910.335(a)] Personal Protective Procedure must be used in conjunction with this procedure. The following is also required:

Employees working in areas where there are potential electrical

hazards must use electrical protective equipment that is appropriate for


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the specific parts of the body to be protected and for the work to be performed.

Protective equipment must be maintained in a safe, reliable condition

and must be inspected or tested prior to each day‘s use. All insulating PPE must be inspected immediately following any incident that can reasonably be suspected of having caused damage.

Insulating gloves shall be given an air test, along with daily inspection. Care must be taken to protect insulating material if subject to damage.

Only non-conductive (type A or B) hard hats should be worn. Eye / face protection must be worn wherever there is a danger of injury from electric arcs or flashes or from flying objects resulting from an electrical explosion.

General Protective Equipment When working near exposed energized conductors or circuit parts,

each employee must use insulated tools or handling equipment if the tools or handling equipment might make contact with such conductors or parts.

Fuse handling equipment, insulated for the circuit voltage, must be

used to remove or install fuses when the fuse terminals are energized. Ropes and hand lines used near energized parts must be non-conductive.

Protective shields, protective barriers, or insulating materials must be

used to protect each employee from shock, burns, or other electrically related injuries. When normally enclosed live parts are exposed for maintenance or repair, they must be guarded to protect unqualified persons from contact with the live parts.

Rubber insulating personal protective equipment shall have maximum

testing intervals, detailed accordingly:

Blankets: before first issue and every 12 months thereafter;

Gloves: before first issue and every 6 months thereafter;

Sleeves: before first issue and every 12 months thereafter;

Covers and Line hose shall be tested if insulating value is suspect.


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Alerting Techniques [1910.335(b)]

Safety signs, safety symbols, or accident prevention tags must be used

where necessary to warn employees about electrical hazards which may endanger them.

Barricades must be used in conjunction with safety signs where it is

necessary to prevent or limit employee access to work areas exposing employees to uninsulated energized conductors or circuit parts.

If signs and barricades do not provide sufficient warning and protection

from electrical hazards, an attendant must be stationed to warn and protect employees.

4 TRAINING

Training in electrical systems work safety procedures must include the following:

The hazards and safeguards associated with electrical systems.

New employee orientation level training should address inherent

electrical hazards associated with the facility / site.

Employees must be trained in and familiar with the safety-related work practices required by this procedure that pertain to their respective job assignments. [OSHA 1910.332(b)]

The training required by this procedure must be of the classroom or on

the-job type. The degree of training provided must be determined by the risk to the employee. [OSHA 1910.332(c)]

Written training plans must be prepared and used for the training

required by this procedure. Such training plans should be written to convey a record of training and:

Specific electrical hazards and potential injury faced by the employee being trained must be addressed in the plan.

Provision for retraining and verification of retraining must be included in the training plan.

Verification of training must be accomplished by testing or practical demonstration.


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All employees must have initial and periodic refresher training on the above. In addition, each supervisor must review any significant incidents involving electrical hazards or work practices in safety meetings.

Documentation of all electrical systems work safety procedures

training is required. The following information should be included:

The date of the training.

Names of the participants and the instructor.

Summary of the subject matter presented.

Method of training and training aids used.

Method used to evaluate participant‘s understanding.

Level One Training

Employee whose work is not dangerously close to exposed parts of electric circuits and who does not face a higher than normal risk of electrical accident (Executives, Office, Construction Managers, Advisors, and Clerical Personnel) is responsible for:

Being aware of and familiar with this procedure and completing Level One electrical training.

Level One Electrical Training: (OSHA does not require training for employees if their work or the work of those they supervise does not bring them or the employees they supervise close enough to exposed parts of electric circuits, operating at 50 volts or more to ground, for a hazard to exist) [OSHA 1910.332 Table S-4] The employee who faces no higher than normal risk of electrical accident must receive training for:

Knowing the correct responses to signs such as Danger, Warning, Caution, Authorized Personnel Only, High Voltage, etc.

Avoiding contact with exposed electrical circuits that have a potential of more than 50 volts to ground.

Knowing that areas containing major electrical installations may be entered only by authorized personnel.

Level Two Training

The Employee who is unqualified for work on electrical systems, but who is in an occupational category that faces a higher than normal risk of electrical accident is responsible for:


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Level One Electrical Training

Knowing their role and limitations under the facility / site Lockout / Tagout Procedure.

Being aware of and familiar with this procedure and completing Level Two electrical training.

Being aware of typical occupational categories of employees facing a higher than normal risk of electrical accident.

Knowing the safeguards built into electrical equipment and having the skills to recognize when an electrical hazard exists.

Knowing the procedures for response to emergencies.

Level Three Training

The Employee who is qualified to work on non-energized equipment and faces a higher than normal risk of electrical shock accident, not reduced to a safe level by compliance with applicable installation requirements, is responsible for:

Levels One and Two Electrical Training

Knowing their role and limitations under the facility / site Lockout / Tagout Procedure.

Being aware of and familiar with this procedure and completing Level Three electrical training. The safety-related work practices required by 29 CFR 1910.331 through 1910.335.

Completing training for avoidance of specific higher than normal risks related to particular work areas, and knowing hazard avoidance practices.

Knowing his/her own work qualifications and limitations.

Conferring with supervision regarding hazards associated with the job assignment.

Advising supervision of any questionable situations relating to procedure, changed worksite conditions, etc.

Following the general and specific requirements of this procedure that are applicable to the work.

Level Four Training

The Employee who is a ―qualified person‖, as defined, and who performs work on or near exposed energized parts (electricians, instrument technicians, electronics technicians, etc.) is responsible for:

Levels One, Two and Three Electrical Training


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Implementing the Site Lockout / Tagout procedure where appropriate.

Being aware of and familiar with this procedure and completing Level Four electrical training.

Being trained and familiar with the following: a) ―The skills and techniques necessary to distinguish

exposed live parts from other parts of electric equipment...‖ [OSHA 1910.332(b)(3)(i)]

b) ―The skills and techniques necessary to determine the nominal voltage of exposed live parts...‖ [OSHA 1910.332(b)(3)(ii)]

c) ―Clearance distances specified in 1910.333(c) and the corresponding voltages to which the qualified person will be exposed.‖ [OSHA 1910.332(b)(3)(iii)]

d) (See ―Approach Distances for Qualified Employees - Alternating Current‖)

e) Working safely on energized circuits and being familiar with the proper use of special precautionary techniques, personal protective equipment, insulating and shielding materials, and insulated tools. [OSHA 1910.333(c)(2)]

5 REFERENCES

Code of Federal Regulations, Title 29, Part 1926, Occupational Safety and Health Administration (OSHA), U.S. Department of Labor.

The applicable requirements of the following OSHA regulations, ANSI standards and NFPA codes are to be complied with as a part of this policy:

Occupational Safety and Health Administration (OSHA) 29 CFR:

1926.416 - Electrical Safety Related Work Practices

Part 1910, Subpart J - General Environmental Controls

1910.147 - The Control of Hazardous Energy (Lockout / Tagout)

Part 1910, Subpart S – Electrical

1910.302 - Design Safety Standards for Electrical Systems

1910.331 - Safety-related Work Practices

1910.361 - Safety-related Maintenance Requirements (Future)

ANSI C2 - National Electric Safety Code NFPA 70 - National Electric Code


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NFPA 70C - Hazardous Locations Classification

NFPA 70E - Standard for the Electrical Safety Requirements for Employee

Workplaces 3.6 MSHA 30 CFR Part 56, Subpart U – Electricity

6 APPENDICES

None

RESPIRATORY PROTECTION

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207

1 PURPOSE AND SCOPE

Purpose

This procedure outlines the requirements for appropriate selection and use of respiratory protection equipment in emergencies or when it is not feasible to implement engineering controls to adequately prevent harmful exposure to employees who are working in areas that require respiratory protection.

Scope

This procedure applies to all Becht employees and subcontractors working on field projects or in offices where respiratory protection is required.

2 GENERAL

In the control of those occupational diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors, the primary objective shall be to prevent atmospheric contamination. This shall be accomplished as far as feasible by accepted engineering control measures (for example, enclosure or confinement of the operation, general or local ventilation, and substitution of less toxic materials). When effective engineering controls are not feasible, or while they are being instituted, appropriate respirators shall be used pursuant to this procedure.

Respirators shall be provided when such equipment is necessary to protect the health of the employee. Respirators, which are applicable and suitable for the purpose intended, shall be provided. Becht shall be responsible for the establishment and maintenance of a respiratory protection program that includes the requirements of this procedure.

Each field site and office facility shall ensure that employees are provided a safe and healthful working atmosphere, free of hazards that could adversely affect their personal health and safety.

It is the policy of Becht to use the most up-to-date and efficient respiratory protective equipment available and the most effective work methods to eliminate or minimize atmospheric hazards. The latter shall be accomplished by accepted engineering control measures. When effective engineering controls are not feasible, appropriate respirators shall be used according to this procedure.


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207

Definitions

Air Purifying Respirator (APR): A respirator with an air-purifying filter, cartridge, or canister that removes specific air contaminants by passing ambient air through the air-purifying element.

Atmosphere Supplying Respirator: A respirator which provides a clean breathable atmosphere that is independent of the surrounding environment. They are designed for use in uncharacterized environments or where contaminant concentrations are too high for APRs. This classification includes supplied-air respirators (SARs) and self-contained breathing apparatus (SCBA) units. Canister or Cartridge: A container with a filter, sorbent, or catalyst, or combination of these items, which removes specific contaminants from the air, passed through the container. Demand Respirator: An atmosphere-supplying respirator that admits breathing air to the face piece only when a negative pressure is created inside the face piece by inhalation. Emergency Situation: Any occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment that may, or does result in an uncontrolled release of an airborne contaminant. Employee Exposure: Exposure to a concentration of an airborne contaminant that would occur if the employee were not using respiratory protection. End-of-Service-Life-Indicator (ESLI): A system that warns the respirator user of the approach to the end of adequate protection. The sorbent is approaching saturation, or is no longer effective. Escape-only Respirator: A respirator intended to be used only for emergency exit. Filter of Air Purifying Element: A component used in respirators to remove solid or liquid aerosols from the inspired air.


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Filtering Face piece (Dust Mask): A negative pressure particulate respirator with a filter as an integral part of the face piece or with the entire face piece composed of the filtering medium. Fit Factor: A quantitative estimate of the fit of a particular respirator to a specific individual, and typically estimates the ratio of the concentration of a substance in ambient air to its concentration inside the respirator when worn. Fit-Test: The use of a protocol to qualitatively or quantitatively evaluate the fit of a respirator on an individual. High Efficiency Particulate Air Filter (HEPA): A filter that is at least 99.97% efficient in removing monodisperse particles of 0.3 micrometers in diameter. Helmet: A rigid respirator inlet covering that also provides head protection against impact and penetration. Hood: A respiratory inlet covering that completely covers the head and neck and may also cover portions of the shoulders and torso. Immediately dangerous to life and health (IDLH): An atmosphere that poses an immediate threat to life, would cause irreversible adverse health effects, or would impair an individual's ability to escape from a dangerous atmosphere. Loose-Fitting Face piece: A respiratory inlet covering that is designed to form a partial seal with the face. Negative Pressure Respirator (tight fitting): A respirator in which the air pressure inside the face piece is negative during inhalation with respect to the ambient air pressure outside the respirator. Oxygen Deficient Atmosphere: Atmosphere with an oxygen content is below 19.5 % by volume.


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Physician or Licensed Health Care Professional (PLHCP): An individual whose legally permitted scope of practice (i.e. license, registration, or certification) allows him/her to independently provide, or be delegated the responsibility to provide, some or all of the health care services required in this procedure. Positive Pressure Respirator: A respirator in which the pressure inside the respiratory inlet covering exceeds the ambient air pressure outside the respirator. Powered Air-Purifying Respirator (PAPR): An air-purifying respirator that uses a blower to force the ambient air through air-purifying elements to the inlet covering. Pressure Demand Respirator: A positive pressure atmosphere-supplying respirator that admits breathing air to the face piece when the positive pressure is reduced inside the face piece by inhalation. Qualitative Fit Test (QLFT): A pass/fail test to assess the adequacy of respirator fit that relies on the individual‘s response to the test agent. Quantitative Fit Test (QNFT): An assessment of the adequacy of respirator fit by numerically measuring the amount of leakage into the respirator. Respiratory Inlet Covering: That portion of a respirator that forms the protective barrier between the user‘s respiratory tract and an air-purifying device or breathing air source, or both. It may be a face piece, helmet, hood, suit, or a mouthpiece respirator with nose clamp. Self-Contained Breathing Apparatus: An atmosphere-supplying respirator for which the breathing air source is designed to be carried by the user. Service Life: The period of time for which a respirator, filter or sorbent, or other respiratory equipment provide adequate protection to the wearer.


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Supplied-air Respirator (SAR) or Airline Respirator: An atmosphere-supplying respirator for which the source of breathing air is not designed to be carried by the user. Tight-Fitting Face piece: A respiratory inlet covering that forms a complete seal with the face. User Seal Check: An action conducted by the respirator user to determine if the respirator is properly seated to the face.

Responsibilities

Manager/Supervisor Responsible for implementing and enforcing this procedure and the

site respiratory protection program. Safety Representative Responsible for monitoring compliance with this procedure. The

Safety Representative shall act as the Respiratory Protection Program Administrator and must be knowledgeable of the complexity of the program, conduct evaluations, and be properly trained.

Employee (whose tasks require the use of respiratory equipment) Responsible to use the appropriate type of respiratory equipment. The

Subcontractor is responsible for providing Becht a written respiratory protection program which, at a minimum, shall meet the requirements of the Becht program. The subcontractor shall also provide evidence of current respiratory training, medical evaluation, and qualitative or quantitative fit testing for those employees required to use respiratory equipment

3 PROCEDURE

Respiratory Protection Program

In any workplace where respirators are necessary to protect the health of the employee, the clients written respiratory protection program shall be adopted. The following element shall be included in the written program:

Procedures for selecting respirators for use in the workplace.

Medical evaluations of employees required to use respirators.

Fit testing procedures for tight-fitting respirators.


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Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations.

Procedures and schedules for cleaning, disinfecting, storing, inspection, repairing, discarding, and otherwise maintaining respirators.

Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators.

Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations.

Training of employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance.

Procedures for regularly evaluating the effectiveness of the program.

The voluntary use of respiratory equipment where not required is prohibited without written authorization from Becht‘s Company Safety Manager.

The use of employee owned respirators is prohibited.

The use of dust mask is prohibited without written authorization from Becht‘s Company Safety Manager.

Becht shall designate a program administrator, at both the corporate and site level, who is qualified by appropriate training or experience to oversee the respiratory protection program and conduct the required evaluations of program effectiveness.

All required training and medical evaluation shall be provided at no cost to the employee.

Selection of Respirators

Selection of appropriate respirators shall be based on the respiratory hazard(s) to which the employee is exposed and workplace and user factors that affect respirator performance and reliability.

A NIOSH-certified respirator must be selected. The respirator shall be used in compliance with the conditions of its certification.

Respirators shall be selected from a sufficient number of respirator models and sizes so that the respirator is acceptable to and correctly fits the user.

Respirator hazard(s) in the work area shall be identified and evaluated. This evaluation shall include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant‘s chemical state and physical form. Where the employee


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exposure cannot be identified or reasonably estimated, the atmosphere shall be considered IDLH.

The following respirators shall be provided for employee use in IDLH atmospheres:

certified by NIOSH for a minimum service life of thirty minutes, or

a combination full face piece pressure demand supplied-air respirator (SAR) with auxiliary self-contained air supply.

Respirators provided only for escape from IDLH atmospheres shall be NIOSH-certified for escape from the atmosphere in which they will be used.

All oxygen-deficient atmospheres shall be considered IDLH.

For atmospheres that are not IDLH, a respirator shall be provided that is adequate to protect the health of the employee and ensure compliance with all other statutory and regulatory requirements, under routine and reasonably foreseeable emergency situations.

The respirator selected shall be appropriate for the chemical state and physical form of the contaminant.

For protection against gases and vapors,

An atmosphere-supplying respirator, or

An air-purifying respirator shall be provided.

a) If an air-purifying respirators is used it should be equipped with an end-of-service-life indicator (ESLI) certified by NIOSH for the contaminant.

b) If there is no ESLI appropriate for conditions in the workplace, a change schedule for canisters and cartridges shall be implemented that is based on objective information or data that will ensure that canisters and cartridges are changed before the end of their service life. The workplace respirator program shall describe the information and data relied upon and the basis for the canister and cartridge change schedule and the basis for reliance on the data.

For protection against particulates, the following shall be provided:

An atmosphere-supplying respirator; or

An air-purifying respirator equipped with a filter certified by NIOSH as a high efficiency particulate air (HEPA) filter, or an


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air-purifying respirator equipped with a filter certified for particulates by NIOSH; or

For contaminants consisting primarily of particles with mass median aerodynamic diameters (MMAD) of at least 2 micrometers, an air-purifying respirator equipped with any filter certified for particulates by NIOSH.

Medical Evaluation

Medical evaluations associated with the use of respiratory protection equipment shall be coordinate and/or performed by Becht‘s Company Safety Manager. The need for such medical evaluations must be coordinated through Becht‘s Company Safety Manager.

A medical evaluation, to determine the employee‘s ability to use a respirator before the employee is fit tested or required to use the respirator in the workplace, shall be provided at no cost.

A physician or other licensed health care professional (PLHCP) shall be identified to perform medical evaluations using a medical questionnaire or an initial medical examination that obtains the same information as the medical questionnaire. SEE 29 CFR 1910.134 Appendix 3

The medical questionnaire and evaluation shall be administered confidentially during the employee‘s normal working hours or at a time and place convenient to the employee. The medical questionnaire shall be administered in a manner that ensures the employee understands the content.

The employee shall be given the opportunity to discuss the medical questionnaire and evaluation results with the PLHCP.

The following information must be provided to the PLHCP before the PLHCP makes a recommendation concerning an employee‘s ability to use a respirator:

The type and weight of the respirator to be used by the employee;

The duration and frequency of respirator use (including use for rescue and escape);

The expected physical work effort;

Additional protective clothing and equipment to be worn; and

Temperature and humidity extremes that may be encountered.

A copy of the workplace written respiratory program and a copy of the respiratory standard shall be provided to the PLHCP.


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A written recommendation regarding the employee‘s ability to use the respirator shall be obtained from the PLHCP. The recommendation shall provide only the following information:

Any limitations on respirator use related to the medical condition of the employee, or relating to the workplace conditions in which the respirator will be used, including whether or not the employee is medically able to use he respirator;

The need, if any, for follow-up medical evaluations; and

A statement that the PLHCP has provided the employee with a copy of the PLHCP‘s written recommendation.

If the respirator is a negative pressure respirator and the PLHCP finds a medical condition that may place the employee‘s health at increased risk if the respirator is used, a PAPR shall be provided if the PLHCP‘s medical evaluation finds that the employee can use such a respirator. If a subsequent medical evaluation finds the employee is medically able to use a negative pressure respirator, then there is no longer a requirement d to provide a PAPR.

Additional medical evaluations shall be provided whenever there is any indication that a reevaluation is appropriate. At a minimum, this would occur:

If an employee reports any signs or symptoms that are related to the ability to use a respirator;

If the PLHCP, program administrator, or supervisor determines that a reevaluation is necessary;

If information from the respiratory protection program indicates a need for reevaluation; or

If a change in workplace conditions could affect the physiological burden placed on the employee.


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Fit Testing

Before an employee is required to use any respirator with a negative or positive pressure tight-fitting face piece, the employee must be fit tested with the same make, model, style and size of respirator that will be used.

If an employee is allowed to voluntarily use a respirator, it is Becht‘s policy that a fit test shall be conducted.

All employees who are required to use a tight-fitting respirator must pass an appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT).

QLFT may only be used to fit test negative pressure air-purifying respirators that must achieve a fit factor of 100 or less.

QLFT involves the introduction of a gas, vapor, or aerosol test agent into an area around the health of the respirator user. If the respirator user can detect the presence of the test agent through subjective means, such as odor, taste, or irritation, the respirator fit is inadequate.

In a QNFT, the adequacy of respirator fit is assessed by measuring the amount of leakage into the respirator, either by generating a test aerosol as test atmosphere, using ambient aerosol as the test agent, or using controlled negative pressure to measure the volumetric leak rate. Appropriate instrumentation is required to quantify respirator fit in QNFT.

Appropriate fit tests shall be performed as follows:

Prior to initial use of the respirator;

Whenever a different respirator face piece (size, style, model or make) is used;

Whenever an employee reports physical condition changes that could affect respirator fit;

Whenever the employee is observed to have undergone physical changes that could affect respirator fit; and

At least annually.

RESPIRATOR USE

Procedures for the proper use of respirators shall be established and implemented. Such procedures must include:

Prohibiting conditions that may result in face piece seal leakage;

Actions to ensure continued effective respirator operation;


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Preventing employees from removing respirators in hazardous environments; and

Use of respirators in IDLH atmospheres.

Respirators with tight-fitting face pieces shall not be worn by employees who have:

Facial hair that comes between the sealing surface of the face piece and the face, or that interferes with value function; or

Any condition that interferes with the face-to-face piece seal or with value function.

If an employee wears corrective glasses or goggles or other personal protective, it must be ensured that the equipment is worn in a manner that does not interfere with the seal of the face piece to the face of the user.

A user seal check must be performed each time an employee puts on a tight-fitting respirator.

Appropriate awareness of workplace conditions and degree of employee exposure or stress must be maintained. When there is a change in work conditions or degree of employee exposure or stress that may affect respirator effectiveness, a reevaluation of the respirator‘s continued effectiveness must be performed.

If an employee detects vapor or gas breakthrough, changes in breathing resistance, or leakage of the face piece, the respirator that is not functioning properly must be replaced, repaired, or discarded before the employee can return to the work area.

Employees must leave the respirator use area under the following conditions:

To wash their faces and respirator face pieces as necessary to prevent eye or skin irritation, and to reduce the amount of contamination;

If they detect vapor or gas breakthrough, changes in breathing resistance, or leakage of the face piece; or

To replace the respirator or the filter, cartridge, or canister elements.

When employees are working in IDLH atmospheres, you must ensure:

Employee(s) located outside the IDLH atmosphere is trained and equipped to provide effective emergency rescue;


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One employee or, when needed, more than one employee is located outside the IDLH atmosphere;

Visual, voice, or signal line communication is maintained between the employee(s) in the IDLH atmosphere and the employee(s) located outside the IDLH atmosphere;

Employee(s) located outside the IDLH atmosphere make appropriate notification prior to entering the IDLH atmosphere to provide emergency rescue;

Authorized personnel provide assistance necessary to an emergency situation; and

Employee(s) located outside the IDLH atmospheres are equipped with pressure demand or other positive pressure SCBAs or a pressure demand or other positive pressure supplied-air respirator with auxiliary SCBA. Also required is either appropriate retrieval equipment for removing the employee(s) who enters these hazardous atmospheres where retrieval equipment would contribute to the rescue and would not increase the overall risk resulting from entry or equivalent means for rescue where retrieval equipment is not required.

Respirator Maintenance and Care

Each respirator wearer must be provided with a respirator that is clean, sanitary, and in good working order.

Respirators are required to be provided in a clean and sanitary manner using procedures in OSHA 1910.134 Appendix 2 or equally effective manufacturer's procedures.

Respirators issued for the exclusive use of an employee shall be cleaned and disinfected as often as necessary to be maintained in a sanitary condition.

Respirators issued to more than one employee shall be cleaned and disinfected after each use.

Respirators maintained for emergency use shall be cleaned and disinfected after each use.

Respirators used in fit testing and training shall be cleaned and disinfected after each use.

All respirators must be stored so they are protected from damage, contamination, harmful environmental conditions and damaging chemicals, and deformation of the face piece and exhalation valve.


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In addition to the above storage requirements, emergency use respirators must be:

Kept accessible to the work area;

Stored in compartments or covers that are clearly marked as containing emergency respirators; and

Stored in accordance with any applicable manufacturer‘s instructions.

Regular inspections to ensure the continued reliability of respiratory equipment must be made. The frequency of inspection and procedures to be followed depend on whether the respirator is intended for non-emergency, emergency, or escape-only use.

Respirators for use in non-emergency situations must be inspected before each use and during cleaning.

Respirators designated for use in emergency situations must be inspected at least monthly and in accordance with the manufacturer‘s instructions. In addition, emergency respirators must be examined to ensure that they are working properly before and after each use. The inspection must be certified including the date of inspection, the name or signature of the inspector, the findings of the inspection, any required remedial action, and a serial number of other means of identifying the inspected respirator. This information must be tagged to the respirator or its storage compartment, or otherwise stored in the form of inspection reports and be maintained until replaced following a subsequent certification.

Emergency escape-only respirators shall be inspected before being carried into the workplace for use.

The inspection will include a check of the respirator function, tightness of connections, and the condition of the various parts including but not limited to, the face piece, head straps, valves, connecting tube, and cartridges, canister or filters; and a check of the elasto-meric parts for pliability and signs of deterioration.

SCBAs must be inspected monthly. Cylinders shall be maintained in a fully charged state and shall be recharged when the pressure falls below 90% of the manufacturer‘s recommended pressure level.

Respirators that fail inspection, or are otherwise defective, are to be removed from service and discarded, repaired, or adjusted according to the following specified procedures:

Repairs or adjustments to respirators are to be made only by persons appropriately trained to perform such operations and


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shall use only the respirator manufacturer‘s NIOSH-approved parts designed for the respirator;

Repairs shall be made according to the manufacturer‘s recommendations and specifications for the type and extent of repairs to e performed; and

Reducing and admission valves, regulators, and alarms shall be adjusted or repaired only by the manufacturer or a technician trained by the manufacturer.

Breathing air, quality and use

Breathing air for atmosphere-supplying respirators must be of high purity, meet quality levels for content, and not exceed certain contaminant levels and moisture requirements. Current regulations set performance standards for the operation and maintenance of breathing air compressors and cylinders, establishes methods for ensuring breathing air quality, and sets requirements for the quality of purchased breathing air.

Air must be Grade D or better. Oxygen is not used in compressed air units, cylinders shall meet DOT requirements, and Compressors shall be located in a "clean" atmosphere, with in-line purification and tagged to indicate date or change out. Carbon monoxide monitor shall be in place & set to alarm at 10 PPM or monitored frequently. Fittings are incompatible for non-respirable gases and containers.

Breathing air must be of Grade D and requires certification from supplier.

Identification of Filters, Cartridges, and Canisters

All filters, cartridges, and canisters used in the workplace shall be labeled and color-coded with the NIOSH approval label. The label must remain legible and affixed to the cartridge, filter, or canister while in service.


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4 TRAINING

Respirator Training

Effective training must be provided to all employees who are required to wear respirators. Employees must be trained sufficiently to:

Show a knowledge of why the respirator is necessary;

How improper fit, usage, or maintenance can compromise the protective effect of the respirator;

Know the limitations and capabilities of the selected respirator;

Deal with emergency situations involving the use of respirators or with respirator malfunction;

Inspect, don, remove, and check the respirator seal;

Understand procedures for respirator maintenance and storage;

Know the medical symptoms and signs that may limit or prevent the effective use of respirators; and

Understand the general requirements of the regulatory requirements.

Training must be understandable and be given to an employee prior to using a respirator, and annually thereafter. Additionally, if there is reason to believe that any employee who has already been trained does not have sufficient understanding and skill to use the respirator, the employee must be retrained in those areas in which his or her knowledge or skill is deficient. Retraining is also required when changes in the workplace or in the type of respirator used render previous training obsolete.

Program Evaluation

An evaluation of the workplace shall be conducted, as necessary, to ensure that the provisions of the current written respiratory program are being effectively implemented and that it continues to be effective.

Employees, required to use respirators, shall be consulted regularly to assess their views on program effectiveness and to identify any problems that need correcting. Factors to be assessed include, but are not limited to:


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Respirator fit;

Appropriate respirator selection for the hazards to which the employee is exposed;

Proper respirator use under the workplace conditions the employee encounters; and

Proper respirator maintenance.

Recordkeeping

Written information regarding medical evaluations, fit testing, and respirator program must be established and retained by Becht Engineering‘s Safety Coordinator in the tested employee‘s hardcopy safety file.

Records of medical evaluations required by this section will be retained and made available in accordance with 29 CFR 1910.1020.

A record of the qualitative and quantitative fit tests administered to an employee shall be established and maintained. The record shall include:

The name or identification of the employee tested;

Type of fit test performed;

Specific make, model, style, and size of respirator tested;

Date of test; and

The pass/fail results for QLFT or the fit factor and strip chart recording or other recording of the test results for QNFTs.

Fit test records shall be retained for respirator users until the next fit test is administered.

A written copy of the current respirator program shall be retained at the workplace.


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5 REFERENCES


American National Standards Institute (ANSI) Z88.2-1992, Practices for Respiratory Protection.

American National Standards Institute (ANSI), Z88.6-1984, Physical Qualifi-cations for Respirator Use.

American Conference of Governmental Industrial Hygienists, Threshold Limit Values and Biological Exposure Indices, Current Edition.

Compressed Gas Association, Commodity Specification G-7.1-1973.

Department of Health and Human Services, NIOSH Guide to Industrial Respiratory Protection, Publication Number 87-116.

6 APPENDICES

Appendix 1 - Respiratory Equipment Selection Chart

APPENDIX 1 - RESPIRATORY EQUIPMENT SELECTION CHART

HAZARD ANALYSIS/RESPIRATORY EQUIPMENT SELECTION CHART

Hazard Respirator (see note) 1. Oxygen deficiency Self-contained breathing apparatus. Hose

mask with blower. Combination air-line respirator with auxiliary self-contained air supply or an air-storage receiver with alarm.

2.A Gas and vapor contaminants immediately dangerous to life and health

Self-contained breathing apparatus. Hose mask with blower. Self-rescue mouthpiece respirator (for escape only). Combination air-line respirator with auxiliary self-contained air supply or an air-storage


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receiver with alarm.

2.B Not immediately dangerous to life and health

Air-line respirator. Air-purifying, half-mask or mouthpiece respirator with chemical cartridge.

3.A Particulate contaminants immediately dangerous to life and health

Self-contained breathing apparatus. Hose mask with blower. Self-rescue mouthpiece respirator (for escape only). Combination air-liner respirator with auxiliary self-contained air supply or an air-storage receiver with alarm.


Air-purifying, half-mask or mouthpiece respirator with filter pad or cartridge. Air-liner respirator with auxiliary self-contained air supply or an air-storage receiver with alarm.

4.A Combination gas, vapor, and particulate contaminants immediately dangerous to life and health

Self-contained breathing apparatus. Hose mask with blower. Self-rescue mouthpiece respirator (for escape only). Combination air-line respirator with auxiliary self-contained air supply or an air-storage receiver with alarm.


Air-line respirator. Air-purifying, half-mask or mouthpiece respirator with chemical cartridge and appropriate filter.

Note: For the purpose of this chart, ―immediately dangerous to life and health‖ is defined as a condition that poses either an immediate threat to life and health or an immediate threat of severe exposure to contaminants, such as radioactive materials and asbestos, which are likely to have an adverse delayed effect on health.

INJURY AND ILLNESS PREVENTION PROGRAM

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1 PURPOSE AND SCOPE

Purpose

To provide Becht Engineering Company‘s Injury and Illness Prevention Program (IIP).

Scope

The Injury and Illness Prevention Program applies to all employees.

2 GENERAL

Definitions

None

Responsibilities

The Injury and Illness Prevention (IIP) Program Administrator

Becht Engineering Safety Director has the authority and the responsibility for implementing and maintaining this IIP Program for Becht Engineering Co., Inc.

Managers and Supervisors

Responsible for implementing and maintaining the IIP Program in their work areas and for answering worker questions about the IIP Program. A copy of this IIP Program is available from each manager and supervisor.

3 PROCEDURE

Compliance

All workers, including managers and supervisors, are responsible for complying with safe and healthful work practices. Our system of ensuring that all workers comply with these practices includes one or more of the following practices:

Informing workers of the provisions of our IIP Program. Evaluating the safety performance of all workers. Recognizing employees who perform safe and healthful work

practices. Providing training to workers whose safety performance is deficient. Disciplining workers for failure to comply with safe and healthful

work practices. If an employee is issued a safety violation, that


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employee‘s immediate supervisor will meet with employee(s) to discuss the infraction and inform individual(s) of the rule or procedure that was violated and the corrective action to be taken.

Physical inspections by company officials that indicate violations showing overall lack of commitment to company safety goals shall be under the same level of disciplinary actions.

Communication

All managers and supervisors are responsible for communicating with all workers about occupational safety and health in a form readily understandable by all workers. Our communication system encourages all workers to inform their managers and supervisors about workplace hazards without fear of reprisal.

Our communication system includes one or more of the following items:

New worker orientation including a discussion of safety and health policies and procedures.

Review of our IIP Program. Training programs. Posted or distributed safety information.

Hazard Assessment

Periodic inspections to identify and evaluate workplace hazards shall be performed by a competent observer in the following areas of our workplace:

Periodic inspections are performed according to the following schedule:

When we initially established our IIP Program; When new substances, processes, procedures or equipment which

present potential new hazards are introduced into our workplace; When new, previously unidentified hazards are recognized; When occupational injuries and illnesses occur; and Whenever workplace conditions warrant an inspection.

Accident/ Exposure Investigation

Procedures for investigating workplace accidents and hazardous substance exposures include:

Interviewing injured workers and witnesses; Examining the workplace for factors associated with the

accident/exposure; Determining the cause of the accident/exposure;


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Taking corrective action to prevent the accident/exposure from reoccurring; and

Recording the findings and actions taken.

Hazard Correction

Unsafe or unhealthy work conditions, practices or procedures shall be corrected in a timely manner based on the severity of the hazards. Hazards shall be corrected according to the following procedures:

When observed or discovered; and When an imminent hazard exists which cannot be immediately

abated without endangering employee(s) and/or property, we will remove all exposed workers from the area except those necessary to correct the existing condition. Workers who are required to correct the hazardous condition shall be provided with the necessary protection.

Recordkeeping

CATEGORY 1

Our establishment has twenty or more workers or has a workers' compensation experience modification rate of greater than 1.1 and is not on a designated low hazard industry list. We have taken the following steps to implement and maintain our IIP Program:

Records of hazard assessment inspections, including the person(s) conducting the inspection, the unsafe conditions and work practices that have been identified and the action taken to correct the identified unsafe conditions and work practices, are recorded on a hazard assessment and correction form; and

Documentation of safety and health training for each worker, including the worker's name or other identifier, training dates, type(s) of training, and training providers are recorded on a worker training and instruction form.

Inspection records and training documentation will be maintained according to the following schedule:


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For one year, except for training records of employees who have worked for less than one year which are provided to the employee upon termination of employment.

4 TRAINING

All workers, including managers and supervisors, shall have training and instruction on general and job-specific safety and health practices. Training and instruction is provided:

When the IIP Program is first established; To all new workers, except for construction workers who are

provided training through a construction industry occupational safety and health training program approved by Cal/OSHA;

To all workers given new job assignments for which training has not previously provided;

Whenever new substances, processes, procedures or equipment are introduced to the workplace and represent a new hazard;

Whenever the employer is made aware of a new or previously unrecognized hazard;

To supervisors to familiarize them with the safety and health hazards to which workers under their immediate direction and control may be exposed; and

To all workers with respect to hazards specific to each employee's job assignment.

General workplace safety and health practices include, but are not limited to, the following:

Implementation and maintenance of the IIP Program. Emergency action and fire prevention plan. Provisions for medical services and first aid including emergency

procedures. Prevention of musculoskeletal disorders, including proper lifting

techniques. Proper housekeeping, such as keeping stairways and aisles clear,

work areas neat and orderly, and promptly cleaning up spills. Prohibiting horseplay, scuffling, or other acts that tend to adversely

influence safety.


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Proper storage to prevent stacking goods in an unstable manner and storing goods against doors, exits, fire extinguishing equipment and electrical panels.

Proper reporting of hazards and accidents to supervisors. Hazard communication, including worker awareness of potential

chemical hazards, and proper labeling of containers. Proper storage and handling of toxic and hazardous substances

including prohibiting eating or storing food and beverages in areas where they can become contaminated.

5 REFERENCE

None

6 APPENDICES

Appendix 1: Hazard Assessment and Correction Form Appendix 2: Accident Expose Investigation Report

Appendix 3: Worker Training and Instruction Form


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HAZARD ASSESSMENT AND CORRECTION RECORD

Date of Inspection: Person Conducting Inspection:

Unsafe Condition or Work Practice:

Corrective Action Taken:







APPENDIX 1 – HAZARD ASSESSMENT AND CORRECTION RECORD


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ACCIDENT/EXPOSURE INVESTIGATION REPORT

Date & Time of Accident:

Location:

Accident Description:

Workers Involved:

Preventive Action Recommendations:

Corrective Actions Taken:

Manager Responsible: Date Completed:

APPENDIX 2 – ACCIDENT/EXPOSURE INVESTIGATION REPORT


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WORKER TRAINING AND INSTRUCTION RECORD

Worker's Name Training

Dates Type of Training Trainers

APPENDIX 3 – WORKER TRAINING AND INSTRUCTION RECORD

ACCESS TO MEDICAL RECORDS

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1 PURPOSE AND SCOPE

Purpose

This procedure provides the guidelines for the control, storage, and availability of employee health exposure and medical records involving employees exposed to known toxic substances or harmful physical agents.

Scope

This procedure applies to all Becht personnel and subcontractors working on projects where requirements for medical records are applicable.

2 GENERAL

Current regulations require the release of occupational exposure and medical data to employees, their designated representatives, health professionals, and OSHA upon request. The access rule itself does not require employers to create medical records or conduct toxic substance exposure monitoring. It does mandate retention of exposure monitoring records for 30 years and personal medical records for employment plus 30 years.

Definitions

Toxic Substance: A substance that demonstrates the potential to induce cancer, to produce short- and long-term disease or bodily injury, to affect health adversely, to produce acute discomfort, or to endanger life of man or animal resulting from exposure via the respiratory tract, skin, eye, mouth, or other routes in quantities which are reasonable for experimental animals or which have been reported to have produced toxic effects in man. Chemical Substance: The organic or inorganic substances of a particular molecular identity listed in 29CFR1910, Subpart Z, by OSHA and the latest printed edition of the NIOSH Registry of Toxic Effects of Chemical Substances (RTECS). Medical Records: The documents associated with personal physical and mental conditions resulting from exposure to toxic substances. Health Exposure Records: The documents which log the sampling levels and monitoring levels of possible health hazards.


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Responsibilities

The Division Manager Responsible for monitoring compliance, implementing and enforcing

this procedure. The Company Safety Manager Responsible for maintaining and securing the final storage of medical

and health exposure records. These records shall be kept for 30 years and personal medical records for employment plus 30 years.

3 PROCEDURE

Medical records include the documents that are relative to employee medical examinations, health hazard exposures involving toxic substances and harmful physical agents, and the protective measures instituted. Medical and health exposure records generated on the jobsite shall be available to employees, designated representatives, health personnel, and OSHA.

Becht medical and health exposure records shall be maintained in the

Becht medical files in the custody of the Company Safety Manager. Employees shall be informed where their records are kept. This shall be

accomplished at the New Employee Safety Training. Employee record requests shall be in writing (see sample request in

Appendix 1), except in an emergency. Designated representatives and health professionals shall need specific written consent to gain access to employees' personal medical records, but may examine exposure records without consent. However, they must state the specific record needed and the occupational health need for requesting the information. Health professionals include physicians, occupational health nurses, industrial hygienists, toxicologists, and epidemiologists who provide medical or other occupational health services to exposed employees. OSHA may obtain personal medical records promptly without the written consent of the subject employees, but will adhere to strict data controls to protect confidentiality.


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One copy of an employee's medical and health exposure record shall be made available to the employee with the Company Safety Manager‘s approval within 15 days of the request and with the written concurrence of the Division Safety Manager.

When an employee is granted a copy of the medical record, a Becht

representative shall make a copy for the employee and return the original to the file.

Persons requesting records not within the scope of this procedure shall be

refused such records and may be referred to the Company Safety Manager.

Personal medical records for short-term employees (less than 1 year)

shall not be retained if they are provided to the employee upon termination.

First aid records and experimental toxicological research records are

excluded from the 30- year retention requirements.

4 TRAINING

Employee information Upon an employee‘s first entering into employment, and at least annually thereafter, Becht Engineering shall inform current employees covered by this section of the following: The existence, location, and availability of any records covered by this

section; The person responsible for maintaining and providing access to

records; Each employee‘s rights of access to these records.

Becht Engineering shall keep a copy of this section and its appendices, and make copies readily available, upon request, to employees. Becht Engineering shall also distribute to current employees any informational materials concerning this section which are made available to the Becht Engineering by the Assistant Secretary of Labor for Occupational Safety and Health.

5 REFERENCE

None


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6 APPENDICES

Appendix 1- Sample Letter

SAMPLE LETTER

I, , (full name of worker/patient) hereby authorize (individual or organization holding the medical records) to release to (individual or organization authorized toreceive the medical information), the following medical information from my personal medical records: ______________________________________________________________ ______________________________________________________________

(Describe generally the information desired to be released).

I give my permission for this medical information to be used for the following purpose: ______________________________________________________________ ______________________________________________________________ However, I do not give permission for any other use or re-disclosure of this information: ______________________________________________________________ ______________________________________________________________ ______________________________________________________________ ____________________________________________________________________________________________________________________________ Full name of Employee or Legal Representative ______________________________________________________________ Signature of Employee or Legal Representative ______________________________________________________________

Date of Signature ______________

HAZARD COMMUNICATION

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1 PURPOSE AND SCOPE

Purpose

This procedure provides the guidelines to protect the safety and health of all Becht Engineering employees through the identification, communication, dissemination of material safety data sheet information, container labeling, and employee training in the safe use of toxic or hazardous substances used on projects.

Scope

This procedure applies to all Becht personnel and subcontractors working on projects where the requirements of a Hazard Communication Program are applicable.

2 GENERAL

Every workplace contains some substances which could pose potential health problems to employees if exposed to them in concentrations or in a manner not prescribed. A hazardous substance is defined as any substance that is a physical hazard or a health hazard, i.e. compressed gases, explosives, flammables, oxidizers, carcinogens, toxins, irritants, or corrosives. Hazardous substances generally have a Material Safety Data Sheet (MSDS) provided by the manufacturer.

Definitions

None

Responsibilities

Non-applicable

3 PROCEDURE

This Program is established to:

ensure compliance with the applicable state and federal standard; safeguard the health and safety of employees of Becht Engineering;

and create guidelines to follow for implementation and maintenance of a

hazard communication program.


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The Hazard Communication Program shall be administered by the Company Safety Manager. This program defines the minimum hazard communication program requirements; the separate divisions will be responsible for developing and maintaining their own internal procedures in accordance with these guidelines and policies. This program shall be made available, upon request, to employees, their designated representatives, the Assistant Secretary & the Director in accordance with requirements of 29 CFR 1910.1020(e). Where employees must travel between work places during a work shift (multi job sites), the written program may be kept at a primary job site. If there is no primary, then the program should be sent with employees.

Chemical Inventory and Material Safety Data Sheets Annual updates of the Chemical Information Lists (CIL) (See Appendix 1: Chemical Information Lists (CIL) to Becht Engineering Hazardous Communication Program) will be provided by the Company Safety Manager. Division Mangers will ensure the any chemicals listed on the CIL are properly stored in accordance with the manufactures safety instructions. The Division Managers will also ensure the outside door of any location where chemicals on the CIL are stored is marked appropriately to warn the fire department should there be a fire. Division Managers are to report the locations of any storage of items on the CIL. MSDSs shall be maintained and readily accessible in each work area. MSDSs can be maintained at the primary work site. However, they should be available in case of an emergency. MSDS must be made available, upon request, to employees, their designated representatives, the Assistant Secretary & the Director in accordance with the requirements of 29 CFR 1910.1020(e). Signs and Labels

All existing labels on containers of hazardous substances must remain intact. The labels must be legible and written in English. However, for non-English speaking employees, information may be presented in their language as well. Where labels are not present or are not legible, a Hazardous Material Information System (HMIS) label will be affixed to those containers holding the hazardous substance.

It is the responsibility of the Division Manager to assure that each container of a hazardous substance in the workplace is marked, labeled or tagged with the common/trade name of the substance and the appropriate hazard warnings: Health, flammability, reactivity, and personal protective equipment (NFPA).

Portable containers filled with hazardous chemicals transferred from a labeled storage container must be labeled if the material is not used within the work


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shift of the employee making the transfer; the employee that made the transfer leaves the work area; the container is moved to another work area and is no longer in possession of the employee who filled the container.

Employees that work in the store room areas, where sealed containers of hazardous substances are received for distribution to other departments, must assure that the manufacturer's labels are not defaced or removed. In addition, if a spill or leak occurs in a container of hazardous substance, the employees should leave the area, go to a place of safety, and call the Division Manager or the Company Safety Manager.

In addition to the labeling requirement for containers of hazardous substances, the area where the hazardous substance is used or stored must be properly marked.

Exclusions These regulations do not apply to any substances which are foods, drugs, cosmetics, or tobacco products intended for personal consumption by the employees while in the workplace. Additionally, these regulations do not apply to any consumer products and food stuffs packaged for distribution to (and intended for use by) the general public. Consumer products are packaged and used as a normal consumer would use the product as defined in the Consumer Product Safety Act and Federal Hazardous Substances Act.

Exposure

Exposure means that an employee is subjected to a hazardous chemical in the course of employment through any route of entry (inhalation, ingestion, skin contact or absorption, etc.), and includes potential (e.g. accidental or possible) exposure as referenced by the MSDS. When the employer discovers that an employee has received a potentially hazardous exposure to any substance or agent, the employer must immediately notify the employee and take such steps that may be necessary to provide medical evaluation, monitoring, or treatment. Likewise, an employee that has received a potentially hazardous exposure to a substance or agent must immediately notify his/her immediate supervisor of such exposure.

After the appropriate safety and health precautions have been taken, it is the responsibility of the employee's supervisor to fill out an Employee Exposure Report (EER). EER forms are available from the Company Safety Manager. (See Appendix 2: Employee Exposure Report (EER) to Becht Engineering Hazardous Communication Program).


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The Company Safety Manager will retain the original EER for record keeping purposes and if the incident requires it, the EER will be the base documentation for an investigation.

Employees working in areas where exposure(s) to hazardous substances exist shall be required to perform their jobs in accordance with precautions communicated to them during training and education programs. A supervisor may take the appropriate disciplinary action when an employee does not comply with the precautionary measure this policy indicates.

The Division Manager or designee shall be responsible for providing the following in all departmental areas having contact with hazardous substances:

Chemical name of each hazardous substance. Correct labeling of each hazardous substance. Availability of any MSDS for each hazardous substance present in the

immediate work area. Training and education of employees on work practices, protective

measures, and emergency measures in the work place.

Hazardous Non-Routine Tasks

Periodically, our employees are required to perform hazardous non-routine tasks. When employees are required to perform hazardous non-routine tasks, a special training session is conducted to inform them about the hazardous chemicals to which they might be exposed and the proper precautions to take to reduce or avoid exposure. Employees who perform these non-routine tasks should be notified about the training by their supervisor and are required to attend the training prior to carrying out the tasks.

4 TRAINING

Becht Engineering shall provide employees and new hires at their initial assignment effective information and training on hazardous chemicals in their work area. At a minimum, the training will include the following:

Requirements of the program. Any operations in their work area where hazardous chemicals are

present. Location of written hazard communication program, listing of

hazardous chemicals present and MSDS.


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Methods and observations that may be used to detect the presence or release of hazardous chemicals by use of monitoring devices, visual appearance or odor.

The physical and health hazards of chemicals in the work area. Protection measures to be utilized to prevent exposure, appropriate

work practices, emergency procedures and proper PPE to be used. Details of the hazard communication program, explanation of the

labeling system and the MSDS and how employees can obtain and use the appropriate hazard information.

Division Managers are responsible for conducting follow up training as necessary. Training and education provided to employees and others must be documented with detailed records of training maintained by the division.

5 REFERENCE

Title 29, Code of Federal Regulations (CFR), Parts 1910 and 1926, Occupational Safety and Health Administration (OSHA), U.S. Department of Labor.

6 APPENDICES

Appendix 1: Chemical Information Lists (CIL) to Becht Engineering Hazardous Communication Program

Appendix 2: Employee Exposure Report (EER) to Becht Engineering

Hazardous Communication Program


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APPENDIX 1: CHEMICAL INFORMATION LISTS (CIL) TO BECHT ENGINEERING HAZARDOUS COMMUNICATION PROGRAM

Becht Engineering Chemical Information List Becht Engineering Co., Inc. employees do not work with any chemicals

as of date. If a Becht Engineering employee is exposed to chemicals at a client

site, they should locate the MSDS at the client site for a list of chemicals and their hazards. The site specific training should indicate the location of all applicable MSDS.


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APPENDIX 2: EMPLOYEE EXPOSURE REPORT (EER) TO BECHT ENGINEERING HAZARDOUS COMMUNICATION PROGRAM

Becht Engineering Employee Exposure Report

1. Date:

2. Location:

3. Employees Exposed:

4. Nature of Exposure:

5. Cause of the Exposure:

6. Did the exposure require medial attention? If yes, briefly describe the injury and the procedures taken to obtain medical services.

HEARING CONSERVATION

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EH&S 304

1 PURPOSE AND SCOPE

Purpose

To establish the minimum requirements for hearing conservation and hearing protective equipment at Becht facilities and job sites.

To prevent employee hearing loss resulting from exposure to industrial noise over 85 decibels (dBA) averaged over eight (8) working hours.

To identify areas / equipment that has high noise levels (over 85 decibels).

Scope

This procedure establishes minimum requirements for the use of hearing protective equipment in all working and operating areas. This procedure applies to all Becht employees, Sub-contractors and Vendors / Visitors.

The procedure specifically applies whenever there could reasonably be exposure to occupational noise levels above 85 decibels (dBA) averaged over eight (8) working hours.

2 GENERAL

Definitions

None

Responsibilities

The Division Manager or Designee Responsible for:

Providing hearing protectors to all employees exposed to an eight-hour

time-weighted average of 85 decibels at no cost to the employee. Posting and maintaining warning signs where hearing protection is

required. Conferring with the supervisors/clients to identify noise hazards and

hearing protection required for a specific job / task. o When information indicates that employee exposure may

equal/exceed the eight-hour time-weighted average of 85 decibels, Becht Engineering shall implement a monitoring program to identify employees to be included in the hearing conservation program.


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Monitoring compliance with the use of proper hearing protection. Ensuring special hearing protection is available on site. Minimizing the sources of industrial noise in their areas whenever

practical. This should include the following: Proper maintenance of equipment Selecting machines with lower noise levels Using mufflers, dampers, etc. Using barriers, baffles, enclosures, absorptive materials, etc. Isolation of the operator from the noise, if possible and practical. Other engineering noise reduction controls

The Employee Responsible for:

Complying with this procedure and using the required hearing

protection. Conferring with supervision as to noise hazards involved and hearing

protection requirements associated with the job. Inspecting hearing protection equipment prior to each use and

maintaining it in a good and clean condition. Advising supervision of any suggestions to improve the Hearing

Conservation Program or the use or selection of hearing protective equipment.

Requesting information from supervision about any portion of the Hearing Conservation Program that is not fully understood.

Having hearing protectors in their possession and using them whenever exposed to elevated noise levels, regardless of the cause or duration of the noise.

Following all verbal instructions and obeying signs requiring hearing protection.

3 PROCEDURE

All hearing protection equipment used at Becht must meet the applicable OSHA and ANSI requirements. The Hearing Conservation Program will be covered with new employees in the orientation training. Hearing protection requirements, importance and limitations will be included in at least one safety meeting each year by each Supervisor.


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Visitors to the facility / site (non-employees) who enter the construction or maintenance areas must be furnished hearing protection if it is required. It is the responsibility of their Becht escort to ensure they have and wear the equipment.

CLIENT FACILITY PROGRAMS

Every employee working in an operations or maintenance area is required to have hearing protection with them at all times. Although most personnel are not exposed to noise on a continuous basis, unforeseen events may occur that renders a usually quiet area into an area of damaging noise. At most operating facilities the client will conduct noise level surveys and post areas requiring hearing protectors. Should Becht‘s scope of work dictate initiation of a hearing conservation program, outside of the 1926 construction standard, Becht will in most cases adopt the client‘s program. By adopting the client‘s program, Becht will include and accept the client‘s noise level survey. However, as a rule of thumb, if an employee must elevate his / her normal speaking voice to be heard, he / she is in an area where hearing protection must be worn. The following applies to the uses of hearing protectors:

Client facilities with noise levels above 90 dBA should have signs posted at all entrances, which state “Caution, Hearing Protection Required”.

Areas with noise levels above 105 dBA will be posted as “Danger,

Double Hearing Protection Required”. Employees will be allowed to select their hearing protectors from a variety of styles designed to reduce noise to acceptable levels. Taking their exposure profile into consideration, employees will not be allowed to choose a protector with a noise reduction rating less than what they would need to reduce the noise levels which they are exposed to in their particular job assignment. Employee will be properly fitted with their selected hearing protection. In compliance with company rules, hearing protectors must be worn when working in regulated or obviously noisy areas. Audiometric Testing and Evaluation Program

Annual audiometric testing shall be mandatory for those employees exposed to noise at or above an eight-hour TWA of 85dBA. Testing will be done at no cost to the employee. Testing to establish a baseline audiogram shall be preceeded by at least 14 hours without exposure to workplace noise. Hearing


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protection may be used to meet the requirement. Employees shall also be notified to avoid high levels of noise. Within 6 months of an employee's first exposure at or above the action level, Becht will establish a valid baseline audiogram against which future audiograms can be compared. When a mobile van is used, the baseline shall be established within 1 yr. At least annually after obtaining the baseline audiogram, the employer shall obtain a new audiogram for each employee exposed at or above an 8-hour time-weighted average of 85 decibels. Each employee's annual audiogram shall be compared to that employee's baseline audiogram to determine if the audiogram is valid and if a standard threshold shift has occurred. If a comparison of the annual audiogram to the baseline audiogram indicates a standard threshold shift, the employee shall be informed of this fact in writing, within 21 days of the determination. If a threshold shift has occurred, use of hearing protection shall be re-evaluated and/or refitted and if necessary a medical evaluation may be required. The testing equipment, calibration, record keeping, evaluation, and follow-up shall comply with all requirements listed in OSHA Standard 1910.95.

RECORD KEEPING All records for noise monitoring will be kept by the Company Safety Manager. If required, audiometric tests and other medical records will also be kept by the Company Safety Manager.

MANAGEMENT CONTROLS Documentation of all Hearing Conservation training is required. Facility / Site Supervision / Sub-contractor Coordinators should continue on-the-job instruction to employees on hearing conservation as necessary to ensure proper compliance with these procedures. Auditing to ensure compliance with the Hearing Conservation Procedure should be performed. Periodic audits will be conducted by supervision. All records required by this procedure will be kept in accordance with OSHA requirements. Any non-conformance with this policy will be addressed and corrected by the responsible supervision.

4 TRAINING


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The Hearing Conservation Program will be covered with new employees in the orientation training. The training program shall be repeated annually for each employee included in the hearing conservation program. Information provided in the training program shall be updated to be consistent with changes in protective equipment and work processes. Becht Engineering shall ensure that each employee is informed of the following:

The effects of noise on hearing; The purpose of hearing protectors, the advantages, disadvantages, and attenuation of various types,

and instructions on selection, fitting, use, and care; and The purpose of audiometric testing, and an explanation of the test

procedures.

5 REFERENCE

OSHA Standard 29 CFR 1926.101 Hearing Protection OSHA Standard 29 CFR 1910.95 Occupational Noise Exposure

6 APPENDICES

None

MEDICAL SERVICES AND FIRST AID

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1 PURPOSE AND SCOPE

Purpose

Becht Engineering shall ensure the availability of medical personnel for advice and consultation on matters of occupational health. 1926.50(a) When a medical facility is not reasonably accessible for the treatment of injured employees, a person qualified (by American Red Cross or similar) to render first aid shall be available at the worksite. 1926.50(c)

Scope

Medical Services and First Aid shall be available to all Becht Engineering employees.

2 GENERAL

Definitions

None

Responsibilities

Non-applicable

3 PROCEDURE

First-aid supplies when required will be readily available. 1926.50(d)(1) Each advisor on assignment that is not expected to have a medical facility will be issued a first aid kit to accompany him/her on assignment. The Division Manager/Designee shall check the First Aid Kit before being sent out on each job and the advisor will check the kit at least weekly on each job to ensure that the expended items are replaced. The first aid kit shall consist of a weatherproof container with individual sealed packages for each type of item. The contents of such kit shall contain a sufficient quantity of at least the following types of items:

Gauze roller bandages, 1 inch and 2 inch. Gauze compress bandages, 4 inch. Adhesive bandages, 1 inch. Triangular bandage, 40 inch. Ammonia inhalants and ampules. Antiseptic applicators or swabs. Burn dressing. Eye dressing.


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Wire or thin board splints. Forceps and tourniquet.

Proper equipment for prompt transportation of the injured person to a physician or hospital, or a communication system for contacting necessary ambulance service, shall be provided. In areas where 911 is not available, the telephone numbers of the physicians, hospitals, or ambulances shall be conspicuously posted. Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.

4 TRAINING

Non-applicable

5 REFERENCE

None

6 APPENDICES

None

HEAT STRESS PREVENTION

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1 PURPOSE AND SCOPE

Purpose

This procedure provides the guidelines for the protection of individuals who work in hot environments

Scope

This procedure applies to all Becht Engineering personnel and subcontractors working on projects where heat stress safety requirements are applicable.

2 GENERAL

Heavy industrial operations where high air temperatures, radiant heat sources, high humidity, direct physical contacts with hot objects or strenuous physical activities are present have a high potential for heat stress. Outdoor operations conducted in hot weather, especially those that require semi-permeable or impermeable protective clothing be worn are also likely to cause heat stress among exposed workers. Age, weight, degree of physical fitness, degree of acclimatization, metabolism, use of alcohol or drugs, and a variety of medical conditions affect a person's sensitivity to heat. Environmental factors include more than the ambient air temperature; radiant heat, air movement, conduction, and relative humidity are all factors. The continued success in preventing heat related injuries and illnesses relies heavily on management, supervisors, and personnel working together to utilize their knowledge and experience in applying these guidelines.

Definitions

None

Responsibilities

Non-applicable


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3 PROCEDURE

The following guidelines and control measures should be followed to assist in heat stress prevention:

Modify work / rest schedules according to temperature and workload.

Rotate personnel; alternate job functions to minimize over-stress or overexertion at one task.

Add additional personnel to work teams. Ventilation, air cooling, fans, shielding, and insulation are the five

major types of engineering controls used to reduce heat stress in hot work environments. One or more of these items may be required to be put into place during a job activity.

Reduce the physical demands of work such as excessive lifting or digging with heavy objects where feasible to do so.

Limit worker occupancy, or numbers of workers present, especially in confined or enclosed spaces.

Ample supplies of liquids should be placed close to the work area. Cool (50-60 F degree) water or other liquids should be made available to workers in such a way that they are stimulated to frequently drink small amounts, e.g., one 5-7oz serving every 20 minutes during high temperatures.

Start drinking water before the beginning of the work period. Thirst is not an adequate stimulus to maintain the proper amount of fluid in the body. (If you get thirsty, it‘s taken too long).

Pay close attention to other co-workers during the day to help identify early signs of heat related problems and encourage fluid replenishment.

Ensure employees are in a shaded area during cool down periods, and help to minimize contact with direct sunlight as they rest in hot working conditions.

Cool vests, wetting areas, and increased ventilation measures are to be considered if the heat conditions become extreme.


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SUMMARY OF HEAT RELATED DISORDERS, SYMPTOMS, AND TREATMENTS

DISORDER SYMPTOMS TREATMENT

HEAT STROKE (Least common, but most dangerous) Occurs when body's system of temperature regulation fails and the body's temperature rises to critical levels. This disorder is associated with high fatality rates; so early recognition and treatment are critical.

Red or flushed skin Confusion, irrational

behavior Lack of sweating, hot dry

skin(although person may have been sweating earlier)

High body temperature Dizziness, convulsions,

nausea, vomiting, and headache can result

Loss of consciousness

If heat stroke suspected, contact Medical personnel immediately

Do not delay transportation to medical facility

Sponge body with cool water and fan individual

If patient is alert, give sips of cool water

No one suspected of being ill from heat stroke should be sent home without medical evaluation

HEAT EXHAUSTION may occur after working in hot environments without adequate fluid replacement. Heat exhaustion may be confused with heat stroke, which is a medical emergency.

Weakness, fatigue Headache, nausea,

vomiting, and/or loss of appetite, thirst

Pale, clammy skin with large amount of sweating

Lightheadedness, fainting

Call for medical assistance and move employee to cool environment

Remove unnecessary clothing Person should lie flat If person is alert, offer small amounts of cool water

HEAT CRAMPS may occur after working in moderate to hot environments. This disorder usually occurs after hard physical work. Heat cramps may occur during or after work.

Cramps in skeletal muscles or abdominal muscles

Cramps may be recurrent Muscle pain may continue

after cramps subside

Move person to cool environment Remove unnecessary clothing Provide water or electrolyte solution Seek Medical attention if necessary

HEAT RASH Is the most common heat related disorder. Aggravated by restrictive or impermeable clothing

Skin rash commonly occurs on the arms, shoulders, chest, and behind the knees

may be accompanied by a tingling or prickly feeling

Move to cool environment Remove restrictive or impermeable

clothing, if present Avoid scratching Seek medical attention if necessary Shower and dry skin thoroughly after

working in hot environments


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Heat Stress Program

Category

Ambient Temp.

(F) wearing regular

clothing1

Ambient Temp. (F)

wearing PPE2

Action Steps

I <90 <70 I. No specific heat stress action steps.

II 90-100 70-90 II. Ready access to water, consumption should be 1 cup every 20 min.

Periodic breaks

Monitoring of individuals for symptoms by supervision

III 100-110 90-100 All II, plus a communicated work/rest schedule and at least one of:

Use shading

Use temporary insulation

Use spot cooling (fan or air conditioning)

Use personal cooling devices - cooling vests or vortex tubes

Supplied air respiratory protection

Reflective barriers for radiant heat

>110 >100 All II, plus a documented work/rest schedule; at least one of III, plus:

No work without approval from CLIENT

1

Regular Clothes - (FRC, Nomex, cotton coveralls, etc.) 2

PPE - slicker suits (e.g., for acids or caustics), impermeable coveralls (e.g., for asbestos, lead), disposable coveralls, welding leathers, etc.


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GUIDELINE FOR WORK/REST SCHEDULES

Work Load with Regular Work Clothes for Acclimatized Workers (Temperature in Degrees F)

Work/Rest Schedule in Each Hour

Work Rest

Light Moderate Heavy

95 90 85 continuous

100 95 90 75% 25%

105 100 95 50% 50%

110 105 100 25% 75%

Work Load with PPE for Acclimatized Workers Work/Rest Schedule in Each Hour (Temperature in Degrees F)

Work Rest


85 80 75 continuous

90 85 80 75% 25%

95 90 85 50% 50%

100 95 90 25% 75%


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4 TRAINING

Non-applicable

5 REFERENCE

None

6 APPENDICES

None

INCIDENT REPORTING AND INVESTIGATION

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Becht Engineering Co., Inc. is dedicated to ensuring the safety of internal employees, Advisors and fellow workers at Client sites. Becht Engineering is also committed to providing an injury free work environment and maintaining safety awareness as an integral part of our work ethic.

1 PURPOSE AND SCOPE

Purpose

To establish basic procedures to be utilized following any incident or injury incurring in any office or structure on the Becht Engineering property, any office or structure when on a project at a client‘s location, and in any company car or truck on any date, and any time of day. This policy is also in effect any time an employee is away from the office and representing Becht Engineering. Scope

The Incident Response Policy applies to all Becht Engineering employees.

2 GENERAL

Definitions

―Accident‖

An occurrence in a sequence of events that produces unintended injury, death, or property damage. Accident refers to the event, not the result of an event. ―First Responder‖ Becht Engineering employee representative designated at a Client site. Each Client site will have at least one First Responder assigned. This employee will receive appropriate training in case management and will serve as Becht Engineering‘s First Responder for all onsite incidents, injuries or illnesses. ―Incident‖ An undesired event that may result in personal harm, property damage or other potentially serious consequences. ―Near-miss incident‖


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A newly discovered unsafe condition, fire of any size or trivial incidents of property damage to equipment, structure or product. Client sites may require near miss incidents to be reported. Becht requires a near miss to be reported and investigated if a potential outcome could have been a serious accident, disabling injury or death. ―Unintentional injury‖ Preferred term for accidental injury in the public health community. Refers to the result of an accident. Responsibilities

The Incident Response Administrators

o Becht Engineering Safety Director has the authority and the

responsibility for implementing and maintaining this Incident Response Policy for Becht Engineering Co., Inc.

o Becht Engineering Safety Coordinator is responsible for implementing the procedures described within the Incident Response Policy, initiating incident investigations, ensuring drug and alcohol test completion and designating follow up procedures where necessary.

o Becht Engineering First Responder assigned for each Client site will be responsible for meeting the involved Becht employee at the Client site and transporting them to an Occupational Clinic for post-incident drug and alcohol testing as well as any necessary first aid or medical treatment. This individual will be trained in case management and will participate in any post-incident follow-up procedures, when required.

Managers and Supervisors

o Responsible for implementing and maintaining the Incident

Response Policy in their work areas and for answering worker questions about the Incident Response Policy. A copy of this Incident Response Policy is available from each manager, supervisor and the Safety Coordinator. Management is required to commit to and support preventative and corrective procedures.

Compliance

All workers, including managers and supervisors, are responsible for complying with safe and healthful work practices to ensure the prevention of


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accidents and/or incidents. Our system of ensuring that all workers comply with this policy includes one or more of the following practices:

o Informing workers of the provisions of the Incident Response Policy.

o Evaluate the safety performance of all workers. o Provide training or retraining to workers who demonstrate deficient

safety performance. o Disciplining workers for failing to comply with the conditions of the

Incident Response Policy.

3 PROCEDURE

Becht Engineering‘s primary objective is to prevent all accidents and/or incidents. With proper hazard identification and evaluation, management commitment and support, preventative and corrective procedures, monitoring and training, these events can be prevented. But, when all of these practices are not properly utilized, an accident or incident can occur.

When a Becht Engineering employee is involved in an accident or incident, the following procedures shall take place: Near-miss

1. Immediately notify your Supervisor or Client Contact and Contractor

Safety Coordinator as well as Becht Engineering‘s Safety Coordinator.

2. Complete Client required form if near-miss occurs at Client site or Becht Engineering provided Near miss incident form.

3. Submit completed form to Supervisor or Client Contractor Safety Coordinator, if near-miss is observed at Client site, as well as Becht Engineering‘s Safety Coordinator.

4. An investigation shall be initiated as necessary at Client sites. Becht Engineering‘s Safety Coordinator will initiate an investigation if a potential outcome could have been a serious accident, disabling injury or death.

Incident or Accident

1. Immediately notify your Supervisor or Client Contact and Contractor Safety Coordinator as well as Becht Engineering‘s Safety Coordinator.


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2. The incident/accident must be reported as soon as possible, but no later than the end of the involved individual(s) shift.

3. Complete Client required form as well as Becht Engineering‘s Incident Investigation Report.

4. Submit completed Client form to Contractor Safety Coordinator or Supervisor as well as Becht Engineering‘s Safety Coordinator. Also submit Becht Engineering‘s Incident Investigation Report to Safety Coordinator.

5. Becht Engineering‘s designated First Responder will meet involved employee(s) at the Client site and accompany them to Client‘s first aid facility, if available and necessary.

6. If no on-site first aid facility is available or necessary, the First Responder shall transport individual(s) to designated Occupational Clinic for post-incident drug and alcohol testing as well as first-aid or medical treatment, if needed. If incident/accident results in serious injury, the individual

shall be transported by ambulance to the nearest offsite treatment facility. The individual shall be accompanied by the First Responder and Supervisor, where required.

7. Individual(s) may report back for duty when drug and alcohol tests are reported as negative and doctor release is given, if an injury was sustained.

8. An Incident Investigation will be initiated by the Client site and Becht Engineering‘s Safety Coordinator. Involved individual(s) must participate as required. First Responder shall participate in case management and provide correspondence when necessary.

If a Client‘s policies differ from the procedures described above, the Client‘s procedures shall be followed accordingly (e.g. report to T/A Safety Coordinator instead of Contractor Safety Coordinator).

4 TRAINING

All workers, including managers and supervisors, shall be provided instruction and guidance on the Incident Response Policy. This training is provided:

When the Incident Response Policy is first established. To all new employees. Whenever employee demonstrates lack of knowledge of the

Incident Response Policy‘s procedures. Whenever any changes are made to the Incident Response

Policy.


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5 REFERENCE

None

6 APPENDICES

None


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1 PURPOSE AND SCOPE

Purpose

Becht Engineering fully understands that companies with eleven (11) or more employees at any time during the calendar year immediately preceding the current calendar year must comply with the provisions of 29 CFR 1904. This section provides for recordkeeping and reporting by Becht Engineering covered under 29 CFR 1904 as necessary or appropriate for developing information regarding the causes and prevention of occupational accidents and illnesses, and for maintaining a program of collection, compilation, and analysis of occupational safety and health statistics both for this company and as part of the national system for analysis of occupational safety and health. Records shall be established on a calendar year basis. Scope

The Injury and Illness Recordkeeping Policy applies to all Becht Engineering employees.

2 GENERAL

Becht Engineering will use the criteria of 29 CFR 1904.7-12 to determine recordability for fatalities, injuries, and illnesses that are work related. Becht Engineering will maintain a log of occupational injuries and illnesses under 29 CFR 1904.29 and to make reports under 29 CFR 1904.4 upon being notified in writing by the Bureau of Labor Statistics that the employer has been selected to participate in a statistical survey of occupational injuries and illnesses. Log and summary of occupational injuries and illnesses: Becht Engineering shall:

Maintain a log and summary of all recordable occupational injuries and illnesses by calendar year.

Enter each recordable injury and illness on the 300 and 301 as early as practicable but no later than 7 calendar days after receiving information that a recordable injury or illness has occurred. For this purpose form OSHA No. 300 or an equivalent which is as readable and comprehensible to a person not familiar with it will be used. The log and summary shall be completed in the detail provided in the form and instructions on form OSHA No. 300.


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If Becht Engineering elects to maintain the log of occupational injuries and illnesses at a place other than this establishment or by means of data-processing equipment, or both, it will meet the following criteria:

There will be available at the place where the log is

maintained sufficient information to complete the log to a date within 7 calendar days after receiving information that a recordable case has occurred.

At each facility belonging to this company, all injury and

illness information of that establishment will be sent to the central location within 7 calendar days.

The central facility will provide current information (300 or

301) on injuries and illnesses to other company facilities by the end of the next business day when requested by an employee, former employee, or employee representative.

Information requested by government representatives will be

provided within 4 business hours. Where the facility has operating hours different from the central location, the 4 hours will be considered from that facility.

In addition to the log of occupational injuries and illnesses (OSHA 300)

Becht Engineering shall have available for inspection at each of our facilities within 7 calendar days after receiving information that a recordable case has occurred, a supplementary record for each occupational injury or illness for that establishment. The record shall be completed in the detail prescribed in the instructions accompanying Occupational Safety and Health Administration Form OSHA No. 301. Workmen's compensation, insurance, or other reports are acceptable alternative records if they contain the information required by Form OSHA No. 301 (according to OSHA). If form OSHA No. 300-A and the following information from that form: no acceptable alternative record is maintained for other purposes, Form OSHA No. 301 shall be used or the necessary information will be otherwise maintained.

Annual summary: Becht Engineering shall post an annual summary of

occupational injuries and illnesses for each facility under our control. This summary shall consist of a copy of the year's totals from the:

Calendar year covered.


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Company Name and establishment address.

Certification signature, title, and date.

A form OSHA No. 300A shall be used in presenting the summary. If no injuries or illnesses occurred in the year, zeros will be entered on the total line, and the form posted.

The summary shall be completed by February 1 of each

calendar year. This company, or the director or employee of the employer who supervises the preparation of the log and summary of occupational injuries and illnesses, shall certify that the annual summary of occupational injuries and illnesses is true and complete. The certification shall be accomplished by affixing the signature of the employer, or the director or employer who supervises the preparation of the annual summary of occupational injuries and illnesses, at the bottom of the last page of the log and summary or by appending a separate statement to the log and summary certifying that the summary is true and complete.

A copy of the establishment's summary in shall be visibly

posted in each facility in the same manner required under 29 CFR 1904.32 The summary covering the previous calendar year shall be posted no later than February 1, and shall remain in place until April 30. For employees who do not primarily report or work at a fixed site belonging to this company, or who do not report to any fixed site on a regular basis, we shall satisfy this posting requirement by presenting or mailing a copy of the summary during the month of February of the following year to each such employee who receives pay during that month.

3 RECORDKEEPING

Records provided for in 29 CFR 1904.4 – 1904.12 (including form OSHA No. 300 and its predecessor forms OSHA No. 301 and OSHA No. 300-A) will be retained for 5 years following the end of the year to which they relate. Access to records: Becht Engineering shall provide, upon request, records provided for in 29

CFR 1904.4 – 1904.12, for inspection and copying by any representative of the Secretary of Labor for the purpose of carrying out the provisions of the OSHA act, and by representatives of the Secretary of Health, Education, and Welfare, or by any representative of a State accorded


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jurisdiction for occupational safety and health inspections or for statistical compilation.

The log and summary of all recordable occupational injuries and illnesses

(OSHA No. 300) will, upon request, be made available to any employee, former employee, and to their representatives for examination and copying in a reasonable manner and at reasonable times. The employee, former employee, and their representatives shall have access to the log for any establishment in which the employee is or has been employed.

Reporting of fatality or multiple hospitalization accidents. Within 8 hours

after the occurrence of an employment accident which is fatal to one or more employees or which results in hospitalization of three or more employees, Becht Engineering shall report the accident either orally or in writing to the nearest office of the Area Director of the Occupational Safety and Health Administration, U.S. Department of Labor. The reporting may be by telephone or telegraph. The report shall relate the circumstances of the accident, the number of fatalities, and the extent of any injuries. It is understood that the Area Director may require such additional reports, in writing or otherwise, as he deems necessary, concerning the accident.

Change of ownership. Should this company change ownership, the

company shall preserve those records, if any, of the prior ownership which are required to be kept.

Petitions for recordkeeping exceptions. Should this company wish to

maintain records in a manner different from that required the company will submit a petition containing the information specified by the Regional Commissioner of the Bureau of Labor Statistics in our region.

Employees not in fixed establishments: Record requirements for company

employees engaged in physically dispersed operations such as occur in construction, installation, repair or service activities who do not report to any fixed company establishment on a regular basis but are subject to common supervision will be satisfied by:

o Maintaining the required records for each operation or group of

operations which is subject to common supervision (field superintendent, field supervisor, etc.) in an established central place located in Baytown, Texas.

o Having the address and telephone number of the central place

available at each worksite.


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o Having personnel available at the central place during normal business hours to provide information from the records maintained there by telephone and by mail.

4 STATISTICAL PROGRAM

Becht Engineering will comply with all requirements to maintain, provide, and use statistical summaries. Upon receipt of an Occupational Injuries and Illnesses Survey Form, Becht Engineering shall promptly complete the form in accordance with the instructions contained therein, and return it in accordance with the instructions.

5 TRAINING

All workers, including managers and supervisors, shall be provided instruction and guidance on the Injury and Illness Recordkeeping Policy. This training is provided:

When the Injury and Illness Recordkeeping Policy is first established.

To all new employees. Whenever employee demonstrates lack of knowledge of the

Injury and Illness Recordkeeping Policy‘s procedures. Whenever any changes are made to the Injury and Illness

Recordkeeping Policy. Whenever specific roles or responsibilities are assigned. Periodically throughout the year during safety meetings and

when an incident occurs.

6 REFERENCE

29 CFR 1904

7 APPENDICES

None

PANDEMIC ILLNESS PREPAREDNESS PLAN

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1 PURPOSE

To proactively protect the health and safety of all employees of Becht Engineering Co., Inc.

2 SCOPE

Becht Engineering recognizes that our people drive our business. As our most critical resource, employees are safeguarded through training, provision of appropriate work surroundings and procedures that foster protection of health and safety. No duty, no matter what its perceived result, is more important than employee health and safety.

3 GENERAL GUIDELINES IN AN EMERGENCY

Stay calm and think through your actions.

Know important emergency numbers:

Fire/Police/Ambulance (9) 9-1-1

Operator 0

Human Resources Manager 908-394-1273

Safety Coordinator 281-427-3900

4 PANDEMIC ILLNESS

Becht Engineering shall appoint the Safety Coordinator or Human Resources Manager as the workplace illness coordinator, who will be responsible for dealing with pandemic illness or disease issues and their impact at the workplace. Key contacts are included on page 8 of this document. In the event of a pandemic illness, employees shall report directly to their Division Director/Supervisor on a daily basis in an effort to maintain effective communication and assess work progress.

Symptoms of flu and other pandemic illnesses can include fever, cough, sore throat, runny or stuffy nose, body aches, headache, chills, and fatigue, and sometimes diarrhea and vomiting. People may be infected with the flu, including 2009 H1N1 flu, and have respiratory symptoms without a fever. Like seasonal flu, 2009 H1N1 flu infection in humans can vary in severity from mild to severe. Visit http://www.cdc.gov for more information on flu and other pandemic illness symptoms.

http://www.cdc.gov/


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Like seasonal flu, the 2009 H1N1 flu virus is spread mainly from person to person through coughs or sneezes of infected individuals. People may also become infected by touching something – such as a surface or object – with flu virus on it and then touching their mouth, nose, or eyes.

Some people are at higher risk than others for serious complications from flu.

These people include:

children younger than 5 years old, but especially children younger than 2 years old

people aged 65 years or older

pregnant women

adults and children who have:

o asthma

o neurological and neurodevelopmental conditions

o chronic lung disease

o heart disease

o blood disorders

o endocrine disorders (such as diabetes)

o kidney, liver, and metabolic disorders

o weakened immune systems due to disease or medication

people younger than 19 years of age who are receiving long-term aspirin therapy

During a flu outbreak, all sick people should stay home and away from the workplace, respiratory etiquette and hand hygiene will be encouraged, and routine cleaning of commonly touched surfaces will be performed regularly. If the severity of illness increases, Becht Engineering will be prepared to implement additional measures while continuing to rigorously implement the interventions recommended for an outbreak similar to April through December 2009 of the 2009 H1N1 flu outbreak.

If severity increases, public health officials may recommend a variety of methods for increasing the physical distance between people (called social distancing) to reduce the spread of disease, such as school dismissal, early childhood program closure, canceling large community gatherings, canceling large business-related meetings, spacing employees farther apart in the workplace, canceling non-essential travel, and recommending work-from-home strategies for employees that can conduct their business remotely. The following strategies and procedures will be utilized in the event of a pandemic illness outbreak:

Separate sick employees:


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o CDC recommends that employees who appear to have flu-like illness upon arrival or who become sick during the day be promptly separated from other employees and be advised to go home immediately until at least 24 hours after they are free of fever (100° F [37.8° C] or greater when taken orally), or signs of a fever, without the use of fever-reducing medicines.

o Those who become sick with symptoms of flu-like illness during the work day should be:

Separated from other employees and asked to go home immediately. (For recommendations on personal protective equipment for a person assisting the sick employee, see Interim Recommendations for Facemask and Respirator Use to Reduce Novel Influenza A (H1N1) Virus Transmission; http://www.cdc.gov/h1n1flu/masks.htm).

CDC recommends people with known, probable, or suspected flu or flu-like illness to use a facemask if available and tolerable, or otherwise to cover their noses and mouths with a tissue when coughing or sneezing (or an elbow or shoulder if no tissue is available).

If an employee becomes sick at work, inform fellow employees of their possible exposure in the workplace to flu-like illness but maintain confidentiality as required by the Americans with Disabilities Act (ADA). For more information on privacy issues, refer to: http://www.flu.gov/faq/workplace_questions/equal_employment/index.html#PrivacyIssues Employees exposed to a sick co-worker should monitor themselves for symptoms of flu-like illness and stay home if they are sick.

Emphasize respiratory etiquette and hand hygiene by both people who are well and those who have any symptoms of flu:

o Flu and viruses are thought to spread mainly from person to person in respiratory droplets of coughs and sneezes. Employees will be provided information on the importance of covering coughs and sneezes with a tissue or, in the absence of a tissue, one‘s elbow or shoulder. Posters will be placed at worksites with 10 or more employees that encourages cough and sneeze etiquette. Posters will be issued via email from the Safety Coordinator to be printed and posted.

o Tissues, disposable towels, and no-touch disposal receptacles will be provided for use by employees.

http://www.cdc.gov/h1n1flu/masks.htm



http://www.flu.gov/faq/workplace_questions/equal_employment/index.html#PrivacyIssues




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o Flu may be spread via contaminated hands. Supervision will instruct or remind employees to wash their hands often with soap and water. If soap and water are not readily available, employees will be supplied with alcohol-based hand rub. However, hand rubs should not be used when hands are visibly soiled. Posters will be distributed by the Safety Coordinator via email to offices with 10 or more employees that encourage hand hygiene. Posters will be placed in a visible and accessible location.

o Adequate supplies will be maintained and made readily available. Where feasible, hand rubs will be placed in multiple locations or in conference rooms to encourage hand hygiene.

o Field personnel will follow the site‘s applicable plan and procedures. The Safety Coordinator will provide anti-bacterial wipes or rub upon request for field personnel that do not have access to an adequate supply at their worksite.

Perform routine environmental cleaning:

o All frequently touched surfaces in the workplace, including but not limited to workstations, countertops, faucets and doorknobs, will be routinely cleaned by office staff and when visibly soiled. Disinfectants will be used in these areas according to the manufacturer‘s recommendations.

o No additional disinfection beyond thorough, routine cleaning is recommended.

o Disposable wipes will be provided so that commonly used surfaces (for example, doorknobs, keyboards, remote controls, desks) can be wiped down by employees before each use.

Take measures to protect employees who are at higher risk for complications from the flu:

o Inform employees that some people are at higher risk for complications from the flu and that if they are at higher risk for complications, they should check with their healthcare provider or Becht Engineering‘s Health Advocate Program at (866) 695-8622 if they become sick. It‘s very important that antiviral drugs be used early to treat flu or illness in people who are very sick (for example people who are in the hospital) and people who are sick with flu and have a greater chance of getting serious flu complications.

o Encourage employees recommended for seasonal flu vaccine and 2009 H1N1 flu vaccines to get vaccinated. If needed, Becht Engineering will grant time off work to obtain the vaccine when vaccines become available in the community. For information on


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groups prioritized for seasonal and 2009/2010 H1N1 flu vaccines, please see: http://www.cdc.gov/flu/protect/keyfacts.htm http://www.cdc.gov/h1n1flu/vaccination/acip.htm.

o Employees who become sick and are at higher risk for flu complications and sick employees who are concerned about their illness should call their healthcare provider or Becht Engineering‘s Health Advocate Program at (866) 695-8622 for advice. Their healthcare provider might want them to take antiviral medicines to reduce the likelihood of severe complications from the flu.

o See http://www.cdc.gov/h1n1flu/qa.htm for more information.

Prepare for increased numbers of employee absences due to illness in employees and their family members, and plan ways for essential business functions to continue:

o Becht Engineering will monitor and respond to absenteeism at the workplace. Elevated absentee rates can be due to sick employees, those who need to stay home and care for others, or from employees with conditions that make them at higher risk for flu complications and who may be worried about coming to work.

o Because workers will be encouraged to stay at home when ill, when having to care for ill family members, or when caring for children when schools close, without fear of reprisal, personnel will be cross-trained to perform essential functions so that the workplace is able to operate even if key staff members are absent or very ill. When possible, staff members will work from home.

o In the event of an escalation in absenteeism, Becht Engineering Division Managers and Site Coordinators will notify the Safety Coordinator when employees under their coordination and supervision are absent, and the reason for the absence (e.g., sick, caring for others, high risk).

The Safety Coordinator shall provide daily updates to the President and Director of Advisor Resources relative to the number of employees who are absent, and the status of each.

Division Managers will work with the President, and the Site Coordinators will work with the Director of Advisor Resources to identify staffing gaps and to develop closure plans which may include the use of cross-trained backup resources, telecommuting, etc.

http://www.cdc.gov/flu/protect/keyfacts.htm

http://www.cdc.gov/h1n1flu/vaccination/acip.htm

http://www.cdc.gov/h1n1flu/qa.htm


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o Becht Engineering Division Managers and Site Coordinators will notify key contacts, including both customers and suppliers, of operation interruptions in the event an outbreak has impacted Becht Engineering‘s ability to perform services. Notifications will be made via telephone and/or e-mail. Formal notification will be provided to customers and suppliers when normal operations resume.

Advise employees before traveling to take certain steps:

o Advise employees to check themselves for fever and any other signs of flu-like illness before starting travel and notify their supervisor and stay home if they are sick.

o Advise employees who will be traveling or on temporary assignment about precautions they may need to take to protect their health and who to call if they become sick.

o Employees who become sick while traveling and are at higher risk for flu complications and others concerned about their illness should promptly call a healthcare provider or Becht Engineering‘s Health Advocate Program at (866) 695-8622 for advice.

Prepare for the possibility of school dismissal or temporary closure of early childhood programs:

o Although school dismissals or closures of early childhood programs are not likely to be generally recommended at this level of severity, they are possible in some jurisdictions.

o Employees will be allowed to stay home, without fear of reprisal, to care for children if schools are dismissed or early childhood programs are closed.

o Strongly recommend that parents not bring their children with them to work while schools are dismissed.

o Leave policies at Becht Engineering are flexible and non-punitive.

o For more information, see the CDC‘s Guidance for State and Local Public Health Officials and School Administrators for School (K-12) Responses, which can be found at http://www.cdc.gov/h1n1flu/schools/schoolguidance.htm, to better understand the conditions under which schools may be dismissed.

Consider increasing social distancing in the workplace:

o If flu severity increases, local public health officials may recommend that employers implement measures to increase the physical distance between people in the workplace to reduce the

http://www.cdc.gov/h1n1flu/schools/schoolguidance.htm


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spread of flu. The goal should be for there to be at least 6 feet of distance between people at most times. This is not a simple or easy strategy and would typically require considerable flexibility. These measures may include avoiding crowded work settings, canceling business-related face-to-face meetings, spacing employees farther apart, canceling non-essential travel, increasing use of tele-working, and using staggered shifts to allow fewer employees to be in the workplace at the same time.

5 TRAINING

Employees will be trained annually, before each flu season, on health issues of pertinent diseases to include prevention of illness, initial disease symptoms, preventing the spread of the disease, and when it is appropriate to return to work after illness. Disease containment plans and expectations will be shared with employees. Appropriate informational and training materials will be provided to employees who are not fluent in English and to those who have disabilities. The plan and emergency communication strategies will be annually tested to ensure they are effective and workable.

6 MEDICAL EMERGENCY

Upon discovering a medical emergency, call (9) 9-1-1. Provide all information available to emergency responders to facilitate a fast response.

Designate one employee to wait for the emergency responders at the point of entry of the building to provide precise direction to the injured person.

Stay with the ill/injured person. Be careful not to come in contact with any bodily fluids unless properly trained and protected. Do not attempt to move the person, unless instructed to do so by a physician or 911 operator.

Send one person to alert Human Resources Manager so they can notify family members of the ill/injured person. Personal information on employees is kept in Liberty Corner on file with Human Resources Manager.

Employees in the immediate vicinity of the emergency, but not involved in the emergency effort, should leave the area.


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Emergency Contact List

Texas Division

Building Warden

Glinda Hawthorne 281-427-3900 281-515-6808 - cell

Occupational Clinic Occupational Healthcare

281-843-2441

610 S Main

Highlands, TX 77562

Local Hospital San Jacinto Methodist

281-420-8600

4401 Garth Rd.

Baytown, TX 77521

Division Director/Safety

Coordinator

Bonnie Winkler

281-705-8287

[email protected]

Rachel Shannon

281-515-6514

[email protected]

Liberty

Corner

Building Warden

Bill McEnerney

908-580-1119 908-392-4136 - cell

Occupational Clinic Primary Medical Center

908-231-0777

350 Grove & Hwy. 22 East

Bridgewater, NJ 08807

Local Hospital St. Peter’s University Hospital

732-745-8525

254 Easton Avenue

New Brunswick, NJ 08901

Division Director/ Key

Contact

Paula Lazer – HR

908-580-1119

[email protected]

Mickey Smajda

908-394-1203

[email protected]

Baton Rouge

Building Warden

Jodi Perrodin

225-293-7727 225-921-2744 – cell

Occupational Clinic Med-Aid

225-767-2750

5475 Essen Lane

Baton Rouge, LA 70809

Local Hospital Our Lady of the Lake

Regional medical Center

225-765-8826

5000 Hennessy Boulevard

Baton Rouge, LA 70808

Division Manager Harry Costner

[email protected]

225-293-7727 - office

225-603-3551 - cell


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California Division

Building Warden

Betsy Jorgensen

949-660-1480 949-231-7225 - cell

Occupational Clinic Optimum Medical Clinic

949-757-1150

20072 SW Birch St., Suite 100

Newport Beach, CA 92660

Occupational Clinic

(Near Refinery)

Long Beach Medical Clinic

562-437-0831

1250 Pacific Avenue

Long Beach, CA 90813

Local Hospital Hoag Hospital

949-764-4624

1 Hoag Drive

Newport Beach, CA 92663

Division Manager Arcot (Radha)

Radhakrishnan

[email protected]

949-660-1480 – office

Canada

Building Warden

Trevor Seipp

1-403-256-3575 ext 221

1-403-978-4332

Occupational Clinic Wellpoint Health Corp.

403-236-8400

Foothills Industrial Park -

Foothills Plaza

Suite 202, 3716 - 61 Ave. SE

Calgary, Alberta

Canada T2C 1Z4

Local Hospital Rockyview General Hospital

403-943-3000

7007 14 Street SW

Calgary, AB T2V 1P9,

Division Manager Trevor Seipp

[email protected]

1-403-256-3575

Employees providing services at a client site will adhere to the Pandemic Illness policies and procedures implemented at their assigned site, and will maintain contact with their Site Coordinator during periods of absenteeism due to an

illness outbreak.

ERGONOMICS PROGRAM

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1 PURPOSE AND SCOPE

Purpose

It is the policy of Becht Engineering to provide all employees with a safe and healthy workplace. A proactive ergonomics program is integrated into our company‘s written safety and health program. Scope

The Office Ergonomics Policy applies to all Becht Engineering employees.

2 GENERAL

Ergonomics is the study of people and their interaction with the elements of their job or task including equipment, tools, facilities, processes, and environment. It is a multidisciplinary field of study integrating industrial psychology, engineering, medicine, and design. In a more practical sense, ergonomics is the science of human comfort. When aspects of the work or workplace exceed the body‘s capabilities, the result is often a musculoskeletal disorder (MSD). To help avoid MSDs, work demands should not exceed the physical capabilities of the worker. MSDs are also known by several other names including: CTDs (cumulative trauma disorders) RSIs (repetitive stress or repetitive strain injuries) RMIs (repetitive motion injuries) Overuse syndrome

The most common, recognizable name for MSDs is cumulative trauma disorders or CTDs. Whatever the name used, these injuries belong to a family or group of wear and tear illnesses that can affect muscles, nerves, tendons, ligaments, joints, cartilage, blood vessels or spinal discs of the body. MSDs do not include slips, trips and falls, cuts, motor vehicle accidents or other similar accidents; although a close look at the reasons for acute injuries often reveals design problems that can be corrected.

3 RESPONSIBILITIES

ERGONOMICS PROGRAM

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Safety Coordinator. The Safety Coordinator will report directly to upper management and be responsible for this policy and program. All evaluations, controls, and training will be coordinated under the direction of the Safety Coordinator in collaboration with management. The Safety Coordinator will monitor the results of the program to determine additional areas of focus, as needed. The Safety Coordinator will:

Ensure employees understand necessity to report MSD signs or

symptoms and suspected work-related risk factors immediately to managers and supervisors;

Ensure that accurate records are maintained and provide documentation upon request;

Ensure that control measures are implemented in a timely manner; Schedule manager, supervisor, and employee training and maintain

records to include date, topic, and materials used; Monitor the program on an annual basis. Follow-up with any ergonomics strategy and/or solutions.

Managers. Duties of all managers will include: Accountability for the health and safety of all employees within their

departments through the active support of the ergonomics program; Allocating human and/or financial resources; Ensuring that recommended controls are implemented and/or used

appropriately through active follow-up; Ensuring that employees are provided with and use the appropriate tools,

equipment, parts, and materials in accordance with ergonomic requirements;

Responding promptly to employee reports; Seeking clarification from human resources when return-to-work directives

from the health care provider are unclear, and; Maintaining clear communication with employees.

Employees. Every employee of Becht engineering is responsible for conducting himself/herself in accordance with this policy and program. All employees will: When provided, use the appropriate tools, equipment, parts, materials,

and procedures in the manner established by managers or client site safety standards;

Ensure that equipment is properly maintained in good condition and when not, report it immediately;

Provide feedback to supervisors regarding the effectiveness of design changes, new tools or equipment, or other interventions;

ERGONOMICS PROGRAM

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Attend ergonomics training as required and apply the knowledge and skills acquired to actual jobs, tasks, processes, and work activities;

Report MSD signs or symptoms (symptoms defined in Appendix B) and work-related MSD hazards to the supervisor as early as possible to facilitate medical treatment and initiate proactive interventions, and;

Take responsibility in their personal health and safety.

4 PROCEDURE

The purpose of an ergonomics program is to apply ergonomic principles to the workplace in an effort to reduce the number and severity of MSDs, thus decreasing workers‘ compensation claims and, where possible, increase productivity, quality, and efficiency. An ergonomically sound work environment maximizes employee comfort while minimizing the risk of undue physical stress. A proactive approach focuses on making changes when risks have already been identified, as well as incorporating ergonomics into the design phase of a new facility or process, into purchasing new equipment or tools, and into the contemplation of scheduling changes. Becht Engineering has such a program which includes the following components:

Management Leadership. The management of Becht Engineering is committed to the ergonomics process. Management will support an effective MSD reporting system and will respond promptly to reports.

Employee Participation. An essential element to the success of the ergonomics program, employees will be solicited for their input and assistance with identifying ergonomic risk factors, worksite evaluations, development and implementation of controls, and training. Employee participation in the program will occur only during company time.

Identification of Problem Jobs. Collecting data that identifies injury and illness trends is called surveillance. Surveillance can be either passive or active. Conducting a records review is an example of passive surveillance, which looks at existing data such as OSHA Logs, workers‘ compensation claims, trips to the medical facility, and absentee records. Active surveillance uses observations, interviews, surveys, questionnaires, checklists, and formal worksite evaluation tools to identify specific high-risk activities. Becht Engineering will be using both passive and active surveillance to identify problem jobs.

Worksite Evaluations.

Triggers for a worksite evaluation:

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When an employee reports an MSD symptom (symptoms defined

in Appendix B). When a safety walk-through or scheduled inspection or survey has

uncovered potential MSD hazards.

Work-related risk factors to be considered in the evaluation process include, but are not limited to:

Physical risk factors including force, postures (awkward and static),

static loading and sustained exertion, fatigue, repetition, contact stress, extreme temperatures, and vibration.

Combination of risk factors such as, but not limited to, highly repetitive, forceful work with no job rotation or precision work done in a dimly lit room.

Worksite Evaluations Methods. Various methods will be used to evaluate problem jobs including:

Walk-through and observations Employee interviews Surveys and questionnaires Checklists Detailed worksite evaluations

Control of the Ergonomic Risk Factors. Becht Engineering will take steps to identify ergonomic risk factors and reduce hazards by using a three-tier hierarchy of control (in order of preference):

Engineering controls. The most desirable and reliable means to

reduce workplace exposure to potentially harmful effects. This is achieved by focusing on the physical modifications of jobs, workstations, tools, equipment, or processes.

Administrative controls. This means controlling or preventing

workplace exposure to potentially harmful effects by implementing administrative changes such as job rotation, job enlargement, rest/recovery breaks, work pace adjustment, redesign of methods, and worker education.

Personal protective equipment (PPE). Although not recognized as

an effective means of controlling hazards and do not take the place of engineering or administrative controls, there are acceptable forms of PPE, which include kneepads and anti-vibration gloves.

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MSD (Medical) Management Pursuant to the law, Becht Engineering provides medical care to all employees injured at work. In the event of an ergonomic work-related injury or illness, the employee‘s selected health care provider will:

Provide diagnosis and treatment. Determine if reported MSD signs or symptoms are work-related; Refer Becht Engineering injured employees to other clinical resources

for therapy or rehabilitation; Provide Becht Engineering with timely work status reports.

Program Evaluation and Follow-Up In order to ensure that issues have been addressed and that new problems have not been created, monitoring and evaluation will be conducted on an on-going basis. The methods include use of individual interviews and checklists to reevaluate the job/task to ensure that risks have been reduced, minimized, or eliminated.

5 PROGRAM EVALUATION

Program Review The Safety Coordinator will conduct an annual program review, following worksite evaluations or reports of ergonomically related injuries, to assess the progress and success of the program. The review will consider the following: Evaluation of all training programs and records. The need for retraining of managers, supervisors, and employees. The jobs, processes, or operations which have produced a high incidence

rate of work-related MSDs. The length of time between a request for an ergonomic evaluation and the

actual evaluation. The length of time between the point at which the results of the evaluation

are known and when implementation of controls begins. The length of time between the beginning and completion of

implementation of controls. The program‘s success based upon comparison to previous years using

the following criteria:

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Number and type of lost workdays associated with OSHA recordable cases.

Employee feedback through direct interviews, walk-through observations, written surveys and questionnaires, and reevaluations.

6 TRAINING

Training is intended to enhance the ability of supervisors and employees to recognize work-related ergonomic risk factors and to understand and apply appropriate control strategies. Training in the recognition and control of ergonomic risk factors will be given as follows:

To all new employees during orientation. When high exposure levels to ergonomic risk factors have been

identified. The minimum for all managers, supervisors and employees will include the following elements:

An explanation of Becht Engineering‘s ergonomics program and their role in the program;

A list of the exposures which have been associated with the development of MSDs;

A description of MSD signs and symptoms and consequences of injuries caused by work and non work-related risk factors;

An emphasis on the importance of early reporting of MSD signs and symptoms and injuries to management, and;

The methods used by Becht Engineering to minimize work and non work-related risk factors.

Training will be provided in one, or a combination, of the following formats:

Oral presentations Videos Distribution of educational literature Hands-on equipment and work practice demonstrations

Trainers will be experienced in delivering training programs that address all work and non work-related risk factors, and will be familiar with Becht Engineering operations. Training will be provided from one, or a combination, of the sources listed below:

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Internally developed resources An outside consultant

All training will be documented:

All employees will be required to sign a training sign-in roster.

7 REFERENCE

NIOSH Publication No. 97-141 California Code of Regulations, Title 8, Section 5110

8 APPENDICES

Appendix A: Becht Engineering‘s Ergonomic Assessment Appendix B: What You Need to Know About Musculoskeletal Disorders (MSDs)

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Becht Engineering Co., Inc. Ergonomics Program

Appendix A: Office Ergonomic Assessment

Step 1: Adjust the Chair 1. Stand in front of the chair. Adjust the

height so that the top surface of the seat is just below the knee cap.

Seat Height is Correct

Seat Too Low

Seat Too High

Chose not to adjust

2. Sit so that your back is against the back of

the chair. Your feet should rest firmly on

the floor with your lower legs vertical, and

your upper legs with a slight downward

slope toward the knee. The clearance

between the front edge of the seat and the

lower part of the legs should be no less

than the width of a clenched fist, and no more than ½ your thigh.

Seat depth is correct

Seat depth is too short

Seat Depth is too long

Chose not to adjust

3. Adjust the angle and height of the chair

back so that the lumbar support contacts

the hollow in the lower back, above the junction with your pelvic bones.

Lumbar support is correct

Lumbar support too low

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Lumbar support too high

No lumbar support in chair back

Chose not to adjust

4. Adjust the angle of the chair back so that

you are held with your torso vertical or with

a slight backward incline, even when

leaning back comfortably against the chair

back.

Seat back is correct

Seat back leans too far backward

Chose not to adjust

5. Adjust the seat pan tilt for comfort,

ensuring that upper legs have a slightly

downward incline and feet rest firmly on the

floor

Seat pan tilt is correct

Seat pan tilts too far forward

Seat pan tilts too far backward

Chose not to adjust

6. Sit with your upper arms comfortably at

your sides, your elbows bent, and your

forearms held at a slightly downward slope

toward the wrists. The armrests should be

just barely supporting your elbows and

forearms, not touching at all, or far enough

away on each side that your forearms move

freely without touching them. Adjust

armrests or remove them.

Armrests properly adjusted

Armrests removed

Armrests interfere with arm movement

Chose not to adjust

Step 2: Adjust your keyboard and mouse 1. Place your chair directly in front of your

keyboard, facing it and the monitor.

Positioned properly

Cannot position properly

Chose not to adjust

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2. Hold your upper arms comfortably by

your side, bend your elbows, and hold

your forearms horizontally with a slight

downward slope to the wrists. Keep

your wrists straight and your palms down.

If you have an

adjustable

keyboard tray,

adjust it so the

keys are under

your fingers.

If you do not have a

height-adjustable

keyboard, or your

keyboard is on the

desktop, raise the

height of the chair so

that the keys are under

your fingers.

Keyboard tray height correct

Chair raised: feet rest firmly on floor

Chair raised: footrest needed

Cannot adjust keyboard or chair

Chose not to adjust

3. Place your mouse at the same height as

your keyboard, immediately to the right

or left (depending on preference). You

should be able to reach and move the

mouse with the same arm position as for

the keyboard (upper arms vertical, lower arms roughly horizontal).

Mouse position correct

No place for mouse on keyboard tray

Chose not to adjust

Step 3: Adjust the Monitor 1. Align the monitor so that it is directly in

front of your chair and keyboard.

Positioned properly

Cannot position properly

Chose not to adjust

2. The top line of the screen should be no

higher than a line horizontal with your

eyes. If you wear bifocals, the monitor

should be lower, so you don’t have to tilt

your head back to read the screen.

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Positioned properly

Can’t lower monitor enough

Chose not to adjust

3. While seated in the typing position,

bring the monitor forward until it is the

length of your arms (shoulders to middle

fingertips) from you. Adjust as

necessary until you don’t need to either

lean forward or backward to comfortably read the screen.

Positioned Correctly

Cannot bring close enough

Cannot get far enough away

Chose not to adjust

4. Tilt the screen so reflections from lights,

windows, and other glare sources do not interfere with reading the screen.

Adjusted correctly

Glare cannot be eliminated

Chose not to adjust

Step 4: Other Adjustments 1. The best location for source documents

is to one side of the monitor at the same

distance, height, and angle. A less

comfortable but acceptable location is

between the monitor and the keyboard,

angled toward your eyes for easy

reading. A document holder is necessary for either location.

Correct

Do not have document holder

Chose not to adjust

2. Arrange telephone, calculator, and other

office equipment that you use regularly

to within easy reach of your arms while

sitting in typing position, so you do not

have to lean over to reach them. A

good solution is a secondary worktable

at right angles to your computer table,

so you can swivel to reach items.

Other items correctly positioned

Space not available

Chose not to adjust

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3. Keep space under desk clear of

computers, trashcans, and other items

that interfere with freedom of movement

for your legs.

Space is correct

Nowhere else to store items

Chose not to adjust

4. Sit at your computer and type awhile.

Does any part of your body rest against

a hard edge - like the edge of a desk or keyboard tray – which is not padded?

No hard edges

Hard edges

Step 5: Finish When you have completed the assessment, give it to your supervisor.

Name Job Title Section Building Floor Office

Step 6: Work Practice Adjustments 1. Do not rest wrists on the keyboard

wristrest while typing. Wrist rests are for resting your wrists when not typing. Resting your wrists on them and pivoting your fingers over the keys while typing causes your wrists to bend upward. Instead, float your hands over the keyboard when typing, then rest your hands on the wrist rest during pauses.

2. Type using your whole forearm instead of stretching your fingers.

Instead of stretching your fingers or pivoting your wrists to reach keys that are further away, move your hand to the key by extending your arm. Do the same to reach keys to the left and right instead of bending your wrists. Always try to keep your wrists at a neutral (unbent) angle when typing.

3. Alternate between keystrokes and The key to reducing ergonomic stresses is

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mouse use. to reduce repetitive motions and static muscle efforts. Save documents sometimes by clicking the Save icon or menu item with the mouse; other times, press CTRL-S to save. Alternate often between the use of the keyboard and the use of the mouse.

4. Quit typing when using the telephone. When you try to talk on the phone while typing, you have to hold the headset wedged between your head and shoulder. This causes you to hunch your shoulders and tilt your head, and presses these body parts against a hard surface. Quit typing when you are on the phone: this gives your hands and arms a rest from typing activities, and doesn‘t place you in an awkward position. If your job requires you to be on the phone and type at the same time, request a headset.

5. Break up typing activities at least 5 minutes each hour.

Adjust your work schedule so you are not sitting at the computer typing for more than 50 – 55 minutes at a time. Perform other activities that allow you to change your posture and use other muscle groups, and that give your upper body muscles (shoulders, neck, arms, wrists, and hands) a chance to recover from the typing activities. Even getting out of your chair and stretching will help reduce muscle stress.

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1 PURPOSE AND SCOPE

Purpose

The purpose of Asbestos Awareness is to inform all Becht employees of the hazards of Asbestos. To describe what asbestos is, where it is found, adverse health effects and how to avoid it.

Scope

This procedure applies to all Becht personnel working on projects where asbestos exposure control requirements are applicable.

2 GENERAL

Definitions None

Responsibilities

Management Responsible for implementing, maintaining & monitoring

effectiveness of the entire asbestos awareness program.

The Company Safety Manager Responsible for including annual revisions and updates to reflect

the current status of the program.

Advisors Responsible for providing continuous control over operations and

inform management of any deficiencies.

Employees Responsible for the following:

1. follow all operational and asbestos safety procedures 2. seek immediate supervisor guidance to resolve questions 3. conduct operations in accordance with Company provided

training 4. immediately report to a supervisor any potential exposures.

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3 PROCEDURE

What is Asbestos?

Asbestos is the name applied to various naturally occurring silicate minerals. The types successfully mined and marketed include: amosite (brown); chrysotile (white); tremolite; actinolite; anthophyllite; and crocidolite (blue). Asbestos is probably the best insulator known to man. Asbestos fibers are resistant to chemicals and heat, do not evaporate into air or dissolve in water, are very stable in the environment, and are also virtually indestructible. Because asbestos has so many useful properties, it has been used in over 3,000 different products. Usually asbestos is mixed with other materials to actually form the products. Floor tiles, for example, may contain only a small percentage of asbestos. OSHA mandates that any product/material containing one percent or more of asbestos be identified as an "asbestos-containing material" (ACM). Where is Asbestos-Containing Material (ACM) Found? ACM is located in nearly all buildings and workplaces. Examples of ACM products may include but are not limited to: Wall, ceiling, pipe insulation, boiler, fire proofing, and other sprayed-on

insulation in buildings Putties, caulks, cements, wall and ceiling textures, mastic, glues and

joint compounds; Ceiling and floor tiles; Roofing shingles and siding shingles; Acoustical plasters and transite (used on many cooling water towers)

materials; Mudded fittings and joints; Fire doors and electrical wire insulation; Gaskets; Brake linings and

clutch pads; These and many other building materials used in construction prior to

1981.

***NOTE*** No Becht employee is authorized to work on any equipment which may contain Asbestos. All work involving Asbestos will be abated by the facility prior to our work beginning. This program is provided simply as general awareness program.

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When is Asbestos Potentially Hazardous/Dangerous? Asbestos or ACM is most hazardous when it is "friable". The term "friable" means that the ACM is easily crumbled by hand, releasing fibers into the air. For example, sprayed-on or pipe asbestos insulation may be highly friable. However, asbestos-containing ceiling tiles, floor tiles, laboratory cabinet tops, shingles, fire doors, siding shingles, etc., will not release asbestos fibers unless they are disturbed or damaged in some way. If an asbestos containing material is drilled, broken, ground, buffed, cut, sawed, struck or otherwise damaged, it may release fibers into the air. If it is left alone and not disturbed, it will not. What are the Potential Adverse Health Effects of Overexposure? ACM materials are generally not considered to be harmful unless it is being damaged to the extent that very small fibers are being released into the atmosphere. Upon continual vibration and physical impact such as drilling or grinding, all types of asbestos tend to break into very tiny fibers, so small that many must be identified using a microscope. In fact, some fibers may be up to 700 times smaller than a human hair and once released into the air, they may stay suspended there for hours for even days. Asbestos is generally considered to be potentially harmful when very small fibers are inhaled deep into the lungs. The very smallest fibers cannot be removed by the lung's natural defense systems and may become lodged in the alveolar lung tissue. They remain in the lung where these fibers may cause disease. OSHA believes that the most common adverse health effect is 'asbestosis", which is scarring of the lungs. Mesothelioma is a rare form of cancer of the membrane lining the chest and abdomen (about 200 cases each year in the U.S.A.). Lung cancer is believed to be more common among persons who were cigarette smokers and were exposed to significant amounts of asbestos fibers in various workplaces (mines, mills, factories, and shipyards). Two determining factors seem to be related to the probability of developing these diseases:

The amount and duration of exposure - persons exposed frequently

over a long period of time are more at risk, making it important to minimize exposures.

Whether or not one smokes cigarettes - the first thing a smoker should do to reduce their risk of developing lung cancer is to stop smoking.

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How Does One Avoid Unnecessary Asbestos Exposure? Asbestos is a naturally occurring mineral and is ubiquitous in our natural environment, including the soil, water and air. As such, it is impossible to achieve zero exposure, but it is possible to minimize unnecessary exposure.

Because one cannot tell if products contain asbestos just by looking at them: Be aware of the clients Asbestos Exposure procedures if there is any

potential for exposure Assume that asbestos is always present and do not damage it. Never

break, saw, cut, hammer, drill, damage, disturb or move any ACM or suspect materials.

If you discover some ACM has been knocked off insulation, this would be considered a "spill". "Spills" of fiber to work areas when the insulation is not labeled as non-asbestos are to be treated as Asbestos pending receipt sample/testing results.

Personnel are to be removed from the effected site and the area is to be barricaded with RED tape. Then notify your supervisor.

The Supervisor must immediately notify the clients of the incident. If insulation is found on workers in the immediate area, their clothing is

to be covered with disposable coveralls, hands/face washed and then they must be transported to the Asbestos Decon Unit of the local facility.

A qualified lab will test the insulation as soon as possible. If the insulation contains Asbestos, only the qualified Abatement Contractor's personnel are allowed into the area to clean.

If the insulation sample(s) contain asbestos, personal clothing must be disposed of as contaminated waste.

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4 TRAINING

All affected employees will participate in the Companies Asbestos Awareness Safety Training program. All affected employees will be trained prior to the time of initial job assignment and at least annually.

5 REFERENCE

29 CFR 1926.1101 – OSHA‘S Asbestos Standard for the Construction Industry

6 APPENDICES

None

LEAD AWARENESS

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1 PURPOSE AND SCOPE

Purpose

The purpose of Lead Awareness is to inform all Becht employees of the hazards of Lead. To describe what Lead is, adverse health effects and how to avoid it.

Scope

This procedure applies to all Becht personnel working on projects where Lead exposure control requirements are applicable.

2 GENERAL

Definitions

None

Responsibilities

Management Responsible for implementing, maintaining & monitoring

effectiveness of the entire Lead awareness program. The Company Safety Manager Responsible for including annual revisions and updates to reflect

the current status of the program.

Advisors Responsible for providing continuous control over operations and

inform management of any deficiencies.

Employees Responsible for the following:

1. follow all operational and Lead safety procedures 2. seek immediate supervisor guidance to resolve questions 3. conduct operations in accordance with Company provided

training 4. Immediately report to a supervisor any potential exposures.

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3 PROCEDURE

What is Lead?

Pure lead (Pb) is a heavy metal at room temperature and pressure and is a basic chemical element. It can combine with various other substances to form numerous lead compounds. The Permissible Exposure Limit (PEL) set by OSHA is 50 micrograms of lead per cubic meter of air (50 ug/m(3)), averaged over an 8-hour workday. The employer must provide lunch room, hygiene, shower, and changing facilities for employees with potential for exposure to lead. Warning signs should be posted in the work area where the PEL is exceeded.

Lead can be absorbed by inhalation (breathing) and ingestion (eating). Lead is not absorbed through your skin. When lead is scattered in the air as a dust, fume or mist it can be

inhaled and absorbed through the lungs and upper respiratory tract. Lead can also be absorbed through the digestive system if swallowed.

Handling food, cigarettes, chewing tobacco, or make-up which has lead contamination or handling them with hands contaminated with lead, will contribute to ingestion.

A significant portion of inhaled or ingested lead goes into the blood stream. Once in the blood stream, lead is circulated throughout the body and

stored in various organs and body tissues. Some of this lead is quickly filtered out of the body and excreted, but

some remains in the blood and other tissues. As exposure to lead continues, the amount stored in the body will

increase. Lead stored in body tissues can cause irreversible damage, first to individual cells, then to organs and whole body systems.

***NOTE*** No Becht employee is authorized to work on any equipment which may contain Lead. All work involving Lead will be abated by the facility prior to our work beginning. This program is provided simply as general awareness program.

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Personal Protective Equipment Gloves, hats, vented goggles, shoes or disposable shoe covers shall be provided. Protective clothing shall be cleaned and laundered at least weekly, properly disposed and repaired or replaced as necessary. A respirator shall be used during the time period necessary to install or implement engineering or work practice controls, where engineering and work practice controls are insufficient and in emergencies. Monitoring Medical examinations & procedures shall be performed by or under the supervision of a licensed physician. The medical surveillance is provided without cost to the employees. The blood sampling & monitoring should be conducted every 6 months until two consecutive blood samples & analysis are acceptable. The sampling & monitoring should be performed at least monthly during the removal period. Any employee with elevated blood levels should be temporarily removed. Employees should be notified in writing within five days when lead levels are not acceptable. The standard requires temporary medical removal with Medical Removal Protection benefits. Full shift personal samples shall be representative of the employees regular, daily exposure to lead. If the initial determination or subsequent air monitoring reveals employee exposure to be at or above the action level but below the permissible exposure limit the employer shall repeat air monitoring in accordance with this paragraph at least every 6 months. The employer shall continue air monitoring at the required frequency until at least two consecutive measurements, taken at least 7 days apart, are below the action level at which time the employer may discontinue monitoring for that employee. The employer must, within 15 working days after the receipt of the results of any monitoring performed under this section, notify each affected employee of these results either individually in writing or by posting the results in an appropriate location that is accessible to affected employees. Whenever the results indicate that the representative employee exposure, without regard to respirators, exceeds the permissible exposure limit, the employer shall include in the written notice a statement that the permissible exposure limit was exceeded and a description of the corrective action taken or to be taken to reduce exposure to or below the permissible exposure limit. Short-term (acute) effects of overexposure to lead Lead is a potent, systemic poison. Taken in large enough doses, lead can kill in a matter of days. A condition affecting the brain called acute encephalopathy may arise which develops quickly to seizures, coma, and death from cardiorespiratory arrest.

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There is no sharp dividing line between rapidly developing acute effects of lead, and chronic effects which take longer to acquire.

Lead adversely affects numerous body systems, and causes forms of health impairment and disease which arise after periods of exposure as short as days or as long as several years.

Long-term (chronic) effective of overexposure to lead Chronic overexposure to lead may result in severe damage to blood-forming, nervous, urinary and reproductive systems. Some common symptoms of chronic overexposure include loss of

appetite, metallic taste in the mouth, anxiety, constipation, nausea, pallor, excessive tiredness, weakness, insomnia, headache, nervous irritability, muscle and joint pain or soreness, fine tremors, numbness, dizziness, hyperactivity and colic.

In lead colic there may be severe abdominal pain. Signs

Proper signs will be posted at the entrance and exits to all lead hazard areas. No other signs or statements may appear on or near any lead hazard sign which contradicts or detracts from the meaning of the required sign. All lead hazard signs will be kept illuminated and cleaned as necessary so that the legend is readily visible. The signs will contain the following or other appropriate wording/warning:

WARNING LEAD WORK AREA POISON NO SMOKING OR EATING

4 TRAINING

Becht shall communicate information concerning lead hazards according to the requirements of OSHA's Hazard Communication Standard for the construction industry, 29 CFR 1926.59, including, but not limited to, the requirements concerning warning signs and labels, Material Safety Data Sheets (MSDS), and employee information and training.

All affected employees will participate in the Companies Lead Awareness Safety Training program. All affected employees will be trained prior to the time of initial job assignment and at least annually.

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5 REFERENCE

None

6 APPENDICES

None

BLOODBORNE PATHOGENS AWARENESS

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167

EH&S 403

1 PURPOSE AND SCOPE

Purpose

In 1991, OSHA issued the Bloodborne Pathogens Standard to protect workers from this risk of exposure. In 2001, in response to the Needlestick Safety and Prevention Act, OSHA revised the Bloodborne Pathogens Standard, 29 CFR 1910.1030. The revised standard clarifies the need for employers to select safer needle devices and to involve employees in identifying and choosing these devices. The updated standard also requires employers to maintain a log of injuries from contaminated sharps.

Scope

OSHA‘s 29 CFR 1910.1030 standard was promulgated to cover all employees who could "reasonably anticipate" to face contact with blood and other potentially infectious materials while performing their job duties are covered by the standard. Becht employees are not covered by OSHA‘s 29 CFR 1910.1030 standard, but are given awareness training to avoid any exposure.

2 GENERAL

The Occupational Safety and Health Administration promulgated the standard to eliminate or minimize occupational exposure to bloodborne pathogens. OSHA has made a determination that employees face a significant health risk as the result of occupational exposure to blood and other potentially infectious materials because they may contain bloodborne pathogens. The Agency further concludes that this exposure can be minimized or eliminated using a combination of engineering and work practice controls, personal protective clothing and equipment, training, medical surveillance, Hepatitis B vaccination, signs and labels, and other provisions. Workers in many different occupations are at risk of exposure to bloodborne pathogens, including Hepatitis B, Hepatitis C, and HIV/AIDS. Bloodborne pathogens are bacteria and viruses that are transmitted by contact with human blood and other potentially infectious materials (such as semen, vaginal secretions) from an infected person. This exposure may be through needlesticks, sharps injuries, mucous membranes, and skin exposures. First aid team members, housekeeping personnel in some settings, and nurses are examples of workers who may be at risk of exposure. Workers and employers are urged to take advantage of


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available engineering controls and work practices to prevent exposure to blood and other body fluids. If you encounter any of the above, report it to your supervisor. You cannot tell by looking at someone if he/she is infected; therefore these guidelines apply to ALL human blood in ALL situations. If hand-washing facilities are not available, then Becht shall provide either an appropriate antiseptic hand cleanser in conjunction with cloth/paper towels or antiseptic towelettes. Becht Engineering shall ensure that a copy of the Exposure Control Plan is accessible to employees in accordance with 29 CFR 1910.1020(e). When the possibility of occupational exposure is present, PPE (e.g., gloves, gowns) will be provided at no cost to the employee. PPE shall be used unless Becht Engineering shows that employees temporarily declined to use PPE under rare circumstances. Becht Engineering shall ensure that appropriate PPE in the appropriate sizes is readily accessible. PPE shall be cleaned, laundered and properly disposed. Becht Engineering shall repair and replace PPE as needed to maintain its effectiveness. Hepatitis B vaccine will be made available to all employees who have occupational exposure at no cost to the employee(s).

Routes of occupational transmission: Puncture or cut with a contaminated sharp object (such as a needle

or broken glass) Splash to the mucous membranes of the eyes, nose or mouth Contact with broken skin.

Disposal of potentially infectious material:

All equipment or environmental surfaces shall be cleaned & decontaminated after contact with blood or other infectious materials.

Specimens of blood or other potentially infectious materials must be put in leak proof bags for handling, storage and transport.

Definitions

None

Responsibilities

Non-applicable


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3 PROCEDURE

Not applicable.

4 TRAINING

Properly training workers and providing information is one of the components of OSHA's Bloodborne Pathogen Standard. Employees must receive training when they are first assigned to tasks where occupational exposure to bloodborne pathogens may occur. The training must be repeated annually, and must be provided at no cost to the employees and during work hours. Employees must receive additional training when changes occur that affect the employees' occupational exposure, such as task or procedural modifications or the institution of new tasks or procedures. This additional training only needs to address new exposures created. The employer shall establish and maintain an accurate record for each employee with occupational exposure in accordance with CFR 1910.1020. Training records will include the following: Dates and Contents of Training, Names and Job Titles of persons attending. Training records shall be maintained for 3 years from the date of training and medical records shall be maintained for at least the duration of employment plus 30 years. The employer shall ensure that all records required by this section shall be made available upon request of employees, Assistant Secretary & the Director for examination & copying. Medical records must have written consent of employee before released. The employer shall comply with the requirements involving transfer of records set forth in 29 CFR 1910.1020(h).

5 REFERENCE

OSHA‘s 29 CFR 1910.1030

6 APPENDICES

None

BENZENE AWARENESS

170

EH&S 404

1 PURPOSE AND SCOPE

Purpose

The purpose of Benzene Awareness is to inform all Becht employees of the hazards of Benzene. To describe what Benzene is, adverse health effects and how to avoid it.

Scope

This procedure applies to all Becht personnel working on projects where Benzene exposure control requirements are applicable.

2 GENERAL

Benzene is an organic chemical compound sometimes known as benzol. It has a particularly sweet smell and is a colorless, flammable liquid. Benzene is a major industrial solvent and is used in the production process of plastic, oil, synthetic rubber and many dyes. The scientist Michael Faraday discovered benzene in 1825. He separated it from oil gas and called it bicarburet of hydrogen. It is produced naturally in forest fires and volcanoes. It is a carcinogen and a major component in cigarette smoke. Until the Second World War, benzene was manufactured as a by-product of coal production, mainly in the steel industry. In the 1950s, there was a growing demand for benzene, especially from the plastics industry. Out of this need, manufacturers began producing benzene from petroleum. Most of today‘s benzene supply comes from the petrochemical industry, with only a small amount obtained from coal. Benzene liquid is highly flammable and vapors may form explosive mixtures in air. Fire extinguishers must be readily available. Smoking is prohibited in areas where Benzene is used or stored.

***NOTE*** No Becht employee is authorized to work on any equipment which may contain Benzene. All work involving Benzene will be removed by the facility prior to our work beginning. This program is provided simply as general awareness program. However, employees need to be aware of the provisions of the site specific contingency/emergency plans.

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Benzene is a chemical with many uses. Because of its sweet smell, it was used as an aftershave in the 19th century. Before the 1920s, it was used regularly as an industrial solvent. This was before people became aware of the dangers of its toxicity. It was once widely used as an additive to gasoline, but this practice was also abandoned due to health concerns. Benzene is mostly commonly used as an additive to other chemicals. It is used to make styrene, which is used to make plastics and polymers, and in the manufacturing process of nylon. Small amounts of benzene are used in the manufacturing processes of drugs, detergents, pesticides and explosives. EXPOSURE Exposure to benzene can have very serious health effects. High levels of exposure can cause breathing disorders, dizziness, drowsiness, headaches, and nausea. If one were to eat food or drink liquid containing benzene, a rapid heart rate, vomiting and stomach irritation may result. Very high levels of exposure to benzene can ultimately lead to death. There are tests that can be performed to show whether a person has been exposed to the chemical. Benzene can be measured by a breath or blood test. Both these tests must be performed shortly after exposure, as the chemical disappears very quickly from the body. In the United States, the maximum amount of benzene permissible in water is 0.005 milligrams per liter.

3 PROCEDURE

PPE Requirements Respirators: <0.5 ppm benzene - No respiratory protection required 0.5 - 5 ppm benzene - Half face respirator with organic vapor cartridge 5 ppm - 25 ppm benzene - Full face respirator with organic vapor

cartridge >25 ppm benzene or when concentrations are unknown - Supplied air

respirator (hoseline with escape bottle or SCBA)

NOTE: Workers must be fit tested, physically qualified, and trained prior to using a half or full face respirator and fit tested annually thereafter.

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Skin Protection For streams less than 5% benzene, use Nitrile or Neoprene/Nitrile

gloves. For streams more than 5% benzene, use Viton or Teflon gloves. Benzene-resistant clothing and rubber boots shall be worn when skin

contact is probable. This requirement does not apply when catching samples at sample points that have been specifically designed to catch benzene samples.

Eye/Face Protection

Chemical goggles and face shields when contact with liquids containing < 5ppm benzene is possible.

Decontamination Requirements

Wash contaminated skin immediately with soap and water. Immediately remove contaminated work clothes and wash separately. In the event of an emergency or uncontrolled release, workers

exposed to benzene via inhalation or skin contact with liquids containing > 0.1% benzene must undergo OSHA required medical screening as soon as possible, but before the end of the shift.

4 TRAINING

All affected employees will participate in the Company‘s Benzene Awareness Safety Training program. All affected employees will be trained prior to the time of initial job assignment and at least annually. For workers who are potentially exposed to over 0.5 ppm (8-hour TWA) benzene, annual Benzene Hazard Awareness Training covering the following topics is required: Location of benzene containing streams and equipment. Recognizing and measuring benzene. Health effects, routes of entry, and signs of exposure. Regulated work areas. Respiratory and skin protection. Medical monitoring. OSHA Benzene Standard.

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5 REFERENCE

None

6 APPENDICES

None

COMPRESSED GAS CYLINDER

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FOR INFORMATION PURPOSES ONLY THIS PROCEDURE IS NOT RELATIVE TO PROVIDED SERVICES

1 PURPOSE AND SCOPE

Purpose

This procedure provides the guidelines to ensure adequate safety to personnel when working with or around compressed gases.

Scope

This procedure applies to all Becht Engineering personnel and subcontractors working on projects where handling of compressed gas requirements is applicable.

2 GENERAL

Cylinders containing compressed gases at high pressures are designed to comply with strict government specifications. However, intentional misuse and/or abuse of the cylinders can result in a potential hazardous situation. The safe handling, storage, and use of compressed gases whenever facility personnel work with or around compressed gas cylinders ensure a hazard free condition.

Definitions

Asphyxiate: A gas or an agent that produces a decrease of oxygen and increase of the carbon dioxide level in the blood stream. Flammable Gas: A gas that is flammable when mixed with air in concentrations of 13 percent or less by volume in air. Inert Gas: A gas that is a simple asphyxiate, which displaces oxygen in the air necessary to sustain life. Inert gases can cause rapid suffocation due to a resultant oxygen deficiency. Small Compressed Gas Cylinder: A cylinder having a maximum water capacity of 1000 lb. (i.e., 120 gallons) or less.


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NFPA: National Fire Protection Association

Internal Reverse Flow Check Valves: Reduce the possibility of explosion or fire, which may occur as a result of fuel gases, and oxygen becoming mixed inside the hose or regulators. It is not intended to act as a fire stop! Flashback Arrestors: designed to prevent a flashback from reaching upstream equipment. They are installed between the outlet of the regulator and the inlet of the hose leading to the torch and between the hose and the torch.

Responsibilities

The Manager/Supervisor Responsible for implementing and enforcing this procedure.

The Safety Representative Responsible for monitoring compliance with this procedure.

3 PROCEDURE

Compressed Gas Cylinder Storage

All compressed gas cylinders shall be stored in an upright position.

Cylinders shall be secured by a chain to ensure that they will not be accidentally knocked over.

Storage locations shall be well ventilated and ambient room storage

Cylinder storage locations shall be distinctly marked with the names of each compressed gas maintained at the location. NO SMOKING - FLAMMABLE GAS signs shall be posted at all entrances to locations where flammable gases are stored.

Each compressed gas cylinder maintained at a storage location shall be labeled with proper identification of its contents.

All cylinders in storage shall require valve protection caps at all times except when the cylinder contents are being dispensed.


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Storage locations for oxidizing gas (i.e., oxygen) and flammable gas (e.g., acetylene) cylinders shall maintain a minimum distance of 20 ft to separate the oxidizing and flammable gas cylinders or by a non combustible barrier at least 5 feet high having a fire resistance rating of at least one-half hour.

Cylinder storage areas containing flammable gases shall be stored to avoid contact with a possible ignition source. Walls of the storage area shall have a fire rating resistance of at least 1 hour, and doors shall be in accordance with NFPA 80.

Flammable gas storage areas shall be heated by indirect means (i.e., steam or hot water).

Electrical equipment within a flammable storage area shall be in accordance with NFPA 70.

Portable fire extinguishers consisting of carbon dioxide and/or dry chemical shall be available at the storage locations.

Transporting Compressed Gas Cylinders

Compressed gas cylinders shall never be rolled, slid, or dragged from one location to another.

To transport cylinders, only a weight approved dolly (i.e., hand truck) shall Subtitle (use T4 style) be used to allow the cylinder to be moved in a secured upright position.

All pressure regulators shall be removed, and valve protection caps shall be installed prior to moving any cylinders.

Handling Compressed Gas Cylinders

Compressed gas cylinders shall not be used in areas where the cylinder tank may come in contact with any sparks or flames.

Compressed gases contained within a cylinder are under extremely high pressure. Therefore, whenever gas is to be withdrawn from a cylinder, pressure-reducing valves shall be used. Under no circumstances is gas to be removed from a cylinder without the use of a pressure reducing valve.

All cylinder connections, hoses, valves, etc., shall be inspected prior to using the compressed gas cylinder. All connections shall be tight with no leaks. The damaged and/or deteriorated cylinder, valves, couplings, hoses, etc., shall not be used.


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When opening cylinder valves, gas outlets shall always be pointed away from the user and any other facility personnel standing in the immediate usage area.

All cylinder valves shall be opened slowly using only approved wrenches for the cylinder as provided by the supplier.

NOTE: When using a compressed gas cylinder, the operating wrench shall remain on the cylinder valve at all times

All compressed gas-cylinder valves, couplings, hoses, etc., shall not be lubricated or allowed to come in contact with oil and/or grease.

Torch handles can be purchased with flashback arrestors built-in, or flashback arrestors shall be added if not equipped.

Separate flashback arrestors must be added to the regulators.

Only experienced and properly trained persons shall use compressed gases

Cylinders of compressed gases shall not be placed in areas where there may be is oil and/or grease nor handled with oily and/or greasy hands.

After each use of a compressed gas, the cylinder valve shall be fully closed and all gas remaining in the regulator valve shall be slowly purged. The regulator valve shall be removed, the cylinder valve cap shall be installed, and the cylinder tank shall be removed from the work area and returned to its proper storage location.

If the contents of a compressed gas cylinder are depleted, the cylinder valve shall be fully closed, and the valve protection cap shall be reinstalled. The cylinder tank shall be appropriately marked with an EMPTY TANK, sign and the tank shall be stored in a secured upright position.

4 TRAINING

None


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5 REFERENCES

Compressed Gas Association, Inc. Handbook of Compressed Gases, 3rd Edition, 1990, Van Nostrand Reinhold.

National Fire Protection Association 51, Standard for the Design and Installation of Oxygen-Fuel Gas Systems for Welding, Cutting and Allied Processes.

National Fire Protection Association 80, Standard for Fire Doors and Windows.


6 APPENDICES

None

MOBILE EQUIPMENT SAFETY

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1 PURPOSE AND SCOPE

Purpose

This procedure provides the requirements for the safe operation of mobile equipment.

Scope

This procedure applies to all Becht Engineering personnel and subcontractors working on projects where mobile equipment safety requirements are applicable.

2 GENERAL

Definitions

Heavy Equipment: Mobile equipment used for or designed for earthmoving. Examples include crawler or wheel tractors, bulldozers, off-highway trucks, graders, loaders, cranes, agricultural and industrial tractors, and similar equipment. This definition does not include industrial trucks. Industrial Trucks: Mobile equipment, other than heavy equipment, used for lifting, carrying and stacking loads on the front of the vehicle. Examples include forklifts, stackers and similar equipment. Mobile Equipment: Self-propelled vehicles that operate within an off-highway jobsite, not open to public traffic.

Responsibilities

The Senior Becht Advisor: Responsible for ensuring that company owned, leased or rented equipment is in serviceable condition and competently manned to afford safe operation at all times. The Senior Becht Advisor responsible for implementing and enforcing this procedure.


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Subcontractors: Responsible for providing all necessary documentation of inspections for the previous year for any mobile equipment brought to the site and certifying that the equipment meets applicable OSHA standards and this program. Subcontractor operators shall provide documentation of mobile equipment operation training or other documentation acceptable to the Safety Representative.

PROCEDURE

Safety Inspection and Maintenance

The operator shall perform a documented inspection on vehicles or equipment daily prior to use and report any unsafe conditions. Unsafe conditions will cause the vehicles or equipment to be taken out of service until corrected.

Fire extinguishers shall be placed on all vehicles or equipment and inspected monthly. Monthly inspection and service records will be filed in the project office.

All safety items on vehicles and equipment shall be inspected and serviced regularly by a qualified mechanic, either on or off the project site.

These items include but not limited to:

Vehicles:

Adequate vision (mirrors, windshield, etc.), windshield wipers, and blades

Brakes – including emergency brakes

Fan belts

Headlights

Tail lights

Brake lights

Signal lights

Hydraulic lifts

Power steering

Tires – including spare

Adequate jacks and lug wrench

Horn

Air equipment

Seat belts


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Equipment:

Adequate vision (mirrors, windshields, etc.)

Windshield wipers and blades

Horn or warning bell (as required)

Air equipment

Lights - front, rear, stop, boom, etc.

Emergency brakes, including winch brakes, etc.

Generator, starter, etc.

Booms, welds, bolts, etc.

Hydraulic hoses, couplings, pumps

Fan belts

Operation of Vehicles

Only trained and certified/licensed operators shall operate company-owned, leased, or rented vehicles.

All operators shall be required to obey all city, county, or state motor vehicle laws.

Industrial trucks shall be examined before being placed in service, and shall not be placed in service if the examination shows any condition adversely affecting the safety of the vehicle. Such examination shall be made at least daily. Where industrial trucks are used on a round-the-clock basis, they shall be examined after each shift. Defects when found shall be immediately reported and corrected.

City, county, or state safety inspection of vehicles, when required, shall be obtained and decals posted on vehicles.

Company-owned or -leased equipment shall not be used off the project except for company business or as approved by senior management.

Persons not employed by the company shall not operate or ride as passengers in company owned, leased, or rented equipment.

Equipment shall not be driven into unsafe areas of construction where unnecessary tire, steering, or body damage could result.

Personnel shall not be allowed to ride on running boards or tailgates, or allow parts of body to protrude from vehicle or equipment.

The brakes of highway trucks shall be set and wheel chocks placed under the rear wheels to prevent the trucks from rolling while they are boarded with powered industrial trucks. Positive protection shall be


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provided to prevent railroad cars from being moved while dockboards or bridge plates are in position.

Vehicles or equipment used to transport explosives, gasoline, fuel oils, or other flammable or combustible material shall not haul passengers.

Smoking will not be allowed on, in or within 50 ft of vehicles hauling fuel oils, gasoline, diesel fuel, or explosives.

Over-the-road vehicles that are required to keep Interstate Commerce Commission (ICC) logs shall do so per ICC regulations.

Use of alcoholic beverages, drugs, (including No-Doze and No-Sleep tablets) shall not be tolerated while operating company-owned, -leased, or -rented vehicles.

All vehicles/equipment transporting material shall comply with city, county, or state laws pertaining to weight, height, length, and width. Permits are mandatory if required by city, county, or state.

Operation of Equipment:

Only qualified/certified/trained personnel shall be allowed to operate company-owned, -leased, or -rented equipment.

All equipment operators shall have a valid driver‘s license.

Aerial lifts may be "field modified" for uses other than those intended by the manufacturer provided the modification has been certified in writing by the manufacturer or by any other equivalent entity, such as a nationally recognized testing laboratory, to be in conformity with all applicable provisions of ANSI A92.2-1969 and this section, and to be at least as safe as the equipment was before the modification.

Lift controls shall be tested before each shift prior to use to determine that such controls are in safe working condition.

Boom and basket load limits specified by the manufacturer shall not be exceeded.

The mobile equipment must not have an obstructed view to the rear, unless: The vehicle has a reverse signal alarm audible above the surrounding noise level; Or, the vehicle is backed up only when an observer signals that it is safe to do so.

When working near energized lines or equipment, aerial lift trucks shall be grounded or barricaded and considered as energized equipment, or the aerial lift truck shall be insulated for the work being performed. For lines rated 50kV or below, minimum clearance


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between the lines and any part of the equipment or load shall be at least 10 feet.

Employees shall always stand firmly on the floor of the basket, and shall not sit or climb on the edge of the basket or use planks, ladders, or other devices for a work position.

An approved fall restraint system shall be worn when working from an aerial lift. The fall restraint system shall be attached to the boom or basket when working from an aerial lift and is not permitted to be attached to adjacent poles or structures.

Cranes Operator Requirements (for information only, Becht Engineering staff are PROHIBITED from operating cranes) Candidates must pass:

Medical Criteria:

Pass a DOT CDL Physical by a licensed Physician.

Submit to a drug screen / Pre-hire/Post incident/ random/ annually per Becht Engineering Policy.

The Written Examination:

Category 1 Operators – Equipment tests are classified into 5 Types and candidates must take all types up to the largest to be qualified. (Progressive written test)

Category 2 Operators - Specialty Equipment

Practical Exam

Practical Exams are done for each specific type piece equipment

Recertify annually or whenever deemed necessary for retraining.

Carry a Becht Engineering certification card at all times while operating.

Operators other than hook equipment requirements

Pass a DOT CDL Physical by a licensed Physician.



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Pass Becht Engineering training test written and practical annually or whenever deemed necessary for retraining.


Aerial Lifts


Pass Becht Engineering training test written and practical annually or whenever deemed necessary for retraining.


Proof of Testing

Operator Cards shall be issued for to all operators as proof of testing and that Becht Engineering has certified that operator for the equipment.

Equipment operator cards can only be issued by approved competent personnel QUALIFIED to certify operators for Becht Engineering.

Subcontractor Vehicles and Equipment

The subcontractor shall notify the Senior Becht Advisor, and Safety Representative of all mobile equipment to be brought onsite. No unsafe vehicles or equipment shall be allowed in construction areas. Equipment not in compliance shall be reported to the Manager or designee immediately.

Subcontractor employees shall follow this procedure for the operation, inspection, and maintenance of vehicles and equipment.

All Becht Engineering supervisors shall visually inspect and observe the vehicles and equipment of subcontractors and stop any unsafe condition or practices. Equipment not in compliance with applicable safety standards shall not be permitted to operate.

Items Most Frequently Not Reported

Dents from minor accidents and broken, cracked, or pitted windshields (from another vehicle throwing or dropping material) are reportable accidents. In most cases, the damages could be paid by


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the other vehicle's liability insurance. All accidents should be reported.

Damages caused by accidental contact with paint, tar, etc., on vehicles or equipment are often not reported.

Driving vehicles over terrain causes extensive damage to front end alignment, rear axles, steering mechanism, undercarriage, tires, and wheels. No insurance coverage is available but these vehicles are not safe for highway travel in most cases. Common sense driving can and will reduce this unnecessary damage.

Speeding is a major hazard. Work areas are congested, and every person operating a vehicle shall drive at a reasonable and prudent speed considering the conditions.

Compliance with all site, city, county, and state speed limits shall be mandatory.

Site Controls

Each site shall establish controls for employees entering into areas where heavy equipment high traffic is present.

High visibility vest shall be worn by everyone in construction areas during initial site prep dirt work, during periods of congested / high traffic heavy equipment work or deemed necessary by management.

On one is allowed access into construction areas alone where heavy equipment is working in high traffic areas.

A spotter shall accompany anyone needing to work in close proximity to high traffic areas.

Or be able to park a truck/vehicle no further than a distance of 2 feet from person.

Or establish equipment exclusion safe zones by perimeter area barricading.

All equipment operators shall be made aware of anyone entering or working in close proximity to their working routes.

4 TRAINING

Training shall consist of a combination of formal instruction (e.g., lecture, discussion, interactive computer learning, video tape, written material), practical


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training (demonstrations performed by the trainer and practical exercises performed by the trainee), and evaluation of the operator's performance in the workplace. All operator training and evaluation shall be conducted by persons who have the knowledge, training, and experience to train truck operators and evaluate their competence. Powered industrial truck operators shall receive initial training in the following topics, except in topics which the employer can demonstrate are not applicable to safe operation of the truck in the employer's workplace:

Distances; Operating instructions, warnings, and precautions for the types of

truck the operator will be authorized to operate; Load capacity; Refueling and/or charging and recharging of batteries; Load stability; Refueling; Ramps and other sloped surfaces that could affect the vehicle‘s

stability;

Refresher training, including an evaluation of the effectiveness of that training, shall be conducted as required to ensure that the operator has the knowledge and skills needed to operate the powered industrial truck safely. Refresher training is required in the following circumstances:

When unsafe operations are observed; Following an accident; If operating a new or different vehicle type; If there are changes in condition;

Operators will be re-evaluated at least every three years.

5 REFERENCES

Code of Federal Regulations, Title 29, Part 1926, Occupational Safety and Health Administration (OSHA), U.S. Department of Labor.

6 APPENDICES

Appendix 1, Equipment Inspection Report


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EQUIPMENT INSPECTION REPORT Date: _____________

Equip. #:

Equip. Owner: Job #: Hour Meter Reading:

MAKE: MODEL: CAPACITY:

TYPE: SERIAL NO. Plant:

JOB LOCATION:

Day Shift Night Shift

Operator’s Name:

Mark each box with D, R, S, N/A Deficient:

Repair:

Satisfactory:

Equipment Safety Requirements

General: Systems Check

Back – up alarm Engine System

Safety Decals Cooling System ( Hoses, Water) Load Charts Air Induction System

Operator‘s Manual Fuel System

Seat Belt / Seat Bar Electrical Systems

Horn Exhaust System

Brakes Hydraulic System

Parking Brake Frame / Sheet Metal

Tires – Wear Mast Assembly Grab Handles Front Drive Axle

Steps, Access / Non-Skid Steering Axle Gauges/Switches/Electrical Transmission

Lights / Beacon Control Levers

Glass

Operator‘s Seat

Engine Shut Down

Steering

Fire Extinguisher Mirrors

Electrical Connections

Roll Over Protection

Falling Object Protection

Keys

Returned to Vendor

Awaiting Repairs

Tagged Out

Comments:

Supervisor Audit, Name: Date

APPENDIX 1 – EQUIPMENT INSPECTION REPORT

SCAFFOLD AND LADDER SAFETY

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FOR INFORMATION PURPOSES ONLY

THIS PROCEDURE IS NOT RELATIVE TO PROVIDED SERVICES

BECHT ENGINEERING STAFF PROHIBITED FROM ENGAGING IN ASSOCIATED ACTIVITIES

1 PURPOSE AND SCOPE

Purpose

This procedure provides the guidelines for erection, use, dismantlement, and storage of scaffolding, ladders and elevated work platforms.

Scope

This procedure applies to all Becht Engineering personnel and subcontractors where scaffold requirements are applicable.

2 GENERAL

The safe and efficient erection, use, dismantling, and storage of scaffolds, ladders and elevated work platforms are considered important objectives in maintaining a safe work environment. Ladders and scaffolds shall be used only for the purpose for which they were designed.

All employees are responsible for fully supporting and strictly adhering to the provisions of this procedure. Employees who observe violations of these requirements are responsible for reporting unsafe conditions or unsafe practices to their supervisor immediately.

Definitions

Adjustable suspension scaffold: a suspension scaffold equipped with a hoist(s) that can be operated by an employee(s) on the scaffold.


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Boatswains' chair: a single-point adjustable suspension scaffold consisting of a seat or sling designed to support one employee in a sitting position.

Competent person: one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.

Contractor: company engaged in installation or removal of scaffolding, ladders and elevated work platforms.

Double pole (independent pole) scaffold: supported scaffold consisting of a platform(s) resting on cross beams (bearers) supported by ledgers and a double row of uprights independent of support (except ties, guys, braces) from any structure.

Tubular welded frame scaffold (fabricated frame scaffold): a scaffold consisting of a platform(s) supported on fabricated end frames with integral posts, horizontal bearers, and intermediate members.

Float (ship) scaffold: a suspension scaffold consisting of a braced platform resting on two parallel bearers and hung from overhead supports by ropes of fixed length.

Form scaffold: means a supported scaffold consisting of a platform supported by brackets attached to formwork.

Lean-to scaffold: a supported scaffold which is kept erect by tilting it toward and resting it against a building or structure.

Mobile scaffold: a powered or non-powered, portable, caster or wheel-mounted supported scaffold.


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Multi-level suspended scaffold: a two-point or multi-point adjustable suspension scaffold with a series of platforms at various levels resting on common stirrups.

Multi-point adjustable suspension scaffold: a suspension scaffold consisting of a platform(s) which is suspended by more than two ropes from overhead supports and equipped with means to raise and lower the platform to desired work levels. Such scaffolds include chimney hoists.

Needle beam scaffold: a platform suspended from needle beams.

Qualified: one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his/her ability to solve or resolve problems related to the subject matter, the work, or the environment.

Self-contained adjustable scaffold: a combination supported and suspension scaffold consisting of an adjustable platform(s) mounted on an independent supporting frame(s) not a part of the object being worked on, and which is equipped with a means to permit the raising and lowering of the platform(s). Such systems include rolling roof rigs, rolling outrigger systems, and some masons' adjustable supported scaffolds.

Shore scaffold: a supported scaffold which is placed against a building or structure and held in place with props.

Single-point adjustable suspension scaffold: a suspension scaffold consisting of a platform suspended by one rope from an overhead support and equipped with means to permit the movement of the platform to desired work levels.

Single-pole scaffold: a supported scaffold consisting of a platform(s) resting on bearers, the outside ends of which are supported on runners secured to a single row


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of posts or uprights, and the inner ends of which are supported on or in a structure or building wall.

Step, platform, and trestle ladder scaffold: a platform resting directly on the rungs of step ladders or trestle ladders.

Stonesetters' multi-point adjustable suspension scaffold: a continuous run suspension scaffold designed and used for stonesetters' operations.

Supported scaffold: one or more platforms supported by outrigger beams, brackets, poles, legs, uprights, posts, frames, or similar rigid support.

Suspension scaffold: one or more platforms suspended by ropes or other non-rigid means from an overhead structure(s).

System scaffold: a scaffold consisting of posts with fixed connection points that accept runners, bearers, and diagonals that can be interconnected at predetermined levels.

Tank builders' scaffold: a supported scaffold consisting of a platform resting on brackets that are either directly attached to a cylindrical tank or attached to devices that are attached to such a tank.

Tube and coupler scaffold: a supported or suspended scaffold consisting of a platform(s) supported by tubing, erected with coupling devices connecting uprights, braces, bearers, and runners.

Two-point suspension scaffold (swing stage): a suspension scaffold consisting of a platform supported by hangers (stirrups) suspended by two ropes from overhead supports and equipped with means to permit the raising and lowering of the platform to desired work levels.


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Responsibilities

The Safety Representative: Responsible for monitoring compliance with this procedure. The Competent Person:

Responsible for the supervision and direction of the erection, movement,

dismantlement or alteration of scaffolds; inspection of scaffold components for visible defects prior to each shift and after each occurrence which could affect a scaffold‘s structural integrity; and other responsibilities as addressed in this procedure.

3 PROCEDURE

The minimum requirements of this procedure, as set forth in the 29 CFR 1926.450-452 and 1926.454 Subpart L - Scaffolds Standard by the Federal Occupational Safety and Health Administration (OSHA), are extensive and therefore must be reviewed by persons responsible for implementing, enforcing, administering, and monitoring the erection, use, dismantlement, and storage of scaffolds and elevated work platforms.

Scaffold Types Not Discussed in this Procedure

The below listed scaffold types are not discussed in this procedure.

For further information, please reference CFR 1926.450 - .452 and .454 of the Subpart L Construction Standard for Scaffolds.

Plasterers', decorators' and large area scaffolds.

Bricklayers' square scaffolds.

Horse scaffolds.

Roof bracket scaffolds.

Outrigger scaffolds (one level).

Pump jack scaffolds.

Ladder jack scaffolds.

Window jack scaffolds.

Crawling boards (chicken ladders).

Multi-point adjustable suspension scaffolds. (a) Stonesetter‘s scaffolds


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(b) Masons‘ scaffolds

Catenary scaffolds.

Repair bracket scaffolds.

Stilts.

Tank builders' scaffolds

General requirements Capacity

Scaffolds shall be designed by a qualified person and shall be constructed and loaded in accordance with that design.

Each scaffold and scaffold component shall be capable of supporting, without failure, its own weight and at least 4 times the maximum intended load applied or transmitted to it.

Direct connections to roofs and floors, and counterweights used to balance adjustable suspension scaffolds, shall be capable of resisting at least 4 times the tipping moment imposed by the scaffold operating at either the rated load of the hoist, or 1.5 (minimum) times the tipping moment imposed by the scaffold operating at the stall load of the hoist, whichever is greater.

Each suspension rope, including connecting hardware, used on non-adjustable suspension scaffolds shall be capable of supporting, without failure, at least 6 times the maximum intended load applied or transmitted to that rope.

Each suspension rope, including connecting hardware, used on adjustable suspension scaffolds shall be capable of supporting, without failure, at least 6 times the maximum intended load applied or transmitted to that rope with the scaffold operating at either the rated load of the hoist, or 2 (minimum) times the stall load of the hoist, whichever is greater.

The stall load of any scaffold hoist shall not exceed 3 times its rated load.

Scaffold Platform Construction

Each platform on all working levels of scaffolds shall be full planked or decked between the front uprights and the guardrail supports as follows:


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(a) Each platform unit (e.g., scaffold plank, fabricated plank, fabricated deck, or fabricated platform) shall be fully decked with no gaps or openings. There shall be no space between adjacent units, and between platforms and adjacent uprights.

(b) The requirement to provide full planking or decking does

not apply to platforms used solely by employees performing scaffold erection or dismantling. In these situations, only the planking that is established as necessary to provide safe working conditions is required.

Except as stated above, each scaffold platform and walkway shall be at least 18inches (46 cm) wide.

(a) There is no minimum width requirement for boatswains'

chairs. (b) Where scaffolds must be used in areas that it can be

demonstrated are so narrow that platforms and walkways cannot be at least 18 inches (46 cm) wide, such platforms and walkways shall be as wide as feasible, and employees on those platforms and walkways shall be protected from fall hazards by the use of guardrails and/or personal fall arrest systems.

The front edge of all platforms shall not be more than 6 inches from the face of the work, unless guardrail systems are erected along the front edge and/or personal fall arrest systems are used to protect employees from falling.

Each end of a platform, unless cleated or otherwise restrained by hooks or equivalent means, shall extend over the centerline of its support at least 6 inches (15 cm).

Each end of a platform 10 feet or less in length shall not extend over its support more than 12 inches (30 cm) unless the platform is designed and installed so that the cantilevered portion of the platform is able to support employees and/or materials without tipping, or has guardrails which block employee access to the cantilevered end.


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Each platform greater than 10 feet in length shall not extend over its support more than 18 inches (46 cm), unless platform is designed and installed so that the cantilevered portion of the platform is able to support employees and/or materials without tipping, or has guardrails which block employee access to the cantilevered end.

On scaffolds where scaffold planks are abutted to create a long platform, each abutted end shall rest on a separate support surface. This provision does not preclude the use of common support members, such as "T" sections, to support abutting planks, or hook on platforms designed to rest on common supports.

On scaffolds where platforms are overlapped to create a long platform, the overlap shall occur only over supports, and shall not be less than 12 inches (30 cm) unless the platforms are nailed together or otherwise restrained to prevent movement.

At all points of a scaffold where the platform changes direction, such as turning a corner, any platform that rests on a bearer at an angle other than a right angle shall be laid first, and platforms which rest at right angles over the same bearer shall be laid second, on top of the first platform.

Wood platforms shall not be covered with opaque finishes, except that platform edges may be covered or marked for identification. Platforms may be coated periodically with wood preservatives, fire-retardant finishes, and slip-resistant finishes; however, the coating may not obscure the top or bottom wood surfaces.

All wood platforms should be treated with fire-retardant finishes so as to reduce the risk of fire from ―hot work‖ operations.

Scaffold components manufactured by different manufacturers shall not be intermixed or modified except as allowed by the manufacturer of that equipment.

Scaffold components made of dissimilar metals shall not be used together unless a competent person has determined that galvanic action will not reduce the strength of any component


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Criteria for Supported Scaffolds

Supported scaffolds with a height to base width (including outrigger supports, if used) ratio of more than four to one (4:1) shall be restrained from tipping by guying, tying, bracing, or equivalent means, as follows:

(a) Guys, ties, and braces shall be installed at locations

where horizontal members support both inner and outer legs.

(b) Guys, ties, and braces shall be installed according to the scaffold manufacturer's recommendations or at the closest horizontal member to the 4:1 height and be repeated vertically at locations of horizontal members every 20 feet (6.1 m) or less thereafter for scaffolds 3 feet (0.91 m) wide or less, and every 25 feet or less thereafter for scaffolds greater than 3 feet (0.91 m) wide. The top guy, tie or brace of completed scaffolds shall be placed no further than the 4:1 height from the top. Such guys, ties and braces shall be installed at each end of the scaffold and at horizontal intervals not to exceed 30 feet (9.1 m) (measured from one end [not both] towards the other).

(c) Ties, guys, braces, or outriggers shall be used to prevent the tipping of supported scaffolds in all circumstances where an eccentric load, such as a cantilevered work platform, is applied or is transmitted to the scaffold.

(d) A qualified person shall determine the structural integrity of steel, reinforcing steel, and concrete or building members prior to the attachment of scaffold ties, guys, or bracing.

Supported scaffold poles, legs, posts, frames, and uprights shall bear on base plates, mud sills or other adequate firm foundation. Mudsills when used shall be constructed of 2 x 10 in. lumber.

(a) Footings shall be level, sound, rigid, and capable of

supporting the loaded scaffold without settling or displacement.

(b) Unstable objects shall not be used to support scaffolds or platform units.


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(c) Unstable objects shall not be used as working platforms.

Supported scaffold poles, legs, posts, frames, and uprights shall be plumb and braced to prevent swaying and displacement.

When screw jacks are used, they shall be used in accordance to manufacturer‘s recommendations but shall not be extended in excess of 12 in. in height.

Criteria for Suspension Scaffolds

All suspension scaffold support devices, such as outrigger beams, cornice hooks, parapet clamps, and similar devices, shall rest on surfaces capable of supporting at least 4 times the load imposed on them by the scaffold operating at the rated load of the hoist (or at least 1.5 times the load imposed on them by the scaffold at the stall capacity of the hoist, whichever is greater).

Suspension scaffold outrigger beams, when used, shall be made of structural metal or equivalent strength material, and shall be restrained to prevent movement.

The inboard ends of suspension scaffold outrigger beams shall be stabilized by bolts or other direct connections to the floor or roof deck, or they shall have their inboard ends stabilized by counterweights.

Before the scaffold is used, direct connections shall be evaluated by a competent person who shall confirm, based on the evaluation, that the supporting surfaces are capable of supporting the loads to be imposed.

(a) Counterweights shall be made of non-flowable material.

Sand, gravel and similar materials that can be easily dislocated shall not be used as counterweights.

(b) Only those items specifically designed as counterweights shall be used to counterweight scaffold systems. Construction materials such as, but not limited to, masonry units and rolls of roofing felt, shall not be used as counterweights.


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(c) Counterweights shall be secured by mechanical means to the outrigger beams to prevent accidental displacement.

(d) Counterweights shall not be removed from an outrigger beam until the scaffold is disassembled.

(e) Outrigger beams which are not stabilized by bolts or other direct connections to the floor or roof deck shall be secured by tiebacks.

(f) Tiebacks shall be equivalent in strength to the suspension ropes.

(g) beams shall be placed perpendicular to its bearing support (usually the face of the building or structure). However, where it can demonstrate that it is not possible to place an outrigger beam perpendicular to the face of the building or structure because of obstructions that cannot be moved, the outrigger beam may be placed at some other angle, provided opposing angle tiebacks are used.

(h) Tiebacks shall be secured to a structurally sound anchorage on the building or structure. Sound anchorages include structural members, but do not include standpipes, vents, other piping systems, or electrical conduit.

(i) Tiebacks shall be installed perpendicular to the face of the building or structure, or opposing angle tiebacks shall be installed. Single tiebacks installed at an angle are prohibited.

Suspension scaffold outrigger beams shall be:

(a) Provided with stop bolts or shackles at both ends; (b) Securely fastened together with the flanges turned out

when channel iron beams are used in place of I-beams; (c) Installed with all bearing supports perpendicular to the

beam center line; (d) Set and maintained with the web in a vertical position;

and (e) When an outrigger beam is used, the shackle or clevis

with which the rope is attached to the outrigger beam shall be placed directly over the center line of the stirrup.


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Suspension scaffold support devices such as cornice hooks, roof hooks, roof irons, parapet clamps, or similar devices shall be:

(a) Made of steel, wrought iron, or materials of equivalent

strength; (b) Supported by bearing blocks; and (c) Secured against movement by tiebacks installed at right

angles to the face of the building or structure, or opposing angle tiebacks shall be installed and secured to a structurally sound point of anchorage on the building or structure. Sound points of anchorage include structural members, but do not include standpipes, vents, other piping systems, or electrical conduit.

(d) Tiebacks shall be equivalent in strength to the hoisting rope.

When winding drum hoists are used on a suspension scaffold, they shall contain not less than four wraps of the suspension rope at the lowest point of scaffold travel. When other types of hoists are used, the suspension ropes shall be long enough to allow the scaffold to be lowered to the level below without the rope end passing through the hoist, or the rope end shall be configured or provided with means to prevent the end from passing through the hoist.

The use of repaired wire rope as suspension rope is prohibited.

Wire suspension ropes shall not be joined together except through the use of eye splice thimbles connected with shackles or coverplates and bolts.

The load end of wire suspension ropes shall be equipped with proper size thimbles and secured by eyesplicing or equivalent means.

Ropes shall be inspected for defects by a competent person prior to each work shift and after every occurrence which could affect a rope's integrity. Ropes shall be replaced if any of the following conditions exist:

(a) Any physical damage which impairs the function and

strength of the rope.


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(b) Kinks that might impair the tracking or wrapping of rope around the drum(s) or sheave(s).

(c) Six randomly distributed broken wires in one rope lay or three broken wires in one strand in one rope lay.

(d) Abrasion, corrosion, scrubbing, flattening or peening causing loss of more than one-third of the original diameter of the outside wires.

(e) Heat damage caused by a torch or any damage caused by contact with electrical wires.

(f) Evidence that the secondary brake has been activated during an overspeed condition and has engaged the suspension rope.

Swaged attachments or spliced eyes on wire suspension ropes shall not be used unless they are made by the wire rope manufacturer or a qualified person.

When wire rope clips are used on suspension scaffolds:

(a) There shall be a minimum of 3 wire rope clips installed, with the clips a minimum of 6 rope diameters apart.

(b) Clips shall be installed according to the manufacturer's recommendations.

(c) Clips shall be retightened to the manufacturer's recommendations after the initial loading.

(d) Clips shall be inspected and retightened to the manufacturer's recommendations at the start of each work shift thereafter.

(e) U-bolt clips shall not be used at the point of suspension for any scaffold hoist.

(f) When U-bolt clips are used, the U-bolt shall be placed over the dead end of the rope, and the saddle shall be placed over the live end of the rope.

Suspension scaffold power-operated hoists and manual hoists shall be tested and listed by a qualified testing laboratory.

Gasoline-powered equipment and hoists shall not be used on suspension scaffolds.

Gears and brakes of power-operated hoists used on suspension scaffolds shall be enclosed.


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In addition to the normal operating brake, suspension scaffold power-operated hoists and manually operated hoists shall have a braking device or locking pawl which engages automatically when a hoist makes either of the following uncontrolled movements: an instantaneous change in momentum or an accelerated overspeed.

Manually operated hoists shall require a positive crank force to descend.

Two-point and multi-point suspension scaffolds shall be tied or otherwise secured to prevent them from swaying, as determined to be necessary based on an evaluation by a competent person. Window cleaners' anchors shall not be used for this purpose.

Devices whose sole function is to provide emergency escape and rescue shall not be used as working platforms. This provision does not preclude the use of systems which are designed to function both as suspension scaffolds and emergency systems.

Access

This paragraph applies to scaffold access for all employees. Access requirements for employees erecting or dismantling supported scaffolds are specifically addressed later in this procedure.

When scaffold platforms are more than 12 inches. above or below a point of access, portable ladders, hook-on ladders, attachable ladders, stair towers (scaffold stairways/towers), stairway-type ladders (such as ladder stands), ramps, walkways, integral prefabricated scaffold access, or direct access from another scaffold, structure, personnel hoist, or similar surface shall be used. Cross braces shall not be used as a means of access.

When climbing ladders, employees shall maintain three-point contact at all times. Tools or materials may not be carried up in employees‘ hands. Toe boards shall not be used as handholds or foot holds.

Portable, hook-on, and attachable ladders:


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Ladders shall be inspected by a competent person for visible defects on a periodic basis and after any occurrence that could affect their safe use. Defective ladders will be tagged a put out of service. Ladders are to be placed on stable, level surfaces. Employees are not to stand on top two rungs, or top of step ladders. Employees are not to carry anything in hands that could cause injury in case of fall, to face the ladder when ascending or descending. Ladders shall not be loaded beyond the maximum intended load for which they were built, nor beyond the manufacturer's rated capacity.

(a) Ladder rungs, cleats, and steps shall be parallel, level, and uniformly spaced, when the ladder is in position for use.

(b) Portable, hook-on, and attachable ladders shall be positioned so as not to tip the scaffold. The ladder side rails shall extend at least 3 feet (.9m) above the upper landing surface. When ladders are not able to be extended then the ladder shall be secured at its top to a rigid support that will not deflect. Ladders shall be placed at a 4:1 ratio.

(c) Hook-on and attachable ladders shall be positioned so that their bottom rung is not more than 12 inches above the scaffold supporting level or a height equal to the vertical rung spacing, whichever is larger.

(d) When hook-on and attachable ladders are used on a supported scaffold more than 35 feet (10.7 m) high, they shall have rest platforms at 35-foot (10.7 m) maximum vertical intervals.

(e) Hook-on and attachable ladders shall be specifically designed for use with the type of scaffold used. Ladders shall be used only for the purpose for which they were designed.

(f) Hook-on and attachable ladders shall have a minimum rung length of 11 1/2 inches (29 cm).

(g) Hook-on and attachable ladders shall have uniformly spaced rungs with a maximum spacing between rungs of 16 3/4 inches.

Stairway-type ladders shall:

(a) Be positioned such that the vertical distance between the bottom steps above the scaffold supporting level is not


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more than 12 inches or a vertical height equal to the distance between the steps of the ladder, whichever is greater.

(b) Be provided with rest platforms at 12 foot (3.7 m) maximum vertical intervals.

(c) Have a minimum step width of 16 inches (41 cm), except that mobile scaffold stairway-type ladders shall have a minimum step width of 11 1/2 inches (30 cm).

(d) Have slip-resistant treads on all steps and landings.

Stair towers (scaffold stairway/towers) shall be positioned such that their bottom step is not more than 12 inches above the scaffold supporting level.

(a) A stair rail consisting of a toprail and a midrail shall be

provided on each side of each scaffold stairway. (b) The toprail of each stair rail system shall also be capable

of serving as a handrail, unless a separate handrail is provided.

(c) Handrails, and toprails that serve as handrails, shall provide an adequate handhold for employees grasping them to avoid falling.

(d) Stair rail systems and handrails shall be surfaced to prevent injury to employees from punctures or lacerations, and to prevent snagging of clothing.

(e) The ends of stair rail systems and handrails shall be constructed so that they do not constitute a projection hazard.

(f) Handrails, and toprails that are used as handrails, shall be at least 3 inches (7.6 cm) from other objects.

(g) Stair rails shall be not less than 28 inches (71 cm) nor more than 37 inches (94 cm) from the upper surface of the stair rail to the surface of the tread, in line with the face of the riser at the forward edge of the tread.

(h) A landing platform at least 18 inches (45.7 cm) wide by at least 18 inches (45.7 cm) long shall be provided at each level.

(i) Each scaffold stairway shall be at least 18 inches (45.7 cm) wide between stair rails.

(j) Treads and landings shall have slip-resistant surfaces. (k) Stairways shall be installed between 40 degrees and 60

degrees from the horizontal.


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(l) Guardrails shall be provided on the open sides and ends of each landing.

(m)Riser height shall be uniform, within 1/4 inch, (0.6 cm) for each flight of stairs. Greater variations in riser height are allowed for the top and bottom steps of the entire system, not for each flight of stairs.

(n) Tread depth shall be uniform, within 1/4 inch, for each flight of stairs.

Ramps and Walkways:

(a) Ramps and walkways 6 feet (1.8 m) or more above lower levels shall have guardrail systems which comply with the fall protection portion of these guidelines.

(b) No ramp or walkway shall be inclined more than a slope of one (1) vertical to three (3) horizontal (20 degrees above the horizontal).

(c) If the slope of a ramp or a walkway is steeper than one (1) vertical in eight (8) horizontal, the ramp or walkway shall have cleats not more than fourteen (14) inches (35 cm) apart which are securely fastened to the planks to provide footing.

Integral prefabricated scaffold access frames shall:

(a) Be specifically designed and constructed for use as ladder rungs.

(b) Have a rung length of at least 8 inches (20 cm). (c) Not be used as work platforms when rungs are less than

11 1/2 inches in length, unless each affected employee uses fall protection, or a positioning device.

(d) Be uniformly spaced within each frame section. (e) Be provided with rest platforms at 35-foot (10.7 m)

maximum vertical intervals on all supported scaffolds more than 35 feet (10.7 m) high.

(f) Have a maximum spacing between rungs of 16 3/4 inches (43 cm). Non-uniform rung spacing caused by joining end frames together is allowed, provided the resulting spacing does not exceed 16 3/4 inches (43 cm).


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Steps and rungs of ladder and stairway type access shall line up vertically with each other between rest platforms.

Direct access to or from another surface shall be used only when the scaffold is not more than 6 inches horizontally and not more than 12 inches vertically from the other surface.

Access for employees erecting or dismantling supported scaffolds shall be in accordance with the following:

(a) Scaffolding contractor shall provide safe means of

access for each employee erecting or dismantling a scaffold where the provision of safe access is feasible and does not create a greater hazard. The competent person and the site safety representative shall determine whether it is feasible or would pose a greater hazard to provide, and have employees use a safe means of access. This determination shall be based on site conditions and the type of scaffold being erected or dismantled.

(b) Hook-on or attachable ladders shall be installed as soon as scaffold erection has progressed to a point that permits safe installation and use.

(c) When erecting or dismantling tubular welded frame scaffolds, (end) frames, with horizontal members that are parallel, level and are not more than 22 inches apart vertically may be used as climbing devices for access, provided they are erected in a manner that creates a usable ladder and provides good hand hold and foot space.

(d) Cross braces on tubular welded frame scaffolds shall not be used as a means of access or egress.

Use

Scaffolds and scaffold components shall not be loaded in excess of their maximum intended loads or rated capacities, whichever is less.

The use of shore or lean-to scaffolds is prohibited.


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Scaffolds and scaffold components shall be inspected for visible defects by a competent person before each work shift, and after any occurrence which could affect a scaffold's structural integrity.

Any part of a scaffold damaged or weakened such that its strength is less than that required by the capacity portion of this section shall be immediately repaired or replaced, braced to meet those provisions, or removed from service until repaired.

Scaffolds shall not be moved horizontally while employees are on them.

Scaffolds shall not be erected, used, dismantled, altered, or moved such that they or any conductive material handled on them might come closer to exposed and energized power lines than as follows:

Insulated & Un-isulated Line

Voltage

Minimum Distance

Less than 50 kV 10 feet (3.1m)

More than 50 kV 10 feet (3.1 m) plus 4.0 inches (10 cm) for each 1 kV over 50 kV

Note: Scaffolds and materials may only be closer to power lines than specified above where the utility company or electrical system operator has been notified of the work and de-energized the lines, relocated the lines, or installed protective coverings to prevent accidental contact with the lines.

Scaffolds shall be erected, moved, dismantled, or altered only under the supervision and direction of a competent person qualified in scaffold erection, moving, dismantling or alteration. Such activities shall be performed only by experienced and trained employees selected for such work by the competent person.

Employees shall be prohibited from working on scaffolds covered with snow, ice, or other slippery material except as necessary for removal of such materials.


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Where swinging loads are being hoisted onto or near scaffolds such that the loads might contact the scaffold, tag lines or equivalent measures to control the loads shall be used.

Suspension ropes supporting adjustable suspension scaffolds shall be of a diameter large enough to provide sufficient surface area for the functioning of brake and hoist mechanisms.

Suspension ropes shall be shielded from heat-producing processes. When acids or other corrosive substances are used on a scaffold, the ropes shall be shielded, treated to protect against the corrosive substances, or shall be of a material that will not be damaged by the substance being used.

Work on or from scaffolds is prohibited during storms or high winds unless a competent person has determined that it is safe for employees to be on the scaffold and those employees are protected by a personal fall arrest system or wind screens. Wind screens shall not be used unless the scaffold is secured against the anticipated wind forces imposed.

Debris shall not be allowed to accumulate on platforms.

Makeshift devices, such as but not limited to boxes and barrels, shall not be used on top of scaffold platforms to increase the working level height of employees.

Ladders shall not be used on scaffolds to increase the working level height of employees, except on large area scaffolds where the following conditions have been satisfied:

(a) When the ladder is placed against a structure which is

not a part of the scaffold, the scaffold shall be secured against the sideways thrust exerted by the ladder.

(b) The platform units shall be secured to the scaffold to prevent their movement.

(c) The ladder legs shall be on the same platform or other means shall be provided to stabilize the ladder against unequal platform deflection.

(d) The ladder legs shall be secured to prevent them from slipping or being pushed off the platform.


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Platforms shall not deflect more than 1/60 of the span when loaded.

No welding, burning, or open flame work shall be performed on any staging suspended by means of fiber or synthetic rope. Only treated or protected fiber or synthetic ropes shall be used for or near any work involving the use of corrosive substances or chemicals.

To reduce the possibility of welding current arcing through the suspension wire rope when performing welding from suspended scaffolds, the following precautions shall be taken, as applicable:

(a) An insulated thimble shall be used to attach each

suspension wire rope to its hanging support (such as cornice hook or outrigger). Excess suspension wire rope and any additional independent lines shall be insulated from grounding.

(b) The suspension wire rope shall be covered with insulating material extending at least 4 feet (1.2 m) above the hoist. If there is a tail line below the hoist, it shall be insulated to prevent contact with the platform. The portion of the tail line that hangs free below the scaffold shall beguided or retained, or both, so that it does not become grounded.

(c) Each hoist shall be covered with insulated protective covers.

(d) In addition to a work lead attachment required by the welding process, a grounding conductor shall be connected from the scaffold to the structure. The size of this conductor shall be at least the size of the welding process work lead, and this conductor shall not be in series with the welding process or the work piece.

(e) If the scaffold grounding lead is disconnected at any time,

the welding machine shall be shut off. (f) An active welding rod or uninsulated welding lead shall

not be allowed to contact the scaffold or its suspension system.

Fall Protection


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Fall protection issues not addressed in this procedure are covered in the Becht Engineering‘s Fall Protection Procedure.

Each employee on a scaffold more than 6 feet above a lower level shall be protected from falling to that lower level.

(a) Each employee on a boatswains' chair, float scaffold or

needle beam scaffold shall be protected by a personal fall arrest system.

(b) Each employee on a single-point or two-point adjustable suspension scaffold shall be protected by both a personal fall arrest system and guardrail system.

(c) Each employee on a self-contained adjustable scaffold shall be protected by a guardrail system (with minimum 200 pound toprail capacity) when the platform is supported by the frame structure, and by both a personal fall arrest system and a guardrail system (with minimum 200 pound toprail capacity) when the platform is supported by ropes.

(d) Each employee on a walkway located within a scaffold shall be protected by a guardrail system (with minimum 200 pound toprail capacity) along both sides of the walkway.

(e) For all scaffolds not otherwise specified, each employee shall be protected by the use of personal fall arrest systems or guardrail systems.

Scaffolding contractor shall have a competent person and the site safety representative determine the feasibility and safety of providing fall protection for employees erecting or dismantling supported scaffolds. Scaffolding contractor is required to provide fall protection for employees erecting or dismantling supported scaffolds where the installation and use of such protection is feasible and does not create a greater hazard.

In addition to meeting the requirements of fall protection, personal fall arrest systems used on scaffolds shall be attached by lanyard to a vertical lifeline, horizontal lifeline, or scaffold structural member. Vertical lifelines shall not be used when overhead components, such as overhead protection or additional platform levels, are part of a single-point or two-point adjustable suspension scaffold.


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(a) When vertical lifelines are used, they shall be fastened to a fixed safe point of anchorage, shall be independent of the scaffold, and shall be protected from sharp edges and abrasion. Safe points of anchorage include structural members of buildings, but do not include standpipes, vents, other piping systems, electrical conduit, outrigger beams, or counterweights. There shall only be one vertical lifeline per worker.

(b) When horizontal lifelines are used, they shall be secured to two or more structural members of the scaffold, or they may be looped around both suspension and independent suspension lines (on scaffolds so equipped) above the hoist and brake attached to the end of the scaffold. Horizontal lifelines shall not be attached only to the suspension ropes.

(c) When lanyards are connected to horizontal lifelines or structural members on a single-point or two-point adjustable suspension scaffold, the scaffold shall be equipped with additional independent support lines and automatic locking devices capable of stopping the fall of the scaffold in the event one or both of the suspension ropes fail. The independent support lines shall be equal in number and strength to the suspension ropes.

(d) Vertical lifelines, independent support lines, and suspension ropes shall not be attached to each other, nor shall they be attached to or use the same point of anchorage, nor shall they be attached to the same point on the scaffold or personal fall arrest system.

Guardrail systems installed to meet the requirements of this section shall comply with the following:

(a) Guardrail systems shall be installed along all open sides

and ends of platforms. Guardrail systems shall be installed before the scaffold is released for use by employees other than erection/ dismantling crews.

(b) Guardrails (toprails and midrails) shall be 2 x 4 in. or equivalent with vertical uprights not to exceed 8 foot intervals. Toe boards shall be a minimum of 4 in. in height.

(c) The top edge height of toprails or equivalent member on supported scaffolds manufactured or placed in service


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after January 1, 2000 shall be installed between 38 inches (0.97 m) and 45 inches (1.2 m) above the platform surface. The top edge height on supported scaffolds manufactured and placed in service before January 1, 2000, and on all suspended scaffolds where both a guardrail and a personal fall arrest system are required shall be between 36 inches (0.9 m) and 45 inches (1.2 m). When conditions warrant, the height of the top edge may exceed the 45-inch height, provided the guardrail system meets all other criteria of this section.

(d) When midrails, screens, mesh, intermediate vertical members, solid panels, or equivalent structural members are used, they shall be installed between the top edge of the guardrail system and the scaffold platform.

(e) When midrails are used, they shall be installed at a height approximately midway between the top edge of the guardrail system and the platform surface.

(f) When screens and mesh are used, they shall extend from the top edge of the guardrail system to the scaffold platform, and along the entire opening between the supports.

(g) When intermediate members (such as balusters or additional rails) are used, they shall not be more than 19 inches (48 cm) apart.

(h) Each toprail or equivalent member of a guardrail system shall be capable of withstanding, without failure, a force applied in any downward or horizontal direction at any point along its top edge of at least 100 pounds (445 n) for guardrail systems installed on single-point adjustable suspension scaffolds or two-point adjustable suspension scaffolds, and at least 200 pounds (890 n) for guardrail systems installed on all other scaffolds.

(i) When the loads specified above are applied in a downward direction, the top edge shall not drop below the minimum height requirements previously stated.

(j) Midrails, screens, mesh, intermediate vertical members, solid panels, and equivalent structural members of a guardrail system shall be capable of withstanding, without failure, a force applied in any downward or horizontal direction at any point along the midrail or other member of at least 75 pounds (333 n) for guardrail systems with a minimum 100 pound toprail capacity, and


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at least 150 pounds (666 n) for guardrail systems with a minimum 200 pound toprail capacity.

(k) Suspension scaffold hoists and non-walk-through stirrups may be used as end guardrails, if the space between the hoist or stirrup and the side guardrail or structure does not allow passage of an employee to the end of the scaffold.

(l) Guardrails shall be surfaced to prevent injury to an employee from punctures or lacerations, and to prevent snagging of clothing.

(m)The ends of all rails shall not overhang the terminal posts except when such overhang does not constitute a projection hazard to employees.

(n) Steel or plastic banding shall not be used as a toprail or midrail.

(o) Manila or plastic (or other synthetic) rope is prohibited for use as toprails or midrails.

(p) Cross bracing is acceptable in place of a midrail when the crossing point of two braces is between 20 inches (0.5 m) and 30 inches (0.8 m) above the work platform or as a toprail when the crossing point of two braces is between 38 inches (0.97 m) and 48 inches (1.3 m) above the work platform. The end points at each upright shall be no more than 48 inches (1.3 m) apart.

Falling Object Protection

In addition to wearing hard-hats each employee on a scaffold shall be provided with additional protection from falling hand tools, debris, and other small objects through the installation of toe boards, screens, or guardrail systems, or through the erection of debris nets, catch platforms, or canopy structures that contain or deflect the falling objects. When the falling objects are too large, heavy or massive to be contained or deflected by any of the above-listed measures, the contractor shall place such potential falling objects away from the edge of the surface from which they could fall and shall secure those materials as necessary to prevent their falling.

Where there is a danger of tools, materials, or equipment falling from a scaffold and striking employees below, the following provisions apply:


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(a) The area below the scaffold to which objects can fall shall

be barricaded, and employees shall not be permitted to enter the hazard area.

(b) A toe board shall be erected along the edge of platforms more than 6 feet above lower levels for a distance sufficient to protect employees below, except on float (ship) scaffolds where an edging of 3/4 x 1 1/2 inch (2 x 4 cm) wood or equivalent may be used in lieu of toe board.

(c) Where tools, materials, or equipment are piled to a height higher than the top edge of the toe board, paneling or screening extending from the toe board or platform to the top of the guardrail shall be erected for a distance sufficient to protect employees below.

(d) A guardrail system shall be installed with openings small enough to prevent passage of potential falling objects.

(e) A canopy structure, debris net, or catch platform strong enough to withstand the impact forces of the potential falling objects shall be erected over the employees below.

Screening used shall consist of No. 18 gage, 1/2 in. wire mesh or equivalent.

Canopies, when used for falling object protection, shall comply with the following criteria:

(a) Canopies shall be installed between the falling object

hazard and the employees. (b) When canopies are used on suspension scaffolds for

falling object protection, the scaffold shall be equipped with additional independent support lines equal in number to the number of points supported, and equivalent in strength to the strength of the suspension ropes.

(c) Independent support lines and suspension ropes shall not be attached to the same points of anchorage.

Where used, toe boards shall be:


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(a) Capable of withstanding, without failure, a force of at least 50 pounds (222 n) applied in any downward or horizontal direction at any point along the toe board; and

(b) At least three and one-half inches (9 cm) high from the top edge of the toe board to the level of the walking/working surface. Toe boards shall be securely fastened in place at the outermost edge of the platform and have not more than 1/4 inch (0.7 cm) clearance above the walking/working surface. Toe boards shall be solid or with openings not over one inch (2.5 cm) in the greatest dimension.

Additional Requirements Applicable to Specific Types of Scaffolds

Pole Scaffolds

When platforms are being moved to the next level, the existing platform shall be left undisturbed until the new bearers have been set in place and braced, prior to receiving the new platforms.

Cross bracing shall be installed between the inner and outer sets of poles on double pole scaffolds.

Diagonal bracing in both directions shall be installed across the entire inside face of double-pole scaffolds used to support loads equivalent to a uniformly distributed load of 50 pounds (222 kg) or more per square foot (929 square cm).

Diagonal bracing in both directions shall be installed across the entire outside face of all double- and single-pole scaffolds.

Runners and bearers shall be installed on edge.

Bearers shall extend a minimum of 3 inches (7.6 cm) over the outside edges of runners.

Runners shall extend over a minimum of two poles, and shall be supported by bearing blocks securely attached to the poles.

Braces, bearers, and runners shall not be spliced between poles.


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Where wooden poles are spliced, the ends shall be squared and the upper section shall rest squarely on the lower section. Wood splice plates shall be provided on at least two adjacent sides, and shall extend at least 2 feet (0.6 m) on either side of the splice, overlap the abutted ends equally, and have at least the same cross-sectional areas as the pole. Splice plates of other materials of equivalent strength may be used.

Pole scaffolds over 50 feet in height shall be designed by a registered professional engineer, and shall be constructed and loaded in accordance with that design.

Tube and Coupler Scaffolds

When platforms are being moved to the next level, the existing platform shall be left undisturbed until the new bearers have been set in place and braced prior to receiving the new platforms.

Transverse bracing forming an "X" across the width of the scaffold shall be installed at the scaffold ends and at least at every third set of posts horizontally (measured from only one end) and every fourth runner vertically. Bracing shall extend diagonally from the inner or outer posts or runners upward to the next outer or inner posts or runners. Building ties shall be installed at the bearer levels between the transverse bracing.

On straight run scaffolds, longitudinal bracing across the inner and outer rows of posts shall be installed diagonally in both directions, and shall extend from the base of the end posts upward to the top of the scaffold at approximately a 45 degree angle. On scaffolds whose length is greater than their height, such bracing shall be repeated beginning at least at every fifth post. On scaffolds whose length is less than their height, such bracing shall be installed from the base of the end posts upward to the opposite end posts, and then in alternating directions until reaching the top of the scaffold. Bracing shall be installed as close as possible to the intersection of the bearer and post or runner and post.

Where conditions preclude the attachment of bracing to posts, bracing shall be attached to the runners as close to the post as possible.


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Braces extended into walkways, which may pose a tripping hazard to personnel, should be ramped over, padded, or flagged, as necessary, to prevent injury.

Bearers shall be installed transversely between posts, and when coupled to the posts, shall have the inboard coupler bear directly on the runner coupler. When the bearers are coupled to the runners, the couplers shall be as close to the posts as possible.

Bearers shall extend beyond the posts and runners a minimum of 4 in. but not more than 12 in., and shall provide full contact with the coupler. Extension of bearers shall not protrude into walking or climbing areas, whenever possible.

Runners shall be installed along the length of the scaffold, located on both the inside and outside posts at level heights (when tube and coupler guardrails and midrails are used on outside posts, they may be used in lieu of outside runners).

Runners shall be interlocked on straight runs to form continuous lengths, and shall be coupled to each post. The bottom runners and bearers shall be located as close to the base as possible.

Couplers shall be of a structural metal, such as drop-forged steel, malleable iron, or structural grade aluminum. The use of gray cast iron is prohibited.

Tube and coupler scaffolds over 50 feet in height shall have their design reviewed by a registered professional engineer, and shall be constructed and loaded in accordance with such design.

Tube and coupler scaffolds over 100 feet in height shall be designed by a registered professional engineer, and shall be constructed and loaded in accordance with such design.

Fabricated Frame Scaffolds (Tubular Welded Frame Scaffolds)

When moving platforms to the next level, the existing platform shall be left undisturbed until the new end frames have been set in place and braced prior to receiving the new platforms.


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Frames and panels shall be braced by cross, horizontal, or diagonal braces, or combination thereof, which secure vertical members together laterally. The cross braces shall be of such length as will automatically square and align vertical members so that the erected scaffold is always plumb, level, and square. All brace connections shall be secured.

More than one section of diagonal braces shall not be removed from a horizontal series of sections unless at least four (4) sets of diagonal braces separate the sections to be removed.

Frames and panels shall be joined together vertically by coupling or stacking pins or equivalent means.

Where uplift can occur which would displace scaffold end frames or panels, the frames or panels shall be locked together vertically by pins or equivalent means.

Brackets used to support cantilevered loads shall:

(a) Be seated with side-brackets parallel to the frames and end-brackets at 90 degrees to the frames.

(b) Not be bent or twisted from these positions. (c) Be used only to support personnel, unless the scaffold

has been designed for other loads by a qualified engineer and built to withstand the tipping forces caused by those other loads being placed on the bracket-supported section of the scaffold.

Scaffolds over 50 feet in height above their base plates shall have their design reviewed by a registered professional engineer, and shall be constructed and loaded in accordance with such design.

Scaffolds over 100 feet in height above their base plates shall be designed by a registered professional engineer, and shall be constructed and loaded in accordance with such design.

Form Scaffolds and Carpenters' Bracket Scaffolds

Each bracket, except those for wooden bracket-form scaffolds, shall be attached to the supporting formwork or structure by means of one or more of the following: nails; a metal stud attachment


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device; welding; hooking over a secured structural supporting member, with the form wales either bolted to the form or secured by snap ties or tie bolts extending through the form and securely anchored; or, for carpenters' bracket scaffolds only, by a bolt extending through to the opposite side of the structure's wall.

Wooden bracket-form scaffolds shall be an integral part of the form panel.

Folding type metal brackets, when extended for use, shall be either bolted or secured with a locking-type pin.

Brackets used on reinforcing steel walls:

(a) When bracket scaffolds are used on reinforcing-steel wall installations and more than one layer of horizontal rebar has been placed, the scaffold shall be secured to an inside horizontal bar.

(b) If conditions do not permit attaching the bracket scaffold to an inside horizontal bar, the scaffold shall be secured with a minimum of three 3/8-in.-diameter U-bolts attached to each end and middle of the outer horizontal or vertical bar. Also, No. 9 wire shall be placed at a minimum of every fourth tie location.

(c) The horizontal reinforcing bar shall be secured to a vertical reinforcing bar that is either embedded in concrete or spliced by an approved method.

(d) Each scaffold shall have a 4 ft. x 1/4 in. safety chain attached to the ends of the scaffold and secured to an inner rebar other than the bar that is supporting the scaffold.

(e) Guardrails and toeboards shall be installed all open sides and ends of scaffolds.

(f) No more than two workers plus necessary tools and equipment shall be permitted on a single scaffold section at any one time. The load is not to go beyond the scaffold‘s designed capacity. Bracket scaffolds shall be constructed to support 1,550 lbs., and the capacity shall be posted on the scaffold.

Step, Platform and Trestle Ladder Scaffolds


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Scaffold platforms shall not be placed any higher than the second highest rung or step of the ladder supporting the platform.

All ladders used in conjunction with step, platform and trestle ladder scaffolds shall meet the pertinent requirements of the Subpart X Construction Standards, except that job-made ladders shall not be used to support such scaffolds.

Ladders used to support step, platform, and trestle ladder scaffolds shall be placed, fastened, or equipped with devices to prevent slipping.

Scaffolds shall not be bridged one to another. Single-Point Adjustable Suspension Scaffolds

When two single-point adjustable suspension scaffolds are combined to form a two-point adjustable suspension scaffold, the resulting two-point scaffold shall comply with the requirements for two-point adjustable suspension scaffolds

The supporting rope between the scaffold and the suspension device shall be kept vertical unless all of the following conditions are met:

(a) The rigging has been designed by a qualified person. (b) The scaffold is accessible to rescuers. (c) The supporting rope is protected to ensure that it will not

chafe at any point where a change in direction occurs. (d) The scaffold is positioned so that swinging cannot bring

the scaffold into contact with another surface.

Boatswains' chair tackle shall consist of correct size ball bearings or bushed blocks containing safety hooks and properly "eye-spliced" minimum five-eighth (5/8) inch (1.6 cm) diameter first-grade manila rope, or other rope which will satisfy the criteria (e.g., strength and durability) of manila rope.

Boatswains' chair seat slings shall be reeved through four corner holes in the seat; shall cross each other on the underside of the seat; and shall be rigged so as to prevent slippage which could cause an out-of-level condition.


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Boatswains' chair seat slings shall be a minimum of five-eight (5/8) inch (1.6 cm) diameter fiber, synthetic, or other rope which will satisfy the criteria (e.g., strength, slip resistance, durability, etc.) of first grade manila rope.

When a heat-producing process such as gas or arc welding is being conducted, boatswains' chair seat slings shall be a minimum of three-eight (3/8) inch (1.0 cm) wire rope.

Boatswains‘ chair seats shall be a minimum of 2 x 12 x 24 in. lumber or equivalent.

Non-cross-laminated wood boatswains' chairs shall be reinforced on their underside by cleats securely fastened to prevent the board from splitting.

Two-Point Adjustable Suspension Scaffolds (Swing Stages)

Workers must be provided with a safe method of moving to and from the scaffold.

Workers involved with the moving of a scaffold shall be protected from falls at heights of 6 feet or greater.

Platforms shall not be more than 36 inches (0.9 m) wide unless designed by a qualified person to prevent unstable conditions.

The platform shall be securely fastened to hangers (stirrups) by U-bolts or by other means which satisfy the capacity requirements previously stated for platforms.

The blocks for fiber or synthetic ropes shall consist of at least one double and one single block. The sheaves of all blocks shall fit the size of the rope used.

Platforms shall be of the ladder-type, plank-type, beam-type, or light-metal type. Light metal-type platforms having a rated capacity of 750 pounds or less and platforms 40 feet (12.2 m) or less in length shall be tested and listed by a nationally recognized testing laboratory.


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Two-point scaffolds shall not be bridged or otherwise connected one to another during raising and lowering operations unless the bridge connections are articulated (attached), and the hoists properly sized.

Passage may be made from one platform to another only when the platforms are at the same height, are abutting, and walk-through stirrups specifically designed for this purpose are used.

Outrigger beams, when required, should extend from 1 ft. to 6 ft. beyond the edge of the building, and the inboard length from the fulcrum should be at least 1.5 times the outboard length from the fulcrum.

Float (Ship) Scaffolds

The platform shall be made of 3/4 in. plywood or equivalent and be supported by a minimum of two bearers, each of which shall project a minimum of 6 inches (15.2 cm) beyond the platform on both sides. Each bearer shall be securely fastened to the platform.

Bearers shall be made from 2 x 4 in. or 1 x 10 rough lumber. They shall be free of knots or other flaws.

Rope connections shall follow standard rigging practices such that the platform cannot shift or slip.

Rope shall be 1 in. manila rope or equivalent and shall be run diagonally underneath the platform from bearer to bearer.

When only two ropes are used with each float:

(a) They shall be arranged so as to provide four ends which are securely fastened to overhead supports.

(b) Each supporting rope shall be hitched around one end of the bearer and pass under the platform to the other end of the bearer where it is hitched again, leaving sufficient rope at each end for the supporting ties.

Interior hung scaffolds


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Scaffolds shall be suspended only from the roof structure or other structural member such as ceiling beams.

Overhead supporting members (roof structure, ceiling beams, or other structural members) shall be inspected and checked for strength before the scaffold is erected.

Suspension ropes and cables shall be connected to the overhead supporting members by shackles, clips, thimbles, or other means that meet equivalent criteria (e.g., strength, durability).

Needle Beam Scaffolds

Scaffold support beams shall be installed on edge.

Ropes or hangers shall be used for supports, except that one end of a needle beam scaffold may be supported by a permanent structural member.

Scaffolds shall be supported by 1 in. manila rope, 1/2 in. wire rope, 1/4 in. or high test chain or equivalent, using standard hitch or eye splice, with supports on the beam not to be more than 10 ft. apart for the 4 x 6 in. timbers.

Needle beams shall be construction-grade lumber with a minimum of 1,500 psi fiber strength.

Maximum platform span shall not exceed 8 feet.

The ropes shall be securely attached to the needle beams.

The support connection shall be arranged so as to prevent the needle beam from rolling or becoming displaced.

Platform units shall be securely attached to the needle beams by bolts or equivalent means. Cleats and overhang are not considered to be adequate means of attachment.

Multi-Level Suspended Scaffolds

Scaffolds shall be equipped with additional independent support lines, equal in number to the number of points supported, and of


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equivalent strength to the suspension ropes, and rigged to support the scaffold in the event the suspension rope(s) fail.

Independent support lines and suspension ropes shall not be attached to the same points of anchorage.

Supports for platforms shall be attached directly to the support stirrup and not to any other platform.

Mobile Scaffolds

Scaffolds shall be braced by cross, horizontal, or diagonal braces, or combination thereof, to prevent racking or collapse of the scaffold and to secure vertical members together laterally so as to automatically square and align the vertical members. Scaffolds shall be plumb, level, and squared. All brace connections shall be secured.

(a) Scaffolds constructed of tube and coupler components

shall also comply with the requirements of the ―tube and coupler‖ section of these guidelines.

(b) Scaffolds constructed of fabricated frame components shall also comply with the requirements of the ―welded frame scaffold‖ section.

Scaffold casters and wheels shall be locked with positive wheel and/or wheel and swivel locks, or equivalent means, to prevent movement of the scaffold while the scaffold is used in a stationary manner.

Manual force used to move the scaffold shall be applied as close to the base as practicable, but not more than 5 feet (1.5 m) above the supporting surface.

Scaffolds shall be stabilized to prevent tipping during movement.

The height of a manually propelled mobile scaffold shall not exceed three times its minimum base dimension.

Employees shall not be allowed to ride on manually propelled mobile scaffolds.


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Platforms shall not extend outward beyond the base supports of the scaffold unless outrigger frames or equivalent devices are used to ensure stability.

Where leveling of the scaffold is necessary, screw jacks or equivalent means shall be used.

Caster stems and wheel stems shall be pinned or otherwise secured in scaffold legs or adjustment screws.

Scaffold Erection and Dismantling Requirements

Workers shall keep both hands empty for secure handholds when moving

above on scaffolds. Pockets, pouches, and tool belts shall be used to carry the necessary

tools for the work to be conducted. Scaffold members shall be hoisted or lowered with a hand line or passed

from hand to hand. Throwing items up or down to co-workers is prohibited.

Scaffold Tagging

A GREEN scaffold tag indicates the scaffold is complete as defined by the

manufacturer for unrestricted use. A YELLOW scaffold tag indicates the scaffold is not complete but is

available for restricted use only. The red tag will detail the missing components and the need for a personal fall arrest system.

A RED scaffold tag indicates the scaffold is in some way defective and

cannot be used. Scaffolds being erected, modified or dismantled shall not be tagged and

can only be accessed by those involved with the process. Installation and Removal of Scaffold Tags The responsible Supervisor shall determine whether a usable scaffold

receives a yellow or green tag, complete all pertinent information on the


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tag, and affix the appropriate tag to the scaffold erected under his/her supervision.

The scaffold tag shall be affixed to the scaffold access ladder

approximately 5 feet from the base, where it will not interfere with normal access.

The Supervisor or a Safety Representative may remove a scaffold tag

from a scaffold that is deficient in any way (i.e. has been damaged, improperly modified or is missing components). RED defective tags shall be used in these circumstances.

After a scaffold has been repaired, the Supervisor shall inspect it and, as

appropriate, tag the scaffold. Periodic inspections shall be performed by the designated competent

person to assure all appropriate tags are present. Inspection and Testing of Scaffold Planks

Wooden planks used for scaffold platforms shall be scaffold grade lumber. Scaffold planks shall be inspected and tested upon receipt and prior to

use. Inspections shall identify any defects, which may affect the structural

integrity of the plank (i.e. decay, splits, cuts, etc.). Scaffold planks when loaded shall not deflect more than 1/60th the length

between bearers. Fire-retardant treated lumber shall have a weight capacity rating of 80 to

85 percent of untreated lumber.

Storage of Scaffolding

1. Scaffolding material shall be stored in a manner that will prevent damage to the equipment.

4. TRAINING


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Training Requirements Contractor shall have each employee who performs work while on a

scaffold trained by a person qualified in the subject matter to recognize the hazards associated with the type of scaffold being used and to understand the procedures to control or minimize those hazards. The training shall include the following areas, as applicable:

The nature of any electrical hazards, fall hazards and falling object hazards in the work area.

The correct procedures for dealing with electrical hazards and for erecting, maintaining, and disassembling the fall protection systems and falling object protection systems being used.

The proper use of the scaffold, and the proper handling of materials on the scaffold.

The maximum intended load and the load-carrying capacities of the scaffolds used.

Any other pertinent requirements. Contractor shall have each employee who is involved in erecting,

disassembling, moving, operating, repairing, maintaining, or inspecting a scaffold trained by a competent person to recognize any hazards associated with the work in question. The training shall include the following topics, as applicable:

The nature of scaffold hazards.

The correct procedures for erecting, disassembling, moving, operating, repairing, inspecting, and maintaining the type of scaffold in question.

The design criteria, maximum intended load-carrying capacity and intended use of the scaffold.

Any other pertinent requirements. When Contractor has reason to believe that an employee lacks the skill or

understanding needed for safe work involving the erection, use or


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dismantling of scaffolds, contractor shall retrain each such employee so that the requisite proficiency is regained. Retraining is required in at least the following situations:

Where changes at the worksite present a hazard about which an employee has not been previously trained.

Where changes in the types of scaffolds, fall protection, falling object protection, or other equipment present a hazard about which an employee has not been previously trained.

Where inadequacies in an affected employee's work involving scaffolds indicate that the employee has not retained the requisite proficiency.

List of Training Topics for Scaffold Erectors and Dismantlers

This section provides information on training needs of personnel erecting

or dismantling supported scaffolds. Employees erecting or dismantling scaffolds should be trained in the

following topics:

General Overview of Scaffolding

a) Regulations and standards b) Erection/dismantling planning c) PPE and proper procedures d) Fall protection e) Materials handling f) Access g) Working platforms h) Foundations i) Guys, ties and braces

Tubular Welded Frame Scaffolds

a) Specific regulations and standards b) Components c) Parts inspection


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d) Erection/dismantling planning e) Guys, ties and braces f) Fall protection g) General safety h) Access and platforms i) Erection/dismantling procedures j) Rolling scaffold assembly k) Putlogs

Tube and Clamp Scaffolds

a) Specific regulations and standards b) Components c) Parts inspection d) Erection/dismantling planning e) Guys, ties and braces f) Fall protection g) General safety h) Access and platforms i) Erection/dismantling procedures j) Buttresses, cantilevers, & bridges

System Scaffolds a) Specific regulations and standards b) Components c) Parts inspection d) Erection/dismantling planning e) Guys, ties and braces f) Fall protection g) General safety h) Access and platforms i) Erection/dismantling procedures j) Buttresses, cantilevers, & bridges

Scaffold erectors and dismantlers should all receive the general overview, and, in addition, specific training for the type of supported scaffold being erected or dismantled.

Deviations


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Any deviations to the above described procedures must be reviewed and approved by the site safety representative.

5 REFERENCE

Title 29, Code of Federal Regulations Parts 1910 and 1926, Occupational Safety and Health Administration (OSHA), U.S. Department of Labor.

6 APPENDICES

None

WELDING AND HOT WORK SAFETY

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1 PURPOSE

Purpose

This safety standard defines safe practices in welding, cutting, burning, brazing, soldering, lead burning, and related processes.

Information on welding processes is not covered by this safety procedure.

Scope

This procedure applies to all Becht Engineering personnel and subcontractors working on projects where handling of welding and hot work requirements is applicable.

2 GENERAL

The principle that is common to all welding, burning, soldering, brazing, and similar metallizing operations is the heating of metals to cause their joining or separation. Many types of health and safety issues can arise, which can be grouped into the following general classes:

Inhalation of fumes and gases

Eye irritation from fumes and gases

Burns

High noise levels

Electric shock

Inadvertent ingestion of toxic substances

Definitions

None


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Responsibilities

Non-applicable

3 PROCEDURE

Work Permits Welding and/or burning operations shall not be conducted until the proper hot work permits are issued, and all required gas tests completed.

Personal Protective Equipment

All personnel performing or working near welding, burning or a related operation shall use appropriate protective equipment for that task. Also, protective gloves and leathers should be worn to prevent burn injuries. Noise levels often exceed 82 dBA, requiring hearing protection.

Grounding Requirements

Electrically-powered Welding Machines

The frames of all arc welding and cutting machines shall be grounded either through a third wire in the cable containing the circuit conductor or through a separate wire which is grounded at the source of the current.

Grounding circuits, other than by means of the structure, shall be checked to ensure that the circuit between the ground and the grounded power conductor has resistance low enough to permit sufficient current to flow to cause the fuse or circuit breaker to interrupt the current.

Engine-driven Welding Machines - Under the following conditions,

the frame of a portable welding machine need not be grounded:

The welding machine supplies only equipment mounted on the machine and/or cord- and plug-connected equipment through receptacles mounted on the welding machine, and


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The non-current-carrying metal parts of equipment and the equipment grounding conductor terminals of the receptacles are bonded to the welding machine frame.

If the welding machine is mounted on a truck, then the frame of the welding machine must also be bonded to the frame of the vehicle.

Equipment Requirements

Welding Machines

All welding machines shall be in good condition. It is the responsibility of a welding machine owner and/or supplier to ensure the machine's condition (through inspection and calibration).

If the auxiliary receptacle outlet on the welding machine is used as a 120 volt AC power source, an approved "Ground Fault Circuit Interrupter (GFCI)" shall be used. In addition, the GFCI's performance shall be checked by the user before the system is used.

Work Practices

Arc Welding

Prior to Welding

a) Inspect welding machine for obvious fuel or oil leaks and general condition (terminal covers, muffler condition and cooling fan guards). In addition, tow welding machines with an approved tow hitch, use proper lifting techniques and care when moving a welding machine manually and chock wheels to prevent movement after placement.

b) Welding cables should be clean, dry, free of damage (torn insulation, torn repair tape, or inadequate splices) and no bare or loose connections or connections supporting the weight of the cable.

c) All grounding contact points shall be clean metal surfaces.


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d) Welding ground cables shall form a continuous electrical path between the work and ground.

1) Welding ground cables shall be connected directly

to the work piece whenever possible. 2) When the welding ground connection is not

located at the area of work, a separate gas test must be conducted.

e) Clean the area to be welded by grinding or wire brushing.

For coated carbon steel, cleaning the coating back 4+" on both sides of the weld will minimize emissions from any surface coatings present. Observe proper IH procedures.

During Welding

a) Keep cables and electrodes dry. Do not change welding rods with wet hands or while standing in water.

b) Never refuel the welding machine while it is in operation. c) No welding machine shall be left operating and

unattended when not in use. d) Welding operations in open shops, lay down areas or

areas with multiple welders in close proximity (i.e. a storage tank) shall be conducted inside approved clear welding curtains or opaque barriers to shield other personnel from glare and sparks.

e) During welding with inert gases (i.e. argon), in areas of poor and/or marginal ventilation, personnel must use supplied air for respiratory protection.

Gas Cutting, Welding, and Related Operations

Cylinders / Regulators

a) Cylinder valves and regulator fittings shall be clean, dry and free of oil and debris before use.

b) Oxygen cylinders must be stored in a separate location at least 20 feet from cylinders of combustible gases. Additionally, other combustible material must not be stored immediately adjacent to oxygen cylinders.


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c) Oxygen and fuel cylinders, either permanently installed or mounted/stored on carts, "buggies", or on vehicles, must be separated by a non-combustible barrier 5 feet high with a minimum 30-minute fire rating. The barrier must be certified by engineering.

Hoses

a) Inspect hoses for cuts or cracks before use and replace as needed

b) Do not locate hoses beneath the work area where hot slag may fall on them.

c) Always purge the hose after connecting to the regulator and before connecting the torch.

d) Prevent any vehicles from running over and damaging the hoses.

Torches

a) Flashbacks can cause explosions in the regulator, hose, or cylinders. Always use reverse flow check valves on both hose connections and flame arrestors at the torch leads to prevent flashback.

b) Open fuel valve first when lighting the torch and close the fuel valve first when finished using the torch. If not done correctly, the torch will "pop" and potentially damage the torch and check valves.

During cutting

a) The oxy-fuel system shall be controlled only by the user. When not in operation or when work is suspended for more than 60 minutes, the system shall be shut off by the user. Torch and hose assemblies will be removed from any confined space.

b) Oxy-fuel systems shall be kept a safe distance from the work area to protect it from hot slag and sparks.


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Ventilation

Large amounts of fresh air are the best prevention against adverse health effects from welding and burning. Other acceptable approaches are the use of respirators and local exhaust to carry away toxic fumes. Portable electrostatic precipitators can also be used to provide adequate local exhaust capability. Routine maintenance must be performed regularly on these devices for them to be effective.

Good Ventilation

a) Natural ventilation in large open areas during field welding.

Marginal Ventilation

a) Field enclosures that restrict natural ventilation such as wind breakers used to protect the gas shield around the weld site or spark enclosures such as a boxed in scaffold with the top open.

b) Not using exhaust vents in welding shops due to physical restriction of the work piece.

c) Unrestricted air flow and distribution in vessels and furnaces. Unrestricted means no major structural packing/tray structures or scaffolds present as barriers to flow.

d) Shallow trenches.

Poor Ventilation

Restricted air flow and distribution in vessels. Examples include visible accumulation of fumes, welders working at multiple levels in a single vessel, short circuiting of air flow by open manways or no manways to affix exhaust air movers.

a) OSHA requires 2000 cfm air flow per welder inside a

vessel or enclosed space. Contact IH for options on achieving required air flows.

b) Respirator use is recommended for all personnel present in vessels or confined spaces with marginal ventilation while burning/welding functions are in progress.


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c) Respirator use is required for all personnel present in vessels or confined spaces with poor ventilation while burning/welding functions are in progress.

d) If 2000 CFM flow per welder cannot be obtained in a vessel then all personnel in the vessel require supplied air, unless the vessel can be adequately segmented.

4 TRAINING

None

5 REFERENCES

OSHA CFR 1910 Subpart Q, "Welding, Cutting, and Brazing" OSHA CFR 1926 Subpart J, "Welding and Cutting" OSHA 1926.404, "Wiring Design and Protection‖

6 APPENDICES

None

HAND AND POWER TOOL SAFETY

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1 PURPOSE AND SCOPE

Purpose

This safety standard defines safe practices in hand and power tools.

Information on welding processes is not covered by this safety procedure.

Scope

This procedure applies to all Becht Engineering personnel and subcontractors working on projects where handling of hand and power tools is applicable.

2 GENERAL

Definitions

None

Responsibilities

Non-applicable

3 PROCEDURE

Condition of tools

All hand and power tools and similar equipment, whether furnished by the client or a contractor, shall be maintained in a safe condition. Any tool which is not in compliance with any applicable requirement of this part is prohibited and shall be identified as unsafe by tagging or locking the controls to render them inoperable.


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Guarding When power operated tools are designed to accommodate guards,

they shall be equipped with such guards when in use.

Belts, gears, shafts, pulleys, sprockets, spindles, drums, fly wheels, chains, or other reciprocating, rotating or moving parts of equipment shall be guarded if such parts are exposed to contact by advisors or otherwise create a hazard. Guarding shall meet the requirements as set forth in American National Standards Institute, B15.1-1953 (R1958), Safety Code for Mechanical Power-Transmission Apparatus.

One or more methods of machine guarding shall be provided to protect

the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks. Examples of guarding methods are - barrier guards, two-hand tripping devices, electronic safety devices, etc.

The point of operation of machines, whose operation exposes an

employee to injury, shall be guarded. The guarding device shall be in conformity with any appropriate standards therefore, or, in the absence of applicable specific standards, shall be so designed and constructed as to prevent the operator from having any part of his body in the danger zone during the operating cycle.

Special hand tools for placing and removing material shall be such as

to permit easy handling of material without the operator placing a hand in the danger zone. Such tools shall not be in lieu of other guarding required by this section, but can only be used to supplement protection provided.

The following are some of the machines which usually require point of

operation guarding:

Guillotine cutters.

Shears.

Alligator shears.

Powered presses.

Milling machines.

Power saws.

Jointers.

Portable power tools.


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Forming rolls and calendars.

When the periphery of the blades of a fan is less than 7 feet (2.128 m) above the floor or working level, the blades shall be guarded. The guard shall have openings no larger than 1/2 inch (1.27 cm)

Machines designed for a fixed location shall be securely anchored to

prevent walking or moving.

Safety guards, where the operator stands in front of the opening, shall be constructed so that the peripheral protecting member can be adjusted to the constantly decreasing diameter of the wheel. The maximum angular exposure above the horizontal plane of the wheel spindle shall never be exceeded, and the distance between the wheel periphery and the adjustable tongue or the end of the peripheral member at the top shall never exceed 1/4 inch (0.635 cm).

The angular exposure of the grinding wheel periphery and sides for

safety guards used on machines known as bench and floor stands should not exceed 90 deg. or one-fourth of the periphery. This exposure shall begin at a point not more than 65 deg. above the horizontal plane of the wheel spindle.

Whenever the nature of the work requires contact with the wheel below

the horizontal plane of the spindle, the exposure shall not exceed 125 deg. The maximum angular exposure of the grinding wheel periphery and sides for safety guards used on cylindrical grinding machines shall not exceed 180 deg... This exposure shall begin at a point not more than 65 deg. above the horizontal plane of the wheel spindle.

Employees using hand and power tools and exposed to the hazard of

falling, flying, abrasive, and splashing objects, or exposed to harmful dusts, fumes, mists, vapors, or gases shall be provided with the particular personal protective equipment necessary to protect them from the hazard.


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Switches

All hand-held powered platen sanders, grinders with wheels 2-inch diameter or less, routers, planers, laminate trimmers, nibblers, shears, scroll saws, and jigsaws with blade shanks one-fourth of an inch wide or less may be equipped with only a positive "on-off" control.

All hand-held powered drills, tappers, fastener drivers, horizontal, vertical, and angle grinders with wheels greater than 2 inches in diameter, disc sanders, belt sanders, reciprocating saws, saber saws, and other similar operating powered tools shall be equipped with a momentary contact "on-off" control and may have a lock-on control provided that turnoff can be accomplished by a single motion of the same finger or fingers that turn it on.

All other hand-held powered tools, such as circular saws, chain saws, and percussion tools without positive accessory holding means, shall be equipped with a constant pressure switch that will shut off the power when the pressure is released.

Hand Tools

A wrench, including adjustable, pipe, end, and socket wrenches shall not be used when jaws are sprung to the point that slippage occurs.

Impact tools, such as drift pins, wedges, and chisels, shall be kept free of mushroomed heads.

The wooden handles of tools shall be kept free of splinters or cracks and shall be kept tight in the tool.

Power-Operated Hand Tools

Electric power operated tools shall either be of the approved double-insulated type or grounded in accordance with Subpart K of this part.

The use of electric cords for hoisting or lowering tools shall not be permitted.

Pneumatic power tools shall be secured to the hose or whip by some positive means to prevent the tool from becoming accidentally disconnected.

Safety clips or retainers shall be securely installed and maintained on pneumatic impact (percussion) tools to prevent attachments from being accidentally expelled.


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All pneumatically driven nailers, staplers, and other similar equipment provided with automatic fastener feed, which operate at more than 100 p.s.i. pressure at the tool shall have a safety device on the muzzle to prevent the tool from ejecting fasteners, unless the muzzle is in contact with the work surface.

Compressed air shall not be used for cleaning purposes except where reduced to less than 30 p.s.i. and then only with effective chip guarding and personal protective equipment which meets the requirements of Subpart E of this part. The 30 p.s.i. requirement does not apply for concrete form, mill scale and similar cleaning purposes.

The manufacturer's safe operating pressure for hoses, pipes, valves, filters, and other fittings shall not be exceeded,

The use of hoses for hoisting or lowering tools shall not be permitted. All hoses exceeding 1/2-inch inside diameter shall have a safety

device at the source of supply or branch line to reduce pressure in case of hose failure.

Airless spray guns of the type which atomize paints and fluids at high pressures (1,000 pounds or more per square inch) shall be equipped with automatic or visible manual safety devices which will prevent pulling of the trigger to prevent release of the paint or fluid until the safety device is manually released.

In lieu of the above, a diffuser nut which will prevent high pressure, high velocity release, while the nozzle tip is removed, plus a nozzle tip guard which will prevent the tip from coming into contact with the operator, or other equivalent protection, shall be provided.

The blast cleaning nozzles shall be equipped with an operating valve which must be held open manually. A support shall be provided on which the nozzle may be mounted when it is not in use.

Fuel Powered Tools

All fuel powered tools shall be stopped while being refueled, serviced, or maintained, and fuel shall be transported, handled, and appropriately stored.

When fuel powered tools are used in enclosed spaces, the applicable requirements for concentrations of toxic gases and use of personal protective equipment shall apply.


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Hydraulic Power Tools

The fluid used in hydraulic powered tools shall be fire-resistant fluids approved under Schedule 30 of the U.S. Bureau of Mines, Department of the Interior, and shall retain its operating characteristics at the most extreme temperatures to which it will be exposed.

The manufacturer's safe operating pressures for hoses, valves, pipes, filters, and other fittings shall not be exceeded.

Powder-Actuated Tools

Only employees who have been trained in the operation of the particular tool in use shall be allowed to operate a powder-actuated tool.

The tool shall be tested each day before loading to see that safety devices are in proper working condition. The method of testing shall be in accordance with the manufacturer's recommended procedure.

Any tool found not in proper working order, or that develops a defect during use, shall be immediately removed from service and not used until properly repaired.

Tools shall not be loaded until just prior to the intended firing time. Neither loaded nor empty tools are to be pointed at any employees. Hands shall be kept clear of the open barrel end.

Loaded tools shall not be left unattended. Fasteners shall not be driven into very hard or brittle materials

including, but not limited to, cast iron, glazed tile, surface-hardened steel, glass block, live rock, face brick, or hollow tile.

Driving into materials easily penetrated shall be avoided unless such materials are backed by a substance that will prevent the pin or fastener from passing completely through and creating a flying missile hazard on the other side.

No fastener shall be driven into a spalled area caused by an unsatisfactory fastening.

Tools shall not be used in an explosive or flammable atmosphere. All tools shall be used with the correct shield, guard, or attachment

recommended by the manufacturer. Powder-actuated tools used by employees shall meet all other

applicable requirements of American National Standards Institute, A10.3-1970, Safety Requirements for Explosive-Actuated Fastening Tools.


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Jacks - lever and ratchet, screw, and hydraulic

The manufacturer's rated capacity shall be legibly marked on all jacks and shall not be exceeded.

All jacks shall have a positive stop to prevent over travel. When it is necessary to provide a firm foundation, the base of the jack

shall be blocked or cribbed. Where there is a possibility of slippage of the metal cap of the jack, a wood block shall be placed between the cap and the load.

After the load has been raised, it shall be cribbed, blocked, or otherwise secured at once.

Hydraulic jacks exposed to freezing temperatures shall be supplied with an adequate antifreeze liquid.

All jacks shall be properly lubricated at regular intervals. Each jack shall be thoroughly inspected at times which depend upon

the service conditions. Inspections shall be not less frequent than the following:

For constant or intermittent use at one locality, once every 6 months, For jacks sent out of shop for special work, when sent out and when

returned, For a jack subjected to abnormal load or shock, immediately before

and immediately thereafter. Repair or replacement parts shall be examined for possible defects. Jacks which are out of order shall be tagged accordingly, and shall not

be used until repairs are made.

4 TRAINING

None

5 REFERENCE

None

6 APPENDICES

None

LOCK OUT / TAG OUT FIELD SAFETY

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THIS PROCEDURE IS NOT RELATED TO PROVIDED SERVICES


1 PURPOSE AND SCOPE

Purpose

This program covers the servicing and maintenance of machines and equipment in which the "unexpected" energization or start up of the machines or equipment, or release of stored energy could cause injury to employees. This program establishes minimum performance requirements for the control of such hazardous energy.

Scope

This program applies to the control of energy during servicing and/or maintenance of machines and equipment.

Normal production operations are not covered by this program. Servicing and/or maintenance which take place during normal production operations are covered by this program only if:

An employee is required to remove or bypass a guard or other safety device; or

An employee is required to place any part of his or her body into an area on a machine or piece of equipment where work is actually performed upon the material being processed (point of operation) or where an associated danger zone exists during a machine operating cycle.

Exception: Minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by this program if they are routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection.


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This program does not apply to the following:

Work on cord and plug connected electric equipment for which exposure to the hazards of unexpected energization or start up of the equipment is controlled by the unplugging of the equipment from the energy source and by the plug being under the exclusive control of the employee performing the servicing or maintenance.

Hot tap operations involving transmission and distribution systems for substances such as gas, steam, water or petroleum products when they are performed on pressurized pipelines, provided that the owner demonstrates that continuity of service is essential; shutdown of the system is impractical; and documented procedures are followed, and special equipment is used which will provide proven effective protection for employees.

2 GENERAL

Definitions

Affected employee: An employee whose job requires him/her to operate or use a machine or equipment on which servicing or maintenance is being performed under lockout or tagout, or whose job requires him/her to work in an area in which such servicing or maintenance is being performed. Authorized employee: A person who locks out or tags out machines or equipment in order to perform servicing or maintenance on that machine or equipment. An affected employee becomes an authorized employee when that employee's duties include performing servicing or maintenance covered under this section. Capable of being locked out: An energy isolating device is capable of being locked out if it has a hasp or other means of attachment to which, or through which, a lock can be affixed, or it has a locking mechanism built into it. Other energy isolating devices are capable of being locked out, if lockout can be achieved without the need to dismantle, rebuild, or replace the energy isolating device or permanently alter its energy control capability. Energized:


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Connected to an energy source or containing residual or stored energy. Energy isolating device: A mechanical device that physically prevents the transmission or release or energy, including but not limited to the following: A manually operated electrical circuit breaker, a disconnect switch, a manually operated switch by which the conductors of a circuit can be disconnected from all ungrounded supply conductors and, in addition, no pole can be operated independently; a line valve; a block; and any similar device used to block or isolate energy. Push buttons, selector switches and other control circuit type devices are not energy isolating devices. Energy source: Any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy. Hot tap: A procedure used in the repair maintenance and services activities which involves welding on a piece of equipment (pipelines, vessels or tanks) under pressure, in order to install connections or appurtenances. It is commonly used to replace or add sections of pipeline without the interruption of service for air, gas, water, steam, and petrochemical distribution systems. Lockout: The placement of a lockout device on an energy isolating device, in accordance with an established procedure, ensuring that the energy isolating device and the equipment being controlled cannot be operated until the lockout device is removed. Lockout device: A device that utilizes a positive means such as a lock, either key or combination type, to hold an energy isolating device in the safe position and prevent the energizing of a machine or equipment. Included are blank flanges and bolted slip blinds. Normal production operations: The utilization of a machine or equipment to perform its intended production function. Potential Energy: Potential energy may include any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy.


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Servicing and/or maintenance: Workplace activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. These activities include lubrication, cleaning or unjamming of machines or equipment and making adjustments or tool changes, where the employee may be exposed to the unexpected energization or startup of the equipment or release of hazardous energy. Setting up: Any work performed to prepare a machine or equipment to perform its normal production operation. Tagout: The placement of a tagout device on an energy isolating device, in accordance with an established procedure, to indicate that the energy isolating device and the equipment being controlled may not be operated until the tagout device is removed. Tagout device: A prominent warning device, such as a tag and a means of attachment, which can be securely fastened to an energy isolating device in accordance with an established procedure, to indicate that the energy isolating device and the equipment being controlled may not be operated until the tagout device is removed.

RESPONSIBILITES Non-applicable

3 PROCEDURE

The owner shall establish a program consisting of energy control procedures, employee training and to periodic inspections to ensure that before any employee or contractor performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative.

If an energy isolating device is not capable of being locked out, the

owner‘s energy control program shall utilize a tagout system.


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If an energy isolating device is capable of being locked out, the owner‘s energy control program shall utilize lockout, unless the owner can demonstrate that the utilization of a tagout system will provide full employee protection.

Whenever replacement or major repair, renovation or modification of a

machine or equipment is performed, and whenever new machines or equipment are installed, energy isolating devices for such machine or equipment shall be designed to accept a lockout device.

When a tagout device is used on an energy isolating device which is

capable of being locked out, the tagout device shall be attached at the same location that the lockout device would have been attached, and the client shall demonstrate that the tagout program will provide a level of safety equivalent to that obtained by using a lockout program.

In demonstrating that a level of safety is achieved in the tagout program

which is equivalent to the level of safety obtained by using a lockout program, the owner shall demonstrate full compliance with all tagout-related provisions of this standard together with such additional elements as are necessary to provide the equivalent safety available from the use of a lockout device. Additional means to be considered as part of the demonstration of full employee protection shall include the implementation of additional safety measures such as the removal of an isolating circuit element, blocking of a controlling switch, opening of an extra disconnecting device, or the removal of a valve handle to reduce the likelihood of inadvertent energization.

Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section.

Exception: The owner need not document the required procedure for a

particular machine or equipment, when all of the following elements exist:

The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees:

the machine or equipment has a single energy source which can be readily identified and isolated:

the isolation and locking out of that energy source will completely de-energize and deactivate the machine or equipment:


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the machine or equipment is isolated from that energy source and locked out during servicing or maintenance:

a single lockout device will achieve a locker-out condition:

the lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance:

the servicing or maintenance does not create hazards for other employees; and

the owner, in utilizing this exception, has had no accidents involving the unexpected activation or re-energization of the machine or equipment during servicing or maintenance.

Locks, tags, chains, wedges, key blocks, adapter pins, self-locking

fasteners, or other hardware shall be provided by the owner for isolating, securing or blocking of machines or equipment from energy sources.

Lockout devices and tagout devices shall be singularly identified; shall be

the only device(s) used for controlling energy; shall not be used for other purposes; and shall meet the following requirements:

Lockout and tagout devices shall be capable of withstanding the

environment to which they are exposed for the maximum period of time that exposure is expected

Tagout devices shall be constructed and printed so that exposure to

weather conditions or wet and damp locations will not cause the tag to deteriorate or the message on the tag to become illegible.

Tags shall not deteriorate when used in corrosive environments such as

areas where acid and alkali chemicals are handled and stored. Lockout and tagout devices shall be standardized within the facility in at

least one of the following criteria: Color; shape; or size; and additionally, in the case of tagout devices, print and format shall be standardized. Lockout devices shall be substantial enough to prevent removal without the use of excessive force or unusual techniques, such as with the use of bolt cutters or other metal cutting tools.

Tagout devices, including their means of attachment, shall be substantial

enough to prevent inadvertent or accidental removal. Tagout device attachment means shall be of a non-reusable type, attachable by hand,


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self-locking, and non-releasable with a minimum unlocking strength of no less than 50 pounds and having the general design and basic characteristics of being at least equivalent to a one-piece, all environment-tolerant nylon cable tie.

Lockout devices and tagout devices shall indicate the identity of the

employee applying the device(s). Tagout devices shall warn against hazardous conditions if the machine or

equipment is energized and shall include a legend such as the following: "Do Not Start. Do Not Open. Do Not Close. Do Not Energize. Do Not Operate."

The owner shall conduct a periodic inspection of the energy control

procedure at least annually to ensure that the procedure and the requirements of this standard are being followed.

The periodic inspection shall be performed by an authorized employee

other than the one(s) utilizing the energy control procedure being inspected.

The periodic inspection shall be conducted to correct any deviations or

inadequacies identified. Where lockout is used for energy control, the periodic inspection shall

include a review, between the inspector and each authorized employee, of that employee's responsibilities under the energy control procedure being inspected.

Where tagout is used for energy control, the periodic inspection shall

include a review, between the inspector and each authorized and affected employee, of that employee's responsibilities under the energy control procedure being inspected, and the elements set forth in paragraph (c)(7)(ii) of this section.

The owner shall certify that the periodic inspections have been performed.

The certification shall identify the machine or equipment on which the energy control procedure was being utilized, the date of the inspection, the employees included in the inspection, and the person performing the inspection.

The owner shall provide training to ensure that the purpose and function of

the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal


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of the energy controls are acquired by employees. The training shall include the following:

Each authorized employee shall receive training in the recognition of

applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control.

Each affected employee shall be instructed in the purpose and use of the

energy control procedure. All other employees whose work operations are or may be in an area

where energy control procedures may be utilized, shall be instructed about the procedure, and about the prohibition relating to attempts to restart or reenergize machines or equipment which are locked out or tagged out.

When tagout systems are used, employees shall also be trained in the

following limitations of tags: Tags are essentially warning devices affixed to energy isolating devices,

and do not provide the physical restraint on those devices that is provided by a lock.

When a tag is attached to an energy isolating means, it is not to be

removed without authorization of the authorized person responsible for it, and it is never to be bypassed, ignored, or otherwise defeated.

Tags must be legible and understandable by all authorized employees,

affected employees, and all other employees whose work operations are or may be in the area, in order to be effective.

Tags and their means of attachment must be made of materials which will

withstand the environmental conditions encountered in the workplace. Tags may evoke a false sense of security, and their meaning needs to be

understood as part of the overall energy control program. Tags must be securely attached to energy isolating devices so that they

cannot be inadvertently or accidentally detached during use. Retraining shall be provided for all authorized and affected employees

whenever there is a change in their job assignments, a change in machines, equipment or processes that present a new hazard, or when there is a change in the energy control procedures.


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Additional retraining shall also be conducted whenever a periodic

inspection reveals, or whenever the owner has reason to believe that there are deviations from or inadequacies in the employee's knowledge or use of the energy control procedures.

The retraining shall reestablish employee proficiency and introduce new or

revised control methods and procedures, as necessary. The owner shall certify that employee training has been accomplished and

is being kept up to date. The certification shall contain each employee's name and dates of training.

Lockout or tagout shall be performed only by the authorized employees

who are performing the servicing or maintenance. Affected employees shall be notified by the owner or authorized employee

of the application and removal of lockout devices or tagout devices. Notification shall be given before the controls are applied, and after they are removed from the machine or equipment.

The established procedures for the application of energy control (the

lockout or tagout procedures) shall cover the following elements and actions and shall be done in the following sequence:

Before an authorized or affected employee turns off a machine or

equipment, the authorized employee shall have knowledge of the type and magnitude of the energy, the hazards of the energy to be controlled, and the method or means to control the energy.

The machine or equipment shall be turned off or shut down using the

procedures established for the machine or equipment. An orderly shutdown must be utilized to avoid any additional or increased hazard(s) to employees as a result of the equipment stoppage.

All energy isolating devices that are needed to control the energy to the

machine or equipment shall be physically located and operated in such a manner as to isolate the machine or equipment from the energy source(s).

Lockout or tagout devices shall be affixed to each energy isolating device

by authorized employees. Lockout devices, where used, shall be affixed in a manner to that will hold

the energy isolating devices in a "safe" or "off" position.


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Tagout devices, where used, shall be affixed in such a manner as will

clearly indicate that the operation or movement of energy isolating devices from the "safe" or "off" position is prohibited.

Where tagout devices are used with energy isolating devices designed

with the capability of being locked, the tag attachment shall be fastened at the same point at which the lock would have been attached.

Where a tag cannot be affixed directly to the energy isolating device, the

tag shall be located as close as safely possible to the device, in a position that will be immediately obvious to anyone attempting to operate the device.

Following the application of logout or tagout devices to energy isolating

devices, all potentially hazardous stored or residual energy shall be relieved, disconnected, restrained, and otherwise rendered safe.

If there is a possibility of re-accumulation of stored energy to a hazardous

level, verification of isolation shall be continued until the servicing or maintenance is completed, or until the possibility of such accumulation no longer exists.

Prior to starting work on machines or equipment that have been locked out

or tagged out; the authorized employee shall verify that isolation and de-energization of the machine or equipment have been accomplished.

Before lockout or tagout devices are removed and energy is restored to

the machine or equipment, procedures shall be followed and actions taken by the authorized employee(s) to ensure the following:

The work area shall be inspected to ensure that nonessential items have

been removed and to ensure that machine or equipment components are operationally intact.

The work area shall be checked to ensure that all employees have been

safely positioned or removed. After lockout or tagout devices have been removed and before a machine

or equipment is started, affected employees shall be notified that the lockout or tagout device(s) have been removed.

Each lockout or tagout device shall be removed from each energy

isolating device by the employee who applied the device. Exception to


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paragraph (e) (3). When the authorized employee who applied the lockout or tagout device is not available to remove it, that device may be removed under the direction of the owner, provided that specific procedures and training for such removal have been developed, documented and incorporated into the owner's energy control program. The owner shall demonstrate that the specific procedure shall include at least the following elements:

Verification by the owner that the authorized employee who applied the

device is not at the facility. Making all reasonable efforts to contact the authorized employee to inform

him/her that his/her lockout or tagout device has been removed; and ensuring that the authorized employee has this knowledge before he/she resumes work at that facility.

In situations in which lockout or tagout devices must be temporarily

removed from the energy isolating device and the machine or equipment energized to test or position the machine, equipment or component thereof, the following sequence of actions shall be followed:

Clear the machine or equipment of tools and materials.

Remove employees from the machine or equipment area.

Remove the lockout or tagout devices.

Energize and proceed with testing or positioning.

De-energize all systems and reapply energy control measures to continue the servicing and/or maintenance.

Whenever outside servicing personnel are to be engaged in activities covered by the scope and application of this standard, the on-site owner and the outside owner shall inform each other of their respective lockout or tagout procedures.

The on-site owner shall ensure that his/her employees understand and

comply with the restrictions and prohibitions of the outside owner's energy control program.

When servicing and/or maintenance is performed by a crew, craft,

department or other group, they shall utilize a procedure which affords the employees a level of protection equivalent to that provided by the implementation of a personal lockout or tagout device.


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Group lockout or tagout devices shall be used including, but not

necessarily limited to, the following specific requirements: Primary responsibility is vested in an authorized employee for a set

number of employees working under the protection of a group lockout or tagout device (such as an operations lock);

Provision for the authorized employee to ascertain the exposure status of

individual group members with regard to the lockout or tagout of the machine or equipment and

When more than one crew, craft, department, etc. is involved, assignment

of overall job-associated lockout or tagout control responsibility to an authorized employee designated to coordinate affected work forces and ensure continuity of protection; and

Each authorized employee shall affix a personal lockout or tagout device

to the group lockout device, group lockbox, or comparable mechanism when he or she begins work, and shall remove those devices when he or she stops working on the machine or equipment being serviced or maintained.

Specific procedures shall be utilized during shift or personnel changes to

ensure the continuity of lockout or tagout protection, including provision for the orderly transfer of lockout or tagout device protection between off-going and oncoming employees, to minimize exposure to hazards from the unexpected energization or start-up of the machine or equipment, or the release of stored energy

4 TRAINING

None

5 REFERENCE

None

6 APPENDICES

None

HYDROGEN SULFIDE AWARENESS

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Becht Engineering Co., Inc. is dedicated to ensuring the safety of internal employees, Advisors and fellow workers at Client sites. Becht Engineering is also committed to providing an injury free work environment and maintaining safety awareness as an integral part of our work ethic.

1 PURPOSE AND SCOPE

Purpose

This standard is to establish the minimum acceptable standards for performing work on equipment which processes streams containing H2S and prevent personnel exposure to Hydrogen Sulfide (H2S). Scope

This Hydrogen Sulfide procedure applies to all Becht Engineering employees.

2 GENERAL

To ensure the greatest possible protection for employees in the workplace, the cooperative efforts of both employers and employees will help in establishing and maintaining a safe and healthful work environment.

Hydrogen sulfide is a colorless, flammable, soluble, extremely hazardous gas with a ―rotten egg‖ smell. It occurs naturally in crude petroleum and natural gas, and can be produced by the breakdown of organic matter and human/ animal wastes (e.g., sewage). It is heavier than air and can collect in low-lying and enclosed, poorly ventilated areas such as basements, manholes, sewer lines and underground telephone/electrical vaults. Can be smelled at low levels, but with continuous low level exposure or at higher concentrations you lose your ability to smell the gas even though it is still present.

***NOTE*** No Becht employee is authorized to work on any equipment which may contain H2S. All work involving H2S will be removed by the facility prior to our work beginning. This program is provided simply as general awareness program.


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At high concentrations – your ability to smell the gas can be lost instantly. DO NOT depend on your sense of smell for indicating the continuing presence of this gas or for warning of hazardous concentrations. Toxicity: Hydrogen sulfide is considered a broad-spectrum poison, meaning that it can poison several different systems in the body, although the nervous system is most affected. The toxicity of H2S is comparable with that of hydrogen cyanide. It forms a complex bond with iron in the mitochondrial cytochrome enzymes, thereby blocking oxygen from binding and stopping cellular respiration. Since hydrogen sulfide occurs naturally in the environment and the gut, enzymes exist in the body capable of detoxifying it by oxidation to (harmless) sulfate.[6] Hence, low levels of sulfide may be tolerated indefinitely. At some threshold level, believed to average around 300–350 ppm, the oxidative enzymes become overwhelmed. Many personal safety gas detectors, such as those used by utility, sewage and petrochemical workers, are set to alarm at as low as 5 to 10 ppm and to go into high alarm at 15 ppm. In the event of an alarm, workers should vacate the area immediately. Never attempt to rescue an H2S victim without a SCBA. An interesting diagnostic clue of extreme poisoning by H2S is the discoloration of copper coins in the pockets of the victim. Treatment involves immediate inhalation of amyl nitrite, injections of sodium nitrite, inhalation of pure oxygen, administration of bronchodilators to overcome eventual bronchospasm, and in some cases hyperbaric oxygen therapy (HBO). HBO therapy has anecdotal support and remains controversial.[7][8][9]

3 EFFECTS

Health effects vary with how long, and at what level, you are exposed. Asthmatics may be at greater risk. Exposure to lower concentrations can result in eye irritation, a sore throat and cough, nausea, shortness of breath, and fluid in the lungs. These symptoms usually go away in a few weeks. Long-term, low-level exposure may result in fatigue, loss of appetite, headaches, irritability, poor memory, and dizziness. Chronic exposures to low level H2S (around 2 ppm) has been implicated in increased miscarriage and reproductive health issues amongst Russian and Finnish wood pulp workers, but the reports have not (as of circa 1995) been replicated. Higher concentrations of 700–800 ppm tend to be fatal.

0.0047 ppm is the recognition threshold, the concentration at which 50% of humans can detect the characteristic odor of hydrogen sulfide [1], normally described as resembling "a rotten egg".

http://en.wikipedia.org/wiki/Nervous_system

http://en.wikipedia.org/wiki/Hydrogen_cyanide

http://en.wikipedia.org/wiki/Iron

http://en.wikipedia.org/wiki/Mitochondria

http://en.wikipedia.org/wiki/Cytochrome

http://en.wikipedia.org/wiki/Enzyme

http://en.wikipedia.org/wiki/Cellular_respiration

http://en.wikipedia.org/wiki/Hydrogen_sulfide#cite_note-5

http://en.wikipedia.org/wiki/Copper

http://en.wikipedia.org/wiki/Amyl_nitrite

http://en.wikipedia.org/wiki/Sodium_nitrite

http://en.wikipedia.org/wiki/Bronchodilator

http://en.wikipedia.org/wiki/Bronchospasm

http://en.wikipedia.org/wiki/Hyperbaric_oxygen_therapy




http://en.wikipedia.org/wiki/Eye

http://en.wikipedia.org/wiki/Cough

http://en.wikipedia.org/wiki/Lung

http://en.wikipedia.org/wiki/Fatigue_(physical)

http://en.wikipedia.org/wiki/Headach

http://en.wikipedia.org/wiki/Dizziness

http://en.wikipedia.org/wiki/Parts_per_million

http://en.wikipedia.org/wiki/Parts_per_million

http://www.extension.iastate.edu/Publications/PM1963A.pdf


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Less than 10 ppm has an exposure limit of 8 hours per day. 10–20 ppm is the borderline concentration for eye irritation. 50–100 ppm leads to eye damage. At 150–250 ppm the olfactory nerve is paralyzed after a few inhalations,

and the sense of smell disappears, often together with awareness of danger,

320–530 ppm leads to pulmonary edema with the possibility of death. 530–1000 ppm causes strong stimulation of the central nervous system

and rapid breathing, leading to loss of breathing; o 800 ppm is the lethal concentration for 50% of humans for 5

minutes exposure(LC50). Concentrations over 1000 ppm cause immediate collapse with loss of

breathing, even after inhalation of a single breath.

4 TRAINING

All current and new employees should receive training in standard operating procedures covering all aspects of the job, with emphasis on safe work practices. Where appropriate, training should also include field observations (on-the-job training) by qualified supervisory personnel, including verification that workers have satisfied the training requirements. Training must include proper procedures for working around areas of potential exposure to hazardous chemicals and include the hazards of exposure. While labeling of pipes cannot be required, the hazard communication standard does require that the employer address the hazards of unlabeled piping systems in a written hazard communication program and that the information be provided through training to workers.

5 GUIDELINES

Use detection equipment when working in an area where there is a possibility of H2S

gas, especially in enclosed or below grade areas (holes, trenches, reserve pits).

Maintain and calibrate detection equipment per manufacturer‘s specifications.

Do not enter an H2S area without proper training and authorization.

In IDLH atmospheres a standby person(s) with suitable Self Contained Breathing

Apparatus (SCBA) must be available for purposes of rescue.

Never attempt to rescue an H2S victim without a SCBA.

Employees working in H2S areas are required to be properly ―fit tested‖.

http://en.wikipedia.org/wiki/Olfactory_nerve

http://en.wikipedia.org/wiki/Pulmonary_edema

http://en.wikipedia.org/wiki/Central_nervous_system

http://en.wikipedia.org/wiki/LC50


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All H2S exposure victims should be treated by a physician before returning to work.

In the event of a H2S emergency, all personnel should follow the site emergency plan.

H2S areas, facilities, pipelines, and/or flowlines should be properly identified with signage.

6 REFERENCES

29 CFR 1926.55(a) 29 CFR 1910.1200

7 APPENDICES

None

GENERAL WASTE MANAGEMENT

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1 PURPOSE AND SCOPE

Purpose

The Waste Management Policy is implemented to ensure that all wastes are disposed of properly. Scope

The Waste Management Policy applies to all Becht Engineering employees.

2 GENERAL

If a project Becht Engineering is involved in has the potential to produce waste, a meeting will take place prior to the commencement of the project to estimate the amount of waste that will be produced in order to ensure proper containers and adequate waste removal services are available. The following procedures will be implemented upon inception of a project producing waste: Communication Plan: Becht Engineering will attend a meeting conducted by the General

Contractor (company who will be performing waste management/clean up) on-site, prior to the commencement of work. Attendance will be required for all contractors‘ and subcontractors‘ key field personnel.

Each site has a designated waste management/recycling coordinator. Prior to inception of services, the contact information for this coordinator will be provided to employees. The waste coordinator ensures the proper disposal or reuse of waste material at the site.

Waste prevention and recycling activities will be discussed at the beginning of each weekly contractor coordination meeting to reinforce project goals and communicate progress to date.

The subcontractor will be expected to ensure that all of its employees comply with the Waste Management Plan.

Becht Engineering will ensure that the Client is aware of the amount of waste that is being generated so that arrangements for disposal services will be coordinated appropriately.

Proper segregation of waste and re-usable materials is required. If there is a potential for the waste material to be used again, it must be recycled, as necessary.


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All recycling containers will be clearly labeled. Containers shall be located

in close proximity to the building(s) under construction in which recyclables/salvageable materials will be placed.

Lists of acceptable/unacceptable materials are posted throughout each site by the Client.

All subcontractors must be informed in writing of the importance of non-contamination with other materials or trash.

Recycling coordinators inspect the containers on a weekly basis to insure that no contamination is occurring and precautions shall also be taken to deter any contamination by the public.

Controls and Disposal of Waste: Left-over materials, scrap or waste will be picked up and placed in

containers as generated. All waste containers shall be emptied by the site‘s contracted maintenance personnel on a regular basis, so as to prevent over-flowing conditions. All handling and disposal will be conducted in such a fashion as to minimize secondary contamination by overflow or spillage during waste transfer.

The production, segregation, transportation, treatment, and disposal of waste involves the handling of potentially hazardous material. Protection against personal injury is therefore essential for all workers who are at risk. The individuals responsible for management of waste should ensure that all risks are identified and that suitable protection from those risks is provided.

A comprehensive risk assessment of all activities involved in waste management, carried out during preparation of the waste management plan, will allow the identification of necessary protection measures. These measures should be designed to prevent exposure to hazardous materials or other risks, or at least to keep exposure within safe limits. Once the assessment is completed, personnel should receive suitable training.

Personal Protective Equipment:

The type of protective clothing used will depend to an extent upon the risk associated with the waste, but the following will be made available to all personnel who collect or handle waste: Health and safety practices for construction personnel and waste workers. Hardhats with or without visors, depending on the operation. Face masks, depending on operation. Eye protectors (safety goggles and/or glasses), depending on operation. Protective clothing (coveralls).


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Industrial aprons. Leg protectors and/or industrial boots. Disposable gloves or heavy-duty gloves.

o Industrial boots and heavy-duty gloves are particularly important for waste workers. The thick soles of the boots offer protection in the storage area, as a precaution from sharp materials, and where floors are slippery.

Disposal of Demolition and Other Construction Debris: Disposition of construction debris shall be conducted as follows: All

wastes generated by demolition activities shall be segregated as much as practicable, and placed in a dumpster, so as to minimize potential impact to the environment.

GENERAL: Upon completion of all demolition activities, the area shall be clean, absent of signs of demolition, construction, temporary construction barriers or demolished structures. Exceptions to this requirement shall be specifically defined within the scope of work for the task order.

SEWAGE: All sewage will be disposed of through connections to established sanitary systems. Where such systems are not available, chemical toilets or comparable effective units will be used with collected wastes periodically emptied by means of a sanitary pumping service. No conditions shall be allowed to exist where noticeable odors are present.

DUST CONTROL: Positive dust control shall be exercised at all times during this project. Dust generation during (saw-cutting or chipping) activities shall be minimized by a constant water stream wetting the concrete. All efforts to minimize dust generation with water spray shall be expended.

CHEMICALS AND CHEMICAL WASTE: In the event that a chemical is put into use in some form (after submittals and approvals are obtained, if required), the following procedure shall be followed:

All chemicals shall be dispensed ensuring no spillage to the ground or water. Periodic inspections of dispensing areas to identify leakage and initiate corrective action.

All activities and inspection shall be documented.

Chemical waste shall be collected in corrosive resistant containers. All chemical containers shall be investigated to assure chemical compatibility with the medium to be collected.

Collection drums shall be monitored and removed to a storage or staging area when contents are within 6-inches of the top.

Wastes shall be classified, managed, stored and disposed of in accordance with Federal, State, and local laws and regulations.

HAZARDOUS WASTE MANAGEMENT AND DISPOSAL: Hazardous waste generated during the course of this project will be appropriately


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classified by the responsible party (as determined by contract) and removed for appropriate disposal by a licensed disposal company.

FUELS AND LUBRICATION: Any fuels brought on-site by the contractor shall be in approved, self-closing, leak-proof, steel containers. These containers (if any) shall not be stored in a designated area and provide secondary containment as required.

WASTEWATER DISPOSAL: Wastewater generated during the course of

these construction activities, such as spray-waters used during trenching, shall not be allowed to enter any waterways or to enter any storm drain system. Any generated wastewater shall be treated to remove any contaminants prior to discharge, or shall be captured, stored and removed from the facility as potentially contaminated wastewater. No wastewater shall be disposed of without compliance with all Federal, State, or local laws and regulations.

GARBAGE DISPOSAL: The designated contract company will place all

generated garbage in an appropriate container and arrange for disposal by means of contracted vendor, which can provide a timely pick-up.

3 TRAINING

All workers, including managers and supervisors, shall be provided instruction and guidance on the Waste Management Policy. This training is provided:

When the Waste Management Policy is first established. To all new employees. Whenever employee demonstrates lack of knowledge of the

Waste Management Policy‘s procedures. Whenever any changes are made to the Waste Management

Policy. Whenever specific roles or responsibilities are assigned.

Employees will also be instructed on the proper disposal methods for waste. If applicable, this will include general instruction on disposal of non-hazardous wastes, trash or scrap metals. If there is a potential for any of the waste to be hazardous, employees will receive further training on the proper disposal of hazardous wastes.


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4 REFERENCE

None

5 APPENDICES

None

SHORT SERVICE EMPLOYEE PROGRAM

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1 PURPOSE AND SCOPE

Purpose

To establish basic procedures to assimilate employees new to any refinery or complex. Employees who are familiarized with a site and its hazards will be less susceptible to being involved in a work-related incident. Scope

The Short Service Employee Program will apply to any employee with less than six months of satisfactory experience at a Refinery or Chemical Site and has not graduated to SSMP status. The program also applies to a employee who has been graduated as a SSMP but has been away from the site for longer than six months.

2 GENERAL

Definitions

―Area/Sites‖ Refers to a Client Chemical Plant, Polyethylene Plant, Lubes Plant or Refinery. Also referred to as Site. ―Buddy‖ A contract employee, designated by the Contract Company, which serves as the mentor/coach for the Short Service Employee (SSE) in the field. The Buddy must have on-going daily contact with the SSE to ensure proper coaching and mentoring occurs. ―Contract Company‖ Any company under contract to provide services at a Client Site and subcontractors to the contract companies. ―Buddy Manager‖

The management representative that serves as the Safety Liaison between the Client contact and the contract company.

―Site Contact‖


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A Mechanical or Process person that is serving as the frontline supervisor of the contract work group. ―Maintenance Work Practice‖ Craft specific safe work practices used at a Client Site. ―Mentor/Coach‖ A contract employee designated and trained by his Contract Company to serve as a Buddy to new-to-the-site employees. This individual is responsible for guiding and monitoring the safety performance of the SSE in the field. ―Short Service Employee (SSE)‖ Any contract employee with less than 6 months of satisfactory experience at the assigned Refinery/ Chemical Site and who has not graduated to SSMP, or a employee who had previously worked at a Site as a SSMP but has been gone for more than 6 months. SSEs are also referred to as Vulnerable Employees since they are more vulnerable to injuries and incidents due to their limited knowledge of the safety requirements and hazards of the worksite. ―Site Safety Mature Person (SSMP)‖ A contract employee who has demonstrated his/her working knowledge and skills in regards to site hazards, hazard management, and safe working practices to the Mentor/Coach and Supervisor, and is qualified to act as a SSMP (see details in Attachment 1). Contract personnel become SSMPs after graduating from the SSE Program. ―Site Safety Standard (SSS)‖ Safety standards used at the Beaumont Complex. ―Supervisor‖ A contract employee designated by their contract company to serve in a leadership capacity. Contract companies shall ensure appropriate training, experience and demonstrated leadership skills are in place before designating personnel as Supervisors.


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Responsibilities

Becht Engineering- Contract Company

o Limit the number of SSEs on-site as much as practical. o Ensure any subcontracted companies have an acceptable SSE Program

in place prior to contracting work. Subcontractors must be managed in alignment with this policy.

o Prior to mobilizing SSE employees, Becht Engineering will notify the project coordinator or onsite supervisor to test the availability of SSMPs before accepting the additional work.

o Acquire approval from Site Management or their Buddy Manager for the percentage of SSEs versus SSMPs on the site. The onsite supervisor or project coordinator will determine the approval status of the crew makeup (ratios defined on page 10).

o Ensure a trained Mentor/Coach is present in the field where SSEs are working and be responsible for a maximum number of SSEs depending on the potential hazards, the nature of the task, and general requirements as agreed by the Buddy Manager or equivalent designated representative.

o Immediately notify the Client Contact and Buddy Manager (if applicable) if SSMP ratio is not attainable and receive written approval on the plan for managing SSEs above the approved ratio.

o Ensure SSEs are distributed evenly across field work crews. o Supply the required identification for the vulnerable employee and ensure

it is used. o A list of SSEs will be maintained and will include the date of initial entry to

the Complex and date of graduation to Site Safe Mature Person. o Actively assimilate and train SSEs so that they will graduate within six

months. o Regularly assess and determine suitability of the SSE for continued work

at the Site. o Provide feedback to the SSE on improvement opportunities and

necessary focus areas. o Immediately remove SSEs from the site if unsuitable or unable to

complete program in six months. o Ensure SSEs are assigned a Buddy who actively mentors and coaches

the SSEs to successful graduation from the program. o Establish written expectations for the Buddy and Supervision to follow in

completing the assimilation and training of SSEs. o Train Buddy(s) and Supervision on expectations and SSE program. o Verify that the SSE has not only completed required training and

assimilation but has also demonstrated knowledge of it.


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o Formally graduate SSEs who have completed the requirements of the program at a Safety Meeting/Luncheon.

o Ensure that recently graduated SSMPs are assigned job tasks in accordance with Becht Engineering‘s evaluation of their ability, and complete any other additional training or assimilation required above and beyond the SSE Program.

o Maintain up-to-date auditable records for each SSE and report status of the SSE Program to the Client quarterly.

Supervisor/ Mentor/Coach

o Complete training on applicable roles and responsibilities. o Demonstrate experience as a Mentor/Coach. o Must have graduated as an SSMP. o Demonstrate safety and leadership skills. o Guide and monitor safety performance of the SSEs. o Track progress of SSEs and report to Supervision or Becht Engineering

Safety Coordinator regularly. o Assist in SSE graduation process.

Short Service Employee

o Complete the required training and assimilation in six months or less. o Demonstrate the behaviors, knowledge and skills provided through

training and assimilation. o Wear the supplied SSE identification at all times while on-site. o Work with assigned Buddy to improve knowledge and skills of the Site‘s

and their craft‘s safety rules and procedures. o Meet regularly with their Supervisor/Mentor to discuss progress and focus

areas.

3 PROCEDURE

Identification

Short service employees will be identified in the following manner:

o Yellow arm band to be worn over the outermost layer of clothing/PPE. o The identifier will remain on the employee until they graduate from the

SSE Program.

Assessment of SSE(s)


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o The SSE will meet with the Site or Safety Coordinator after a period of two weeks to determine the suitability of the SSE for continued work at the site.

o The Site or Safety Coordinator will document status using the SSE Tracking Log and provide feedback to the SSE on improvement opportunities and necessary focus areas.

o Safety Coordinator will complete a Safety Competency Assessment on the SSE. (Attachment A)

Time Required in SSE Program

The following time limits will apply to the employee before graduation from the SSE Program can occur:

o Minimum time in SSE program is 1 week. o Normal time in SSE program is not to exceed 6 months. o Exceptions to these time requirements may be considered based upon

demonstrated competency, such as: previous experience at the Site; experience at other petrochemical facilities which helped the SSE graduate more quickly at the company site; special or enhanced site introduction and training programs; or, if the individual has demonstrated knowledge, skills, safe behavior and performance, with input from the Supervisor or Mentor/Coach.

Ratios Becht Engineering defines the established expected ratios of SSEs to SSMPs in Attachment B (page 10). At a minimum, a single person crew cannot be an SSE and crew sizes of less than five shall have no more than one SSE. Ratios must be approved by the Buddy Manager or equivalent designated representative. Graduation

Upon meeting all of the requirements of the Short Service Employee Program and approval by Supervisor/Mentor/Coach, SSEs will formally graduate to Site Safety Mature Persons.

o Becht Engineering shall graduate SSEs during a Safety Luncheon which is held monthly or bi-monthly, depending upon the number of Advisors at the site.

o If a SSE leaves the site and returns after a period of 6 months or more , he/she will be required to complete the SSE process again.

Records Required for Audit


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Becht Engineering shall keep the following records available for audit by the Client:

o Copy of Becht Engineering‘s Short Service Employee Program. o SSE Tracking Log. o SSE Training Records. These records will consist of training logs, tests

and other records of instruction. o Exception Forms Approved for Time in SSE Program. o Becht Engineering Mitigation Plans. o Quarterly Stewardship Metrics reported to Client.

These records will be reviewed during the third-party PSM audit. SSE records shall be kept for three years. Quarterly Reports to Client

Becht Engineering will forward quarterly metric report to the Client Contact at quarterly stewardship meetings. The following metrics shall be included in the Quarterly Stewardship Report:

o Number of SSEs utilized in quarter. o Number of SSEs and number of SSMPs at quarter‘s end. o Number of SSEs graduated in quarter. o Number of SSEs (if any) removed from Site for failure to graduate

successfully. o Number of incidents/near-misses involving SSEs.

4 TRAINING

All employees, who are categorized as Short Service Employees, shall be provided instruction and guidance on the Short Service Employee Program. This training is provided:

o When the Short Service Employee Program is first established. o To all employees who qualify as SSEs. o Whenever employees return to the site who have been gone for six

months or longer. o To any employees who demonstrate lack of familiarity with the site or

who experience a change in work environment within the site.

Basic Training Requirements

o Becht Engineering Orientation and test completion.


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o Basic Plus Orientation. o Client Site Specific.

Pre-Access Training

The following training shall be delivered through PowerPoint Presentation, on and off site instruction by Safety Coordinator and Mentor/Coach/Supervisor and site held classes.

o Becht Engineering Safety Orientation o Site Safety Expectations and Responsibilities o Fall Protection/ Anchor Points o Emergency Response/Evacuation areas o Site Hazards o Primary and/or Secondary PPE. o Security Requirements o JSA/LMRA Training o Site tour reviewing site/work area hazards. o Work Place Injury/Illness notification process. o General knowledge of SSS/MWP/SPMs (including written test)

Graduation Requirements

The following training requirements must be completed prior to a SSE graduating to SSMP status. Becht Engineering will provide the training and verify satisfactory competency upon completion of each subject area.

o Assignment specific SSS/MWP/SPMs. o Assignment specific tools and procedures at job site. o Vehicle safety o Bicycle safety o Behavior consequence model o Injury and Near Miss reporting o General Work Permission

Mitigation Plans

Becht Engineering shall maintain an approved ratio of SSEs versus SSMPs. If the ratio will exceed this, a mitigation plan must be put into place. When Becht Engineering identifies a situation where the proper ratio cannot be maintained, the following must be completed prior to bringing additional SSEs on-site:

o Immediately notify the Site Contact and Buddy Manager (if applicable).


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o Develop a written plan for managing the additional SSEs, consulting with Client supervision as necessary.

o Received written approval on the plan for managing SSEs above the acceptable ratio from Client SLS and Buddy Manager (if applicable).

o Implement mitigation steps as described within the management plan. o Forward a copy of the approved plan to the Client Site Contact. o Keep original copy of plan on file for three years for audit purposes.

Mitigation Plans Requirements

Mitigation plans that are accepted and approved by the Client will be subject to the following requirements:

o Must include a description of the roles and responsibilities of Becht

Engineering and their employees in mitigating SSE ratios. o Are designated for a short time frame until an adequate amount of

SSMPs are available to serve as Mentors/Coaches. o Will not take the place of Becht Engineering‘s SSE program. o Will automatically expire after 90 days, at which time there should be a

sufficient number of SSMPs or a new plan will be developed. o For major Projects or Turnarounds, the plan shall also be agreed to by

the Client Turnaround or Project/Construction Managers.

5 REFERENCE

None

6 APPENDICES

Attachment A: Safety Competency Assessment Attachment B: Established Work Ratios and Additional Training Requirements

273 Mar./ 2010

Attachment: A

Safety Competency Assessment for application of Safe Working Practices (behavior/work habits) in the field

SAFETY

Exceeds Expectations Meets Expectations Inconsistent Performance Expectations Not Met

Initiate actions to help others to prevent exposure to potential hazards, reports hazards that need follow-up

Originates safety suggestions.

Actively encourages safe practices in others.

Improves safety in work area and/or other parts of the site.

Is always aware of potential hazards from the process, work area and task. Able to list hazards and tell how exposure will be prevented.

Consistently works safely by following rules and procedures.

Properly uses and maintains safety equipment.

Demonstrates concern for others.

Is sometimes not able to list hazards and demonstrate how exposure to potential hazards is being prevented.

Occasionally needs to be reminded to follow/use safety procedures/safety equipment.

Has received counseling for safety infractions.

Is often not able to list hazards and is often not able to explain/demonstrate how exposure to these potential hazards is being prevented.

Received written warning for safety infractions.

Must be frequently reminded to use safety equipment.

Needs to improve safety awareness.

CRAFT KNOWLEDGE & SKILLS


Demonstrates exceptional ability to apply skills and knowledge required for safe work execution.

Effectively communicates craft knowledge to others to improve their skill level.

Demonstrates the ability to utilize the skills and knowledge required to apply safe working practices.

Capable and willing to help others learn the skills required to work safely at their level.

Occasionally have problems in the ability to apply skills and knowledge required to safely execute work.

Consistently fails to demonstrate the ability to apply the skills and knowledge required to safely execute tasks.

COOPERATION AND TEAMWORK


Boosts group morale.

Consistently volunteers to help and encourage others.

Readily accepts and suggests new safe work processes.

Complies with directives.

Cooperates well with others.

Willing to support team effort.

Openly discusses problems.

Uses new/safer work processes.

Occasionally causes or encourages conflict among co-workers or supervisors.

Reluctant to follow directives.

Helps only when asked.

Shows limited ability to adapt.

Rarely helps others.

Causes conflicts and disrupts the work of crew members.

Refuses to use new work processes.


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ATTACHMENT B: BECHT ENGINEERING ESTABLISHED WORK RATIOS AND ADDITIONAL TRAINING REQUIREMENTS FOR SSES

Table: 1

Table: 2

Additional orientation provided by contractor after the completion of first shift (during first week on job)

Review FLRA

process

Review fall protection

requirements

Review work area hazards - live equipment (steam

tracing), odors, etc.

Review permitting process

Review emergency response and

incident reporting requirements

Experience Descriptions Ratio to experienced workers in the crew

3. Workers with 5+ years in industrial green field or live industrial sites.

1 to 2

2. Workers with 1 through 5 years of industrial experience.

2 to 5

1. Workers with: limited or no industrial experience, commercial experience, Apprentices, Permit holders.

1 to 3

275

BECHT ENGINEERING FIELD SAFETY POLICIES AND PROCEDURES

APPENDIX

A MAY/ 2010

The field safety manual is designed to provide safety policies and guidance which are generic to safe field operations for all Becht Divisions. Policies and procedures specific to a division‘s operations are outlined in the attached division standards tabs. Becht Engineering personnel may be called on to perform work in the field: in plants, vendor shops, construction sites, etc. In transferring from the office to the field, you may be exposed to many hazards such as toxic chemicals, high temperatures, and be in close proximity to operating and construction equipment. To work safely in such environments you must develop a strong sense of AWARENESS to spot such unsafe conditions. You must abide by all existing local safety rules, but, as a minimum, follow these safety procedures and policies. Normally, the host company has responsibility for site safety. While all employees are responsible for safety, always ensure you are aware of who is legally responsible for site safety and that you have completed any required safety orientation and training. Any conflicts in this respect should be referred to your supervisor immediately. Throughout this portion of the manual we will to stress two key words: AWARENESS and DIFFERENCES. Awareness because it is critical that employees be aware of the potential hazards around them and differences because safety hazards are just that, differences in standard procedures which may cause injuries.

1 PRIOR TO DEPARTURE FOR A FIELD ASSIGNMENT

Review all site safety requirements with your supervisor including

site safety policies and procedures of the host company. Assemble appropriate personnel protective equipment as required

including:

Hard hat

Ear protection

Hand and foot protection equipment

Safety goggles

Nomex Overalls

Check local weather conditions to ensure you have the proper clothing for the forecasted conditions

276


APPENDIX

A MAY/ 2010

If the job site is in outside the United States ensure you have the following items:

Passport or Visa

List of contact personnel in the host country and at Becht Engineering

Received the proper inoculations and your shots are up to date

Reviewed any government warnings and literature on safety in the host country

Take time to ensure your personal documents are in order including your will and power of attorney as appropriate

If you will be required to drive, ensure you have all the necessary paperwork and safe driving rules for the host country

2 UPON ARRIVAL AT SITE

Check to ensure you have received any required safety orientation

or training Ensure you are aware of the job site requirements for reporting

safety hazards, accident reporting procedures and emergency evacuation procedures

Know where the nearest medical station is located

3 DURING THE JOB

Constantly look and be alert for safety hazards Report any safety hazard immediately Ensure you are properly trained on any equipment you are asked to

operate. Ensure you are aware of any safety restrictions while working near

any equipment. Regardless of the facility you are visiting, the following rules apply:

You should not supervise, direct, or control any operation or facility visited. Responsibility for the safety and operation of the equipment remains with the owner at all times.

Insist on minimum standards concerning your safety even if unsafe practices are followed at the location being visited.

277


APPENDIX

A MAY/ 2010

You should not undertake any activity during your assignment that you believe may involve possible personal danger or potential injury. If an unsafe condition prevents you from doing your job during your assignment, notify our on-site supervisor of your concern. While on assignment by yourself, notify the appropriate plant or vendor personnel of the unsafe condition and your concern to your management at the home office for resolution before proceeding with your assignment.

You must comply with the local safety rules in force at the facility visited. If any of theses rules are less stringent that the Becht Engineering safety requirements, then the latter shall govern.

The Employee should know and use the following safety tools as

they will help to handle most safety situations when visiting sites:

Appraisal Technique: This is a visual evaluation of the job area to discern unsafe conditions or unsafe acts that may affect the risk associated with safely performing the work. Many common actions from driving a car to going down stairs have a risk. By the appraisal techniques it should be possible to put the risks involved in proper perspective. Having done this, suitable safeguards can be taken.

Protective Clothing and Equipment: A wide variety of protective devices are available, and the Employee is expected to use judgment in determining what is required. Basically, an employee must follow the rules and practices of the host company, and, as a minimum the requirements described herein.

Know Your Limitation: The Employee should use his experience, judgment, common sense, and the applicable tools available to him to assure his safe conduct of his work. Nonetheless, there are times when the situation presented has the potential unusual or unknown consequences to the employee‘s safety. He should ask questions and get satisfactory answers before proceeding with unusual exposures. If special guidance is needed,

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the matter might be referred to the home office supervisor.

The Employee should feel relatively comfortable with his assessment of the conditions. He should feel SAFE, but not necessarily SECURE. (To feel secure implies freedom from anxiety or apprehension of DANGER or RISK.)

Awareness: Awareness implies vigilance in observing or alertness in drawing inferences from what one sees and hears or learns. Therefore, awareness works hand-in-glove with the appraisal technique. Experience and a desire to practice safety are proper steps to awareness. Often awareness and appraisal require no more than a pause to reflect on what has to be done, how it will be done, and whether or not it will be done in the safest manner. It is this pause to reflect on what has to be done, how it will be done, and whether or not it will be done in the safest manner. It is this pause that helps in practicing safety.

Exposure Control: Once the potential dangers have been noted, the Employee should limit his exposure to them. Especially when a work area is bustling with activity, the potential for an unsafe condition to develop unexpectedly is very real. Therefore, the Employee should plan his work to move in, do the job and move back; that is, stay in the safest area until needed for an inspection, to read gages, or witness a test. In test work, use could be made of remote-reading gages permitting only occasional verification at the source. Use of these remote gages might require a special effort by the vendor, but exposure control may make it desirable to do this.

4 TRAVEL CONSIDERATIONS

Air Travel to New Locations

Frequently you will be required to travel to your assignment by air. Today, traveling by commercial

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airlines is one of the safest means of transportation based on accident statistics. However, you should recognize that changes, both external and internal, have occurred to you rapidly as a result of air travel which affects your AWARENESS to potential safety hazards.

Jet lag, fatigue, time change, and dietary changes are some of the biological DIFFERENCES you may experience as a result of traveling by air.

Language, customs, and local regulations are some of area DIFFERENCES you may encounter at a new location.

Avoid injury by giving yourself time to adjust to the new environment air travel has quickly exposed you to.

Driving Safety

Consider not hiring a rental car after traveling overnight through several time zones. Be extra careful when crossing streets in countries

where driving on the left side of the road is practiced (St. Croix, Japan, Far East, etc.). It is best to get in the habit of always looking BOTH ways before crossing any street.

Consider not eating at that local native restaurant as soon as you arrive until your body is prepared for the change in diet.

Consider effects of alcoholic beverage consumption on fatigue and stress while traveling.

A safe highway driver must remain alert and must continuously adapt to changing road conditions. Driving in a refinery or chemical plant is no different. However, in addition to the good driving practices mentioned earlier there are rules and regulations that must be followed to maintain safety when driving in a plant. The potential for catastrophic results occurring from an automobile accident in a processing plant is great.

Driving accidents in a plant can be minimized if the driver uses good general driving practices, follows the local driving regulations, and is aware of the possible tremendous consequences of poor driving techniques.

When starting an assignment at any refinery/chemical plant/laboratory/office you must determine all the safety

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rules that apply to those particular locations-including safe driving practices. The general driving rules are minimums standards. At other plants the local practices might be more restrictive or less restrictive than these; when in doubt follow these guidelines as a minimum.

All vehicles entering a plant must be in safe operating condition. As a minimum, equipment such as brakes, lights, horn, muffler, windows, wipers, and mirrors must be checked for proper operation and good physical condition.

Seat belts must be worn by the driver and all passengers when driving.

Maximum permissible speed in a processing plant is 30 mph. Posted speed limits in the unit operating areas or congested locations may be much lower. The driver must at all times obey the posted speed limit signs. Extra caution must be used during shift change periods when traffic flow in the plant will be the greatest.

Vehicles must not be driven onto operating unit areas without clearance from authorized unit personnel.

Vehicles shall be on the proper side of the road.

Parking shall be on the proper side of the road, except when parking in designated parking areas, or when directed otherwise by traffic signs or during emergencies.

Vehicles shall not be parked on streets or roadways in such a manner to slow down, hinder or interfere with the use of fire hydrants or fire equipment. Most refineries are equipped with excellent fire fighting equipment which can be rendered useless when fire hydrants are blocked by a careless driver.

Check and follow plant policy regarding leaving the ignition key in the vehicle to permit moving of the vehicle by others should this be required.

All motor vehicles shall give right-of-way to pedestrians, bicycles, ambulances, fire-fighting equipment and firemen.

Vehicle shall be pulled to one side and shall be brought to a complete stop when approached from either direction by emergency vehicles responding to a call.

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Ordinary driving courtesy shall be practiced by all drivers of motor vehicles.

All traffic signs and signals, whether fixed or portable, shall be obeyed.

Drivers must obey security officers and others appointed to direct traffic.

Special caution must be exercised when approaching railroad crossing. Vehicles should come to a complete stop before attempting to cross the tracks.

Areas blocked by traffic barriers or a road closed signs are closed to all traffic.

The number of passengers permitted in a vehicle shall not exceed the maximum number recommended by the manufacturer.

Drivers of motor vehicles shall not permit passengers to ride on fenders, running boards, tops, or bumpers of motor vehicles.

Passengers shall keep all parts of their bodies inside the cab or body of vehicle and shall be seated while vehicle is in motion. Passengers shall not get on or off a vehicle while it is in motion.

An auto accident involving Company-Owned or leased vehicles shall be reported by the person involved to his supervisor giving all the necessary details. Where an auto accident involves an employee-owned or rented vehicle on Company business, the employee shall report the facts immediately to his personal insurance carrier or the rental agency, as appropriate.

Rental Car Safety. Company business sometimes requires that you drive rented cars. Below is a safety Check List that should be followed before any newly rented car is driven:

o Thoroughly familiarize yourself with the vehicle before driving.

o Locate control and check operation of headlights (including high beams), directional lights, windshield, defroster and horn.

o Check tire inflation and insure that a good spare tire has been included (with Jack).

o Check car ashtrays prior to use to be sure they are free of flammable debris.

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o Before leaving the parking lot check steering control and brake operation.

o Adjust side view and rear view mirrors.

5 DRIVING IN FOREIGN COUNTRIES

Driving in a foreign country is a challenge which requires

adjustment to different driving customs and norms. The speed and accuracy of this adjustment are extremely important as the cost of failure could be life itself.

Foreign driving involves the same basic skills that are required for domestic driving and, all of the information in the General Safe Driving Section of this write-up also applies to foreign driving. In addition, there are some special considerations.

There are three components involved in automobile safety: The driver; the vehicle; and the environment. The weakest link in this chain is by far the driver. It is vital and basic that the vehicle is in good mechanical condition; nevertheless, statistics show that driver error accounts for most accidents-with the chances for error increasing on foreign assignments.

The Driver

o Assignments away from the home office cause a number of changes to take place in the employee‘s life. He must adjust to a new level of mental, emotional and physical stress. These changes all have an effect on how he will react in a given traffic situation.

o Psychological factors are more important than physical factors in measuring the ability of a driver to proceed safely in traffic. Most people think a person unfit to drive is someone who is impaired or physically unfit. But, each of us at some time or other is unfit to drive in a particular driving situation. The driver‘s mental and emotional state has something to do with almost all accidents. If nothing else is at fault, it is boredom. Inattention is related not only to

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boredom but also to anger, hostility, ambition, anxiety, and a lot of other things.

o Many become preoccupied with work problems while driving when they should be paying more attention to the road ahead. Foreign assignments often carry longer hours, higher stress levels, and more fatigue than domestic assignments. Although in many instances it is not possible to eliminate fatigue and other causes of inattentiveness, it certainly is possible to take them into account and consciously make the necessary adjustment.

The Vehicle

o Normally, you will be using a rented car rather than your own. This in itself requires driver adjustment. A moving automobile is a man-machine system. The machine will perform as it is instructed to perform. However, when the operator does not yet have complete knowledge of the car and has not developed the proper automatic responses using the new control system, he must compensate by adjusting his driving style.

o Thoroughly familiarize yourself with the operating systems of the car before you drive it. It will lessen any reaction time should you need it.

The Environment

o Always pay attention to where you are. When traveling, major roads can quickly change to secondary roads. Transitions from rural, in restricted travel to congested town traffic can occur quickly. If you are driving any distance at all, you will probably be required to make many of these transitions. Be alert and aware of your changing environment.

o An excellent system of roads exists in the United States. This road system generally offers few surprises to highway drivers. As a result, drivers accustomed to this system tend to relax behind the wheel when driving on the major roadways. This practice is dangerous.

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o Many foreign countries have good highway systems. However it is not uncommon in some countries to encounter large potholes, animals, bricks, disabled vehicles, etc., in the right-of-way of an otherwise perfect major highway. Some foreign highway designs may not meet our safety standards. Curves may not be banked and highway shoulders may be nonexistent.

o Driving customs can vary from country to country. Following are a few examples which illustrate this point:

o In the United States, Canada, Mexico, and all Latin American countries driving is to the right. The same is true for most European countries with the exception of Great Britain and Ireland where driving is to the left. Australia, New Zealand, Japan, and St. Croix are additional locations where driving to the left is practiced.

o It is a driving regulation in the Netherlands and France to yield to the right. Thus, a vehicle entering a roadway from the right side has the right-of-way. Because of this regulation, the drivers in those countries don‘t look to the left as much as they should. You, as the defensive driver, have to be alert regarding this practice.

o In some countries, you may have to spend a short period in jail if you are the driver of a car involved in an accident, even a minor one. This harsh technique adds another incentive to avoid accidents.

o Do not assume roadway conditions and driving customs in foreign countries are similar to those at home. Be informed and adjust your driving accordingly.

6 FIELD CONDITIONS AND CONSIDERATIONS

Many of the recommendations made in this section may seem like

common sense. They are. However, frequently the reason for the recommendation is not apparent. For example, hard hats are not

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so much for protection from objects falling from the sky as they are for protection from walking into an obstruction.

Another problem is that the most dangerous hazards are those which seem harmless. Nitrogen is an example of this. Nitrogen is often used for purging vessels and is considered by many to be a safe gas. Unfortunately, workers occasionally enter purged vessels before testing for oxygen sufficiency. And each year a number of workers die from simple asphyxiation from entering vessels purged with nitrogen.

As previously mentioned, many conditions beyond your control such as language problems, jet lag, and being away from home office will affect your safety awareness. Don‘t let these compromise your safety

7 COMMON DO‘S AND DON‘TS

The following is a list of common Do‘s and Don‘ts that you will find applicable to most types of assignments away from the home office.

Do These:

Be extra cautious in foreign locations since safety instructions and signs may be in foreign language.

Review any safety feedback from previous visits to the location

Wear clean fire-retardant clothing when working near any potential fire hazards. Wear long-sleeve shirts in all refineries and chemical plants. NOMEX clothing will be purchased by the company for such assignments where the clothing is needed and is not available at the visiting plant. Procurement may be arranged through your supervisor.

When on a field visit have adequate pocket space for pencils, notebooks, tape measures and other necessary items so that both hands are free. Ensure that all items are secure. Loose objects may fall and injure a fellow worker working below.

When your work involves a processing unit, always report to the operator in charge or the unit supervisor before entering the operating area. In addition, you should always check with him on leaving the area.

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When visiting a facility for the first time, appraise the overall safety appearance before entering the work areas e.g., housekeeping, use of safety equipment, condition of equipment, any work in progress, etc.

On the initial site visit, you should be accompanied by a plant representative who is familiar with the operations and any safety hazards associated with the equipment.

Before conducting process or equipment tests, review written procedures with a unit supervisor and startup leader if applicable, with regard to safety personnel and equipment.

Keep alert for moving equipment, loads being lifted, tripping hazards, overhead hazards, missing grating, workmen overhead, welding spatter and arc strikes, and exposed electrical lines.

Be familiar with any toxic materials handled at the location you are visiting.

Wash chemicals (acid, caustic, and phenol particularly) splashed from skin immediately. Know the location of the emergency showers. If chemicals are spilled on clothing, clean them off as soon as possible or discard them if necessary.

Become familiar with the location and normal readings of gauges and instruments related to the unit you are working on.

Be aware of any hot bare metal surfaces in your work area.

Stay clear of any radiographic examination work in progress.

Use ear protection equipment when participating in noisy operations.

Use only a light source that has been approved for the use in the intended location.

Learn the numbers to call in case of an emergency.

If you should use a fire extinguisher, inform the unit supervisor.

At all times inside a vessel, be aware of route to nearest access opening in case of an emergency. Use life belts and lines should there be any danger of falling inside a vessel.

Do Not Do These:

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Do not smoke except in approved areas.

Do not wear short sleeve shirts or the common synthetic fabrics in operating plants.

Do not walk through operating areas where you are not required and never take shortcuts that are not walkways.

Do not enter any enclosed area, such as vessels, tanks, furnaces, etc., unless the operator has certified that the equipment is safe to enter (gas free, sufficient oxygen present, and all process and utility piping connections are blinded)

All local confined space entry procedures are followed.

Do not climb scaffolds or structures if you do not feel comfortable either because of height or sturdiness. (Don‘t be afraid to ask for a safety harness).

Do not walk through any vapor clouds.

Do not wear loose clothing, ties, gloves, sweaters or long hair in rotating equipment areas.

Oil impregnated clothing should not be worn or stored in an area where it might be a fire hazard (such as a locker).

Do not use hydrocarbons for washing hands or cleaning clothing.

Do not walk in the space of areas, vessels, or furnaces where work is taking place overhead. (Walking around is preferred).

Walk around puddles, do not step over them or walk through them.

Do not ride on crane hooks or blocks.

Pipe racks should not be used for walkways.

Do not wear contact lenses when wearing a full face respirator or breathing apparatus, while working near electrical, electronic or arc welding activities.

Do not look directly at a welding arc. Use dark glasses of proper density to assure protection (not sunglasses).

If unexpected flammable vapors or solid dust clouds are encountered, under no circumstances should you activate any electrical devices in the area. This includes radios, pocket calculators, tape recorders, etc. In-plant phones and walkie-talkies are generally approved for hazardous areas.

Do not assume equipment lockout procedure has been followed - always check.

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Do not enter or inspect any equipment alone or after normal working hours.

Do not walk on roller conveyors.

Do not be a spectator at a fire.

Do not use compressed air, oxygen or light distillates to clean clothes.

Do not use plant compressed air for breathing purposes unless specifically approved for this use.

Do not take chances with electrical equipment or wiring. Exposed ungrounded conductors could be energized with lethal test voltages. Do not touch electrical equipment or conductors unless you have a need to.

If you must work in the vicinity of exposed electrical conductors, do not touch them unless they are visibly grounded, they are tested for no voltage by authorized personnel and then grounded.

Do not operate or manipulate any valves or instruments

8 FIRES AND OTHER EMERGENCIES

As a general rule, Becht Engineering personnel, as technical

advisors, are not expected to participate in fire fighting or other emergency control activities at a field location where trained local staff are available.

In the event of a fire, Becht Engineering personnel should:

Move to a safe location, moving upwind of the fire.

Immediately notify the responsible personnel using established procedures for the specific location. Never assume that reporting has already been done unless you are positive that it has.

Report to a predetermined marshaling point if local procedures or regulations require it. Otherwise, report to the unit control center or other location where they can be accounted for.

While staying out of the way, offer to help in ways that they are qualified to. For example, they might be of assistance in giving technical advice on how to quickly and safely shut down a process unit or piece of equipment, or in planning the next steps to be taken.

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NEVER attempt to fight a refinery or chemical plant fire by yourself. The exception to this rule is if someone‘s life is at stake and other trained, local staff are not available, in which case, appropriate action may be taken provided this can be done without jeopardizing ones own safety.

NEVER be spectators at a fire or other emergency.

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ACCESS TO MEDICAL & EXPOSURE RECORDS PROGRAM

1 PURPOSE AND SCOPE

Purpose This procedure provides the guidelines for the control, storage, and availability of employee health exposure and medical records involving employees exposed to known toxic substances or harmful physical agents.

Scope This procedure applies to all Becht personnel and subcontractors working on projects where requirements for medical records are applicable.

2 GENERAL

Current regulations require the release of occupational exposure and medical data to employees, their designated representatives, health professionals, and OSHA upon request. The access rule itself does not require employers to create medical records or conduct toxic substance exposure monitoring. It does mandate retention of exposure monitoring records for 30 years and personal medical records for employment plus 30 years.

Definitions

Toxic Substance: A substance that demonstrates the potential to induce cancer, to produce short- and long-term disease or bodily injury, to affect health adversely, to produce acute discomfort, or to endanger life of man or animal resulting from exposure via the respiratory tract, skin, eye, mouth, or other routes in quantities which are reasonable for experimental animals or which have been reported to have produced toxic effects in man.

Chemical Substance:

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The organic or inorganic substances of a particular molecular identity listed in 29CFR1910, Subpart Z, by OSHA and the latest printed edition of the NIOSH Registry of Toxic Effects of Chemical Substances (RTECS). Medical Records: The documents associated with personal physical and mental conditions resulting from exposure to toxic substances.

Health Exposure Records: The documents which log the sampling levels and monitoring levels of possible health hazards.

Responsibilities

The Division Safety Officer: Is responsible for monitoring compliance, implementing and enforcing this procedure. The Company Safety Manager: Is responsible for maintaining and securing the final storage of medical and health exposure records. These records shall be kept for 30 years and personal medical records for employment plus 30 years.

3 PROCEDURE

Medical records include the documents that are relative to employee medical examinations, health hazard exposures involving toxic substances and harmful physical agents, and the protective measures instituted. Medical and health exposure records generated on the jobsite shall be available to employees, designated representatives, health personnel, and OSHA.

Becht medical and health exposure records shall be maintained in the

Becht medical files in the custody of the Company Safety Manager. Employees shall be informed where their records are kept. This shall be

accomplished at the New Employee Safety Training.

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Employee record requests shall be in writing (see sample request in Appendix 1), except in an emergency. Designated representatives and health professionals shall need specific written consent to gain access to employees' personal medical records, but may examine exposure records without consent. However, they must state the specific record needed and the occupational health need for requesting the information. Health professionals include physicians, occupational health nurses, industrial hygienists, toxicologists, and epidemiologists who provide medical or other occupational health services to exposed employees. OSHA may obtain personal medical records promptly without the written consent of the subject employees, but will adhere to strict data controls to protect confidentiality.

One copy of an employee's medical and health exposure record shall be

made available to the employee with the Company Safety Manager‘s approval within 15 days of the request and with the written concurrence of the Division Safety Manager.

When an employee is granted a copy of the medical record, a Becht

representative shall make a copy for the employee and return the original to the file.

Persons requesting records not within the scope of this procedure shall be

refused such records and may be referred to the Company Safety Manager.

Personal medical records for short-term employees (less than 1 year) shall not be retained if they are provided to the employee upon termination.

First aid records and experimental toxicological research records are excluded from the 30- year retention requirements.

4 REFERENCES

National Institute for Occupational Safety and Health (NIOSH), Registry of Toxic Effects of Chemical Substances (RTECS).

Title 29, Code of Federal Regulations, Parts 1910 and 1926, Occupational

Safety and Health Administration (OSHA), U.S. Department of Labor.

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Appendix 1, Sample Letter: I, , (full name of worker/patient) hereby authorize (individual or organization holding the medical records) to release to (individual or organization authorized to receive the medical information), the following medical information from my personal medical records: ________________________________________________________________ ________________________________________________________________ (Describe generally the information desired to be released). I give my permission for this medical information to be used for the following purpose: ________________________________________________________________ ________________________________________________________________ But I do not give permission for any other use or re-disclosure of this information. ____________________________________________________________ __ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________________________________________________________________________ Full name of Employee or Legal Representative ________________________________________________________________ Signature of Employee or Legal Representative ________________________________________________________________ Date of Signature

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ASBESTOS AWARENESS PROGRAM

***NOTE*** No employee is authorized to work on any equipment which may contain Asbestos. All work involving Asbestos will be abated by the facility prior to our work beginning. This program is provided simply as general awareness program.

1 WHAT IS ASBESTOS?

Asbestos is the name applied to various naturally occurring silicate minerals. The types successfully mined and marketed include: amosite (brown); chrysotile (white); tremolite; actinolite; anthophyllite; and crocidolite (blue). Asbestos is probably the best insulator known to man. Asbestos fibers are resistant to chemicals and heat, do not evaporate into air or dissolve in water, are very stable in the environment, and are also virtually indestructible. Because asbestos has so many useful properties, it has been used in over 3,000 different products. Usually asbestos is mixed with other materials to actually form the products. Floor tiles, for example, may contain only a small percentage of asbestos. OSHA mandates that any product/material containing one percent or more of asbestos be identified as an "asbestos-containing material" (ACM).

2 WHERE IS ASBESTOS-CONTAINING MATERIAL (ACM) FOUND?

ACM is located in nearly all buildings and workplaces. Examples of ACM products may include but are not limited to:

Wall, ceiling, pipe insulation, boiler, fire proofing, and other sprayed-on insulation in buildings

Putties, caulks, cements, wall and ceiling textures, mastic, glues and joint compounds;

Ceiling and floor tiles; Roofing shingles and siding shingles; Acoustical plasters and transite (used on many cooling water towers)

materials; Mudded fittings and joints; Fire doors and electrical wire insulation; Gaskets; Brake linings and clutch

pads; These and many other building materials used in construction prior to

1981.

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3 WHEN IS ASBESTOS POTENTIALLY HAZARDOUS/DANGEROUS?

Asbestos or ACM is most hazardous when it is "friable". The term "friable" means that the ACM is easily crumbled by hand, releasing fibers into the air. For example, sprayed-on or pipe asbestos insulation may be highly friable. However, asbestos-containing ceiling tiles, floor tiles, laboratory cabinet tops, shingles, fire doors, siding shingles, etc., will not release asbestos fibers unless they are disturbed or damaged in some way. If an asbestos containing material is drilled, broken, ground, buffed, cut, sawed, struck or otherwise damaged, it may release fibers into the air. If it is left alone and not disturbed, it will not.

4 WHAT ARE THE POTENTIAL ADVERSE HEALTH EFFECTS OF OVER-EXPOSURE?

ACM materials are generally not considered to be harmful unless it is being damaged to the extent that very small fibers are being released into the atmosphere. Upon continual vibration and physical impact such as drilling or grinding, all types of asbestos tend to break into very tiny fibers, so small that many must be identified using a microscope. In fact, some fibers may be up to 700 times smaller than a human hair and once released into the air, they may stay suspended there for hours for even days. Asbestos is generally considered to be potentially harmful when very small fibers are inhaled deep into the lungs. The very smallest fibers cannot be removed by the lung's natural defense systems and may become lodged in the alveolar lung tissue. They remain in the lung where these fibers may cause disease. OSHA believes that the most common adverse health effect is 'asbestosis", which is scarring of the lungs. Mesothelioma is a rare form of cancer of the membrane lining the chest and abdomen (about 200 cases each year in the U.S.A.). Lung cancer is believed to be more common among persons who were cigarette smokers and were exposed to significant amounts of asbestos fibers in various workplaces (mines, mills, factories, and shipyards). Two determining factors seem to be related to the probability of developing these diseases:

The amount and duration of exposure - persons exposed frequently over a long period of time are more at risk, making it important to minimize exposures.

Whether or not one smokes cigarettes - the first thing a smoker should do to reduce their risk of developing lung cancer is to stop smoking.

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5 HOW DOES ONE AVOID UNNECESSARY ASBESTOS EXPOSURE?

Asbestos is a naturally occurring mineral and is ubiquitous in our natural environment, including the soil, water and air. As such, it is impossible to achieve zero exposure, but it is possible to minimize unnecessary exposure. Because one cannot tell if products contain asbestos just by looking at them:

Be aware of the owners Asbestos Exposure procedures if there is any potential for exposure

Assume that it does and do not damage it. Never break, saw, cut, hammer, drill, damage, disturb or move any ACM or suspect materials.

If you discover some ACM has been knocked off insulation, this would be considered a "spill". "Spills" of fiber to work areas when the insulation is not labeled as non-asbestos are to be treated as Asbestos pending receipt sample/testing results.

Personnel are to be removed from the effected site and the area is to be barricaded with RED tape. Then notify your supervisor.

The Supervisor must immediately notify the Owners of the incident.

If insulation is found on workers in the immediate area, their clothing is to be covered with disposable coveralls, hands/face washed and then they must be transported to the Asbestos Decon Unit of the local facility.

A qualified lab will test the insulation as soon as possible. If the insulation contains Asbestos, only the qualified Abatement Contractor's personnel are allowed into the area to clean.

If the insulation sample(s) contain asbestos, personal clothing must be disposed of as contaminated waste.

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ASSURED GROUNDING

1 ASSURED EQUIPMENT GROUNDING

Whether one is involved in designing, installing, or maintaining an electrical system, protection must be of primary concern. This includes not only safeguarding equipment and facilities from damage or improper operation, but it also includes the safety of personnel who may be exposed to the hazards inherent with any electrical installation.

Relative to safety of personnel, consideration for some form of ground-fault protection must be made to prevent current flow through the body due to line-to-ground faults. This is not to be confused with ground-fault protection for equipment, which has a totally different level of protection and a totally different intent. Because of the effects of current flow through the human body, ground-fault protection for personnel typically addresses current in the 4 to 6 milliampere range. Ground-fault protection for equipment addresses electrical apparatus damage due to line-to-ground faults and looks at current several orders of magnitude higher.

Assured equipment grounding conductor program (AEGCP) is a method of protection for personnel against ground-fault current flow through the body. The basic concept of the AEGCP is that conductive surfaces which may become energized due to line-to-ground faults and with which personnel may come in contact be properly grounded. Thus if properly grounded and a line-to-ground fault occurs, the low impedance path would allow resulting current flow to be large enough to be detected and removed by the circuit protective device. This would then de-energize the conductive surface subject to contact by personnel, removing the shock hazard.

Ground-Fault Protection for Personnel:

Ground-fault protection for personnel for all temporary wiring installations shall be provided to comply with (a) and (b). This section shall apply only to temporary wiring installations used to supply temporary power to equipment used by personnel during construction, remodeling, maintenance, repair, or demolition of buildings, structures, equipment, or similar activities.

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(a) Receptacle Outlets. All 125-volt, single-phase, 15, 20, and 30 ampere receptacle outlets that are not part of the permanent wiring of the building or structure and that are in use by personnel shall have ground-fault circuit interrupter protection for personnel. If a receptacle(s) is installed or exists as part of the permanent wiring of the building or structure and is used for temporary electric power, ground-fault circuit-interrupter protection for personnel shall be provided. For the purposes of this section, cord sets or devices incorporating listed ground-fault circuit interrupter protection for personnel identified for portable use shall be permitted.

Exception No. 1: Receptacles on a 2-wire, single-phase portable or vehicle-mounted generator rated not more than 5 kW, where the circuit conductors of the generator are insulated from the generator frame and all other grounded surfaces, shall be permitted without ground-fault protection for personnel.

Exception No. 2: In industrial establishments only, where conditions of maintenance and supervision ensure that only qualified personnel are involved, an assured equipment grounding conductor program as specified in Section 305-6(b)(2) shall be permitted to be utilized for all receptacle outlets.

(b) Use of Other Outlets. Receptacles other than 125-volt, single-phase, 15-, 20-, and 30-ampere receptacles shall have protection in accordance with (1) or, the assured equipment grounding conductor program in accordance with (2).

(1) Ground-fault circuit interrupter protection for personnel.

(2) A written assured equipment grounding conductor program continuously enforced at the site by one or more designated persons to ensure that equipment grounding conductors for all cord sets, receptacles that are not a part of the permanent wiring of the building or structure, and equipment connected by cord and plug are installed and maintained in accordance with the applicable requirements of Sections 210-7(c), 250-114, 250-138, and 305-4(d).

(a) The following tests shall be performed on all cord sets, receptacles that are not part of the permanent wiring of the building or structure, and cord- and plug-connected equipment required to be grounded.

(1) All equipment grounding conductors shall be tested for continuity and shall be electrically continuous.

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(2) Each receptacle and attachment plug shall be tested for correct attachment of the equipment grounding conductor. The equipment grounding conductor shall be connected to its proper terminal.

(3) All required tests shall be performed

(a) Before each use on site,

(b) When there is evidence of damage,

(c) Before equipment is returned to service following any repairs,

(d) At intervals not exceeding 3 months.

(b) The tests required in (2)(a) shall be recorded and made available to the authority having jurisdiction. Very similar wording on this issue can be found in Subpart K of the OSHA Construction Standard, specifically

(a) The following tests shall be performed on all cord sets, receptacles that are not

(b)(1) Ground-fault protection –

(b)(1)(i) General. The employer shall use either ground-fault circuit interrupters as specified in paragraph. (b)(1)(ii) Of this section or an assured equipment grounding conductor program as specified in paragraph. (b)(1)(iii) Of this section to protect employees on construction sites. These requirements are in addition to any other requirements for equipment grounding conductors.

(b)(1)(ii) Ground-fault circuit interrupters. All 120-volt, single-phase 15- and 20-ampere receptacle outlets on construction sites, which are not a part of the permanent wiring of the building or structure and which are in use by employees, shall have approved ground-fault circuit interrupters for personnel protection. Receptacles on a two-wire, single-phase portable or vehicle-mounted generator rated not more than 5kW, where the circuit conductors of the generator are insulated

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from the generator frame and all other grounded surfaces, need not be protected with ground-fault circuit interrupters.

(b)(1)(iii) Assured equipment grounding conductor program. The employer shall establish and implement an assured equipment grounding conductor program on construction sites covering all cord sets, receptacles which are not a part of the building or structure, and equipment connected by cord and plug which are available for use or used by employees. This program shall comply with the following minimum requirements:

(b)(1)(iii)(A) A written description of the program, including the specific procedures adopted by the employer, shall be available at the jobsite for inspection and copying by the retary and any affected employee.

(b)(1)(iii)(B) The employer shall designate one or more competent persons (as defined in 1926.32(f)) to implement the program.

(b)(1)(iii)(C) Each cord set, attachment cap, plug and receptacle of cord sets, and any equipment connected by cord and plug, except cord sets and receptacles which are fixed and not exposed to damage, shall be visually inspected before each day‘s use for external defects, such as deformed or missing pins or insulation damage, and for indications of possible internal damage. Equipment found damaged or defective shall not be used until repaired.

(b)(1)(iii)(D) The following tests shall be performed on all cord sets, receptacles which are not a part of the permanent wiring of the building or structure, and cord and plug-connected equipment required to be grounded:

(b)(1)(iii)(D)(1) All equipment grounding conductors shall be tested for continuity and shall be electrically continuous.

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(b)(1)(iii)(D)(2) Each receptacle and attachment cap or plug shall be tested for correct attachment of the equipment grounding conductor. The equipment grounding conductor shall be connected to its proper terminal.

(b)(1)(iii)(E) All required tests shall be performed:

(b)(1)(iii)(E)(1) Before first use;

(b)(1)(iii)(E)(2) Before equipment is returned to service following any repairs;

(b)(1)(iii)(E)(3) Before equipment is used after any incident which can be reasonably suspected to have caused damage (for example, when a cord set is run over); and

(b)(1)(iii)(E)(4) At intervals not to exceed 3 months, except that cord sets and receptacles which are fixed and not exposed to damage shall be tested at intervals not exceeding 6 months.

(b)(1)(iii)(F) The employer shall not make available or permit the use by employees of any equipment which has not met the requirements of this paragraph (b)(1)(iii) of this section.

(b)(1)(iii)(G) Tests performed as required in this paragraph shall be recorded. This test record shall identify each receptacle, cord set, and cord- and plug-connected equipment that passed the test and shall indicate the last date it was tested or the interval for which it was tested. This record shall be kept by means of logs, color coding, or other effective means and shall be maintained until replaced by a more current record. The record shall be made available on the jobsite for inspection by the Assistant Secretary and any affected employee.

While the AEGCP is permitted, it is only valid if all requirements are continuously met which requires correct administration and strict enforcement. Because of

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concerns largely with the lack of enforcement, an effort to remove the AEGCP was made during the revision cycle for the 1999 Code. This effort was based on experiences that indicated personnel were not properly protected because of improper enforcement, primarily on construction sites. During those discussions, arguments were made that lack of enforcement was not the correct reason to remove this option and that other means of protection would also be ineffective if not properly enforced. The result was that Section 305-6 was modified but the AEGCP remained as an option.

During the current revision cycle for the 2002 NEC the effort to remove the language permitting the AEGCP is again being made. Proposal 3-138a, referencing Section 305-6(a), Exception No. 2, was submitted by the panel, CMP-3, to delete Exception No. 2 in its entirety. Substantiation for the proposal was that "The sufficient availability of GFCI (Ground-Fault Circuit Interrupter) protection and proven safety record eliminates the need for this exception." Arguments are again being made to allow AEGCP to remain in the language for those who want to use it, and who will enforce and administer its requirements correctly. The outcome for the 2002 NEC will be determined by the action of the panel during this code cycle.

Finally, it is very important to point out that a false sense of security can be created through the use of ground-fault protection for personnel, regardless of the method used. A clear understanding of the method used and the protection it affords personnel must exist. Simply because the AEGCP is used, or a device is connected to a GFCI device does not mean personnel are protected from all possible shock situations. Since the AEGCP relies on current flow high enough to be detected and removed by the circuit protective device, it does not contribute to safety of personnel in a series contact situation. Its effectiveness is also reduced in high impedance or partial ground fault situations. Further, neither the AEGCP nor the GFCI devices provide safety to personnel in line-to-line or line-to-neutral contact situations. As with other protective methods and equipment in the electrical discipline, there are specific designs for specific hazards. These must be clearly understood and the correct protection employed for the hazards present.

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1 GENERAL

The standard for confined space entry is OSHA Permit-Required Confined Space Standard (CFR 1910.146). For the purposes of this tab the following definitions will apply:

Confined Space - A confined space has limited or restricted means of entry or exit, is large enough for an employee to enter and perform assigned work, and is not designed for continuous occupancy by the employee. These spaces may include, but are not limited to, underground vaults, manholes, tanks, storage bins, pits and diked areas, vessels, and silos.

Permit-Required Confined Space - A "permit-required confined space" is one that meets the definition of a confined space and has one or more of these characteristics:

contains or has the potential to contain a hazardous atmosphere,

contains a material that has the potential for engulfing an entrant,

has an internal configuration that might cause an entrant to be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross section, and/or contains any other recognized serious safety or health hazards.

Entry into Permit-Required Confined Spaces

Prior to entry into any permit-required confined space, the supervisor will issue a permit that specifies the location, type, and duration of the work to be done, and the date. The permit will certify that all existing hazards have been evaluated by the supervisor and that necessary protective measures have been taken for the safety of workers. It will provide documentation of the atmospheric testing that has been done. It will assign entry and attendant duties to specific persons.

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Before issuing an entry permit, the supervisor will be responsible for the following:

As the danger of explosion, asphyxiation, toxic gases/fumes, engulfment or entrapment, electrical or mechanical hazards, etc.

Isolate the space from potential hazards, if possible, to provide for safe entry.

Purge, inert, flush, ventilate to eliminate atmospheric hazards.

Provide external barriers and warning signs.

Perform pre-entry oxygen, flammable gas and toxicity air tests. All test results are to be recorded on the entry permit. If potential hazards cannot be isolated, continuous monitoring is required. If potential hazards can be isolated, periodic monitoring is required.

Provide at least one trained attendant outside of each confined space that will be entered.

Ensure that rescue and emergency services and equipment are in place as noted in this policy.

Ensure that all required equipment is provided, maintained and properly used. This includes air monitoring equipment, forced air ventilation equipment, communications equipment, personal protective equipment (PPE), lighting, external barriers and warning signs, ladders, and rescue equipment.

If hazardous conditions are detected during entry, employees will immediately leave the space and the supervisor will determine the cause of the hazardous atmosphere and take corrective actions before allowing re-entry.

Rescue & Emergency Services

If proper protective measures are taken to eliminate and control any possible hazards in the confined space (i.e., ventilation, purging, monitoring, lockout/tagout, etc.), rescue operations should not be necessary. Nonetheless, we must be prepared for the worst case scenario.

We working at remote site ensure you know the emergency procedures for the site. If you are not given guidance then request it before your begin work.

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Under no circumstances is the attendant to enter the space to effect rescue; rescue operations must be left to trained Emergency Response Team personnel.

Training

Employees involved with permit-required confined space work will be trained to assure the knowledge, understanding, and skills necessary for the safe performance of their duties. The on site supervisor will be trained in the identification and evaluation of confined space hazards and in the proper precautions to be taken to assure safe entry and work in confined spaces. Employees entering confined spaces will be trained in the hazards and potential hazards involved and how to protect themselves from those hazards. They will be trained to never enter a confined space until a permit is issued and they have been authorized to by the foreman. Attendants will be trained in their duties and responsibilities and the actions to be taken in the event of an emergency.

Subcontractors

Subcontractors should be required to submit written policies and procedures for entry into permit-required confined spaces that are at least as stringent as our policies and procedures. Entry into confined spaces by the subcontractors must be coordinated with and approved by the supervisor in charge of the confined space.

Subcontractors will be responsible for providing all training, equipment, testing, personnel and emergency services, and permits for entry into confined spaces by their employees.

In cases where our employees and those of subcontractors may be entering the same confined spaces or where operations of subcontractors may impact the hazards involved in the confined spaces we must enter, the supervisor will coordinate our efforts and protective measures with those of the subcontractors.

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FALL PROTECTION

1 PURPOSE

It is important to take all practical measures possible to prevent employees from being injured by falls from heights.

This information is base on the OSHA standard for potential falls from heights of at least 6 feet. First consideration will be given to the elimination of fall hazards. If a fall hazard cannot be eliminated, effective fall protection will be planned, implemented, and monitored to control the risks of injury due to falling.

All employees exposed to potential falls from heights will be trained to minimize the exposures. Fall protection equipment will be provided and its use required by all employees.

2 GENERAL:

DEFINITIONS

Anchorage:

A secure point of attachment, not part of the work surface, to which lifelines, drop-lines, or lanyards are affixed. An anchorage must be capable of supporting a minimum dead weight of 5,000 pounds (2,268 kilograms) for every person attached to it. An anchorage is often a beam, girder, column, or floor.

Anchorage connector:

A component or device that is installed on an anchorage and is specifically intended for attaching a fall-arrest system to the anchorage. Anchorage connection straps, carabineers, and girder grips rated to support a minimum dead weight of 5,000 pounds (2,268 kilograms).

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Carabineer:

A trapezoid or oval shaped connector component with a gate or similar arrangement that remains closed until it is intentionally opened for connection or disconnection.

Descent Device:

A device or piece of equipment used to escape from an elevated structure such as a work platform, tower, column, or an overhead crane cab.

Energy Shock Absorber:

A device that limits shock-load forces on the body. Some lanyards have built-in shock absorbers. Most energy shock absorbers are made of webbing material with tear-away stitching designed to gradually absorb the fall-arrest load.

Fall-Arrest System:

A system specifically designed to secure, suspend, or assist in retrieving a worker in or from a hazardous work area. A fall-arrest system may not prevent a fall, but it will reduce the fall distance and prevent or reduce injury. The basic components of a fall-arrest system include an anchorage, anchorage connector, lanyard, shock absorber, harness, and self-locking snap hook.

Fall Hazard:

A condition or situation that could result in a fall.

Fallout:

An unintentional separation of a person from a body-support component during or after fall arrest.

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Fall Prevention:

Eliminating fall hazards during all phases of work at heights, including access and egress. Examples of fall prevention measures include using complete scaffolds, aerial lifts, and secured ladders.

Free Fall:

An un-arrested fall.

Harness (full-body):

A device with straps that can be attached to a fall-arrest system. The straps are fastened around a person‘s body to contain the torso and distribute fall-arrest forces over at least the upper thighs, pelvis, chest and shoulders.

Lanyard:

A flexible line that secures a person wearing a harness to an anchorage, anchorage connector, lifeline, or drop line. A lanyard must have a nominal breaking strength of 5,000 pounds (2,268 kilograms) and may be nylon or Dacron rope, flexible aircraft steel cable, or webbing.

Leading Edge:

The edge of a floor, deck, or grating that changes location as additional floor or deck sections are placed.

Lifeline:

A flexible vertical or horizontal line, secured to an anchorage or between two anchorages, to which a lanyard or harness may be attached. A Catenary lifeline is a lifeline used in a horizontal position that is secured between two anchorages. A lanyard can be attached to a catenary lifeline by using a sliding connection or by tying off.

Positioning Device System:

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Equipment that allows a person to work with both hands free while standing in such a way (for example, leaning backward) that a fall could result. Positioning device systems are often used on framework construction and concrete rebar replacement.

Retractable lifeline:

A fall-arrest device that allows free travel without slack rope, but locks instantly when a fall begins. Retractable lifelines may be used when vertical movement is required but must be limited, such as in tanks, manholes, and pressure vessels, or on roofs.

Rollout:

A process by which a snap hook or carabineer unintentionally disengages from another connector or object.

Rope Grabs (Fall-Arrester):

Automatic lifeline devices that act by inertia to grab the lifeline if a fall should occur. Rope grabs are used when vertical movement is required, such as work from boatswain chairs or suspended scaffolds.

Self-locking Snap Hook:

A hook-shaped connector with a gate or similar arrangement that remains closed and locked until it is intentionally opened for connection or disconnection. When the gate is released, it automatically closes.

3 PROCEDURE

Fall Hazard Identification and Evaluation:

The senior employee on each jobsite will be responsible for identifying fall hazards on their jobsite. He/she will evaluate each situation or work procedure where employees may be exposed to a fall of 6 feet or more. The senior

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employee will be responsible for developing a plan to eliminate the exposures, if possible, or to select the appropriate fall protection systems and/or equipment.

Examples of Situations Requiring Fall Protection:

We are not contractors nor are we responsible for on site safety, we should be cognizant of the required fall protection safety requirements when we are out on a job. The following are examples of situations were fall protection would be needed. This listing is by no means complete, and there are many other situations where a fall of 6 feet or more is possible. It should be noted that ladders and scaffolding are not included in this list because they are covered by other OSHA standards and other requirements of our safety program.

Wall Openings:

Each employee working on, at, above, or near wall openings (including those with chutes attached) where the outside bottom edge of the wall opening is 6 feet (1.8 meters) or more above lower levels and the inside bottom edge of the wall opening is less than 39 inches (1.0 meter) above the walking/working surface must be protected from falling by the use of a guardrail system, a safety net system, or a personal fall arrest system.

Holes:

Personal fall arrest systems, covers, or guardrail systems shall be erected around holes (including skylights) that are more than 6 feet (1.8 meters) above lower levels.

Leading Edges:

Each employee who is constructing a leading edge 6 feet (1.8 meters) or more above lower levels shall be protected by guardrail systems, safety net systems, or personal fall arrest systems.

Excavations:

Each employee at the edge of an excavation 6 feet (1.8 meters) or more deep shall be protected from falling by guardrail systems, fences, barricades, or covers. Where walkways are provided to permit employees to cross over excavations, guardrails are required on the walkway if it is 6 feet (1.8 meters) or more above the excavation.

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Formwork and Reinforcing Steel:

For employees, while moving vertically and/or horizontally on the vertical face of rebar assemblies built in place, fall protection is not required when employees are moving. OSHA considers the multiple hand holds and foot holds on rebar assemblies as providing similar protection as that provided by a fixed ladder. Consequently, no fall protection is necessary while moving point to point for heights below 24 feet (7.3 meters). An employee must be provided with fall protection when climbing or otherwise moving at a height more than 24 feet (7.3 meters), the same as for fixed ladders.

Hoist Areas:

Each employee in a hoist area shall be protected from falling 6 feet (1.8 meters) or more by guardrail systems or personal fall arrest systems. If guardrail systems (or chain gate or guardrail) or portions thereof must be removed to facilitate hoisting operations, as during the landing of materials, and a worker must lean through the access opening or out over the edge of the access opening to receive or guide equipment and materials, that employee must be protected by a personal fall arrest system.

Ramps, Runways, and Other Walkways:

Each employee using ramps, runways, and other walkways shall be protected from falling 6 feet (1.8 meters) or more by guardrail systems.

Low-slope Roofs:

Each employee engaged in roofing activities on low-slope roofs with unprotected sides and edges 6 feet (1.8 meters) or more above lower levels shall be protected from falling by guardrail systems, safety net systems, personal fall arrest systems or a combination of a warning line system and guardrail system, warning line system and safety net system, warning line system and personal fall arrest system, or warning line system and safety monitoring system. On roofs 50 feet (15.24 meters) or less in width, the use of a safety monitoring system without a warning line system is permitted.

Steep Roofs:

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Each employee on a steep roof with unprotected sides and edges 6 feet (1.8 meters) or more above lower levels shall be protected by guardrail systems with toe boards, safety net systems, or personal fall arrest systems.

Controlled Access Zones:

A Controlled access zone is a work area designated and clearly marked in which certain types of work may take place without the use of conventional fall protection systems, personal arrest or safety net to protect the employees working in the zone.

Controlled access zones are used to keep out workers other than those authorized to enter work areas from which guardrails have been removed. Controlled access zones, when created to limit entrance to areas where leading edge work and other operations are taking place, must be defined by a control line or by any other means that restrict access. Control lines shall consist of ropes, wires, tapes or equivalent materials, and supporting stanchions, and each must be:

Flagged or otherwise clearly marked at not more than 6-foot (1.8 meters) intervals with high-visibility material;

Rigged and supported in such a way that the lowest point (including sag) is not less than 39 inches (1 meter) from the walking/working surface and the highest point is not more than 45 inches (1.3 meters)--nor more than 50 inches (1.3 meters) when overhand bricklaying operations are being performed from the walking/working surface;

Strong enough to sustain stress of not less than 200 pounds (0.88 kilonewtons), Control lines shall extend along the entire length of the unprotected or leading edge and shall be approximately parallel to the unprotected or leading edge.

Control lines also must be connected on each side to a guardrail system or wall.

When control lines are used, they shall be erected not less than 6 feet (1.8 meters) nor more than 25 feet (7.6 meters) from the unprotected or leading edge, except when precast concrete members are being erected. In the latter case, the control line is to be erected not less than 6 feet (1.8 meters) nor more than 60 feet (18 meters) or half the length of the member being erected, whichever is less, from the leading edge.

Controlled access zones when used to determine access to areas where overhand bricklaying and related work are taking place are to be defined by a

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control line erected not less than 10 feet (3 meters) nor more than 15 feet (4.6 meters) from the working edge. Additional control lines must be erected at each end to enclose the controlled access zone. Only employees engaged in overhand bricklaying or related work, are permitted in the controlled access zones.

On floors and roofs where guardrail systems are not in place prior to the beginning of overhand bricklaying operations, controlled access zones will be enlarged as necessary to enclose all points of access, material handling areas, and storage areas.

On floors and roofs where guardrail systems are in place, but need to be removed to allow overhand bricklaying work or leading edge work to take place, only that portion of the guardrail necessary to accomplish that day‘s work shall be removed.

Fall Protection Systems

When there is a potential fall of 6 feet or more, we will utilize one or more of the following means of providing protection:

Guardrail Systems:

Guardrail systems must meet the following criteria: Toprails and midrails of guardrail systems must be at least one-quarter inch (0.6 centimeters) nominal diameter or thickness to prevent cuts and lacerations. If wire rope is used for toprails, it must be flagged at not more 6 feet intervals (1.8 meters) with high-visibility material. Steel and plastic banding cannot be used as toprails or midrails. Manila, plastic, or synthetic rope used for toprails or midrails must be inspected as frequently as necessary to ensure strength and stability.

The top edge height of toprails or (equivalent) guardrails must be 42 inches (1.1 meters) plus or minus 3 inches (8 centimeters), above the walking/working level. When workers are using stilts, the top edge height of the top rail, or equivalent member, they must increase the amount equal to the height of the stilts.

Screens, midrails, mesh, intermediate vertical members, or equivalent intermediate structural members must be installed between the top edge of the guardrail system and the walking/working surface when there are no walls or parapet walls at least 21 inches (53 centimeters) high. When midrails are used, they must be installed at a height midway between the top edge of the guardrail system and the walking/working level. When screens and mesh are used, they

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must extend from the top rail to the walking/working level and along the entire opening between top rail supports. Intermediate members, such as balusters, when used between posts, shall not be more than 19 inches (48 centimeters) apart.

Other structural members, such as additional midrails and architectural panels, shall be installed so that there are no openings in the guardrail system more than 19 inches (48 centimeters).

The guardrail system must be capable of withstanding a force of at least 200 pounds (890 newtons) applied within 2 inches of the top edge in any outward or downward direction. When the 200 pound (890 newtons) test is applied in a downward direction, the top edge of the guardrail must not deflect to a height less than 39 inches (1 meter) above the walking/working level.

Midrails, screens, mesh, intermediate vertical members, solid panels, and equivalent structural members shall be capable of withstanding a force of at least 150 pounds (667 newtons) applied in any downward or outward direction at any point along the midrail or other member.

Guardrail systems shall be surfaced to protect workers from punctures or lacerations and to prevent clothing from snagging.

The ends of top rails and midrails must not overhang terminal posts, except where such overhang does not constitute a projection hazard.

When guardrail systems are used at hoisting areas, a chain, gate or removable guardrail section must be placed across the access opening between guardrail sections when hoisting operations are not taking place.

At holes, guardrail systems must be set up on all unprotected sides or edges. When holes are used for the passage of materials, the hole shall have not more than two sides with removable guardrail sections. When the hole is not in use, it must be covered or provided with guardrails along all unprotected sides or edges.

If guardrail systems are used around holes that are used as access points (such as ladder ways), gates must be used or the point of access must be offset to prevent accidental walking into the hole.

If guardrails are used at unprotected sides or edges of ramps and runways, they must be erected on each unprotected side or edge.

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Personal Fall Arrest Systems

Personal Fall Arrest Systems consist of an anchorage, connectors, and a body harness and may include a deceleration device, lifeline, or suitable combinations. If a personal fall arrest system is used for fall protection, it must do the following:

Limit maximum arresting force on an employee to 900 pounds (4 kilonewtons) when used with a body belt;

Limit maximum arresting force on an employee to 1,800 pounds (8 kilonewtons) when used with a body harness;

Be rigged so that an employee can neither free fall more than 6 feet (1.8 meters) nor contact any lower level;

Bring an employee to a complete stop and limit maximum deceleration distance an employee travels to 3.5 feet (1.07 meters); and

Have sufficient strength to withstand twice the potential impact energy of an employee free falling a distance of 6 feet (1.8 meters) or the free fall distance permitted by the system, whichever is less.

The use of body belts for fall arrest is prohibited and a full body harness is required.

Personal fall arrest systems must be inspected prior to each use for wear damage, and other deterioration. Defective components must be removed from service.

Positioning Device Systems

These body belt or body harness systems are to be set up so that a worker can free fall no farther than 2 feet (0.6 meters). They shall be secured to an anchorage capable of supporting a least twice the potential impact load of an employee‘s fall or 3,000 pounds (13.3 kilonewtons), whichever is greater.

Safety Monitoring Systems

When no other alternative fall protection has been implemented, the employer shall implement a safety monitoring system. Employers must appoint a competent person to monitor the safety of workers and the employer shall ensure that the safety monitor:

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Is competent in the recognition of fall hazards; Is capable of warning workers of fall hazard dangers and in

detecting unsafe work practices; Is operating on the same walking/working surfaces of the workers

and can see them; Is close enough to work operations to communicate orally with

workers and has no other duties to distract from the monitoring function.

Mechanical equipment shall not be used or stored in areas where safety monitoring systems are being used to monitor employees engaged in roofing operations on low-sloped roofs.

No worker, other than one engaged in roofing work (on low-sloped roofs) or one covered by a fall protection plan, shall be allowed in an area where an employee is being protected by a safety monitoring system.

All workers in a controlled access zone shall be instructed to promptly comply with fall hazard warnings issued by safety monitors.

Safety Net Systems

Safety nets must be installed as close as practicable under the walking/working surface on which employees are working and never more than 30 feet (9.1 meters) below such levels. Defective nets shall not be used. Safety nets shall be inspected at least once a week for wear, damage, and other deterioration. Safety nets shall be installed with sufficient clearance underneath to prevent contact with the surface or structure below.

Items that have fallen into safety nets including—but not restricted to, materials, scrap, equipment, and tools—must be removed as soon as possible and at least before the next work shift.

Warning Line Systems

Warning line systems consist of ropes, wires, or chains, and supporting stanchions and are set up as follows:

Flagged at not more than 6-foot (1.8 meters) intervals with high-visibility material;

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Rigged and supported so that the lowest point including sag) is no less than 34 inches (0.9 meters) from the walking/working surface and its highest point is no more than 39 inches (1 meter) from the walking/working surface.

Stanchions, after being rigged with warning lines, shall be capable of resisting, without tipping over, a force of at least 16 pounds (71 newtons) applied horizontally against the stanchion, 30 inches (0.8 meters) above the walking/working surface, perpendicular to the warning line and in the direction of the floor, roof, or platform edge;

The rope, wire, or chain shall have a minimum tensile strength of 500 pounds (2.22 kilonewtons) and after being attached to the stanchions, must support without breaking the load applied to the stanchions as prescribed above.

Shall be attached to each stanchion in such a way that pulling on one section of the line between stanchions will not result in slack being taken up in the adjacent section before the stanchion tips over.

Warning lines shall be erected around all sides of roof work areas. When mechanical equipment is being used, the warning line shall be erected not less than 6 feet (1.8 meters) from the roof edge parallel to the direction of mechanical equipment operation, and not less than 10 feet (3 meters) from the roof edge perpendicular to the direction of mechanical equipment operation.

When mechanical equipment is not being used, the warning line must be erected not less than 6 feet (1.8 meters) from the roof edge.

Covers

Covers located in roadways and vehicular aisles must be able to support at least twice the maximum axle load of the largest vehicle to which the cover might be subjected. All other covers must be able to support at least twice the weight of employees, equipment, and materials that may be imposed on the cover at any one time. To prevent accidental displacement resulting from wind, equipment, or workers‘ activities, all covers must be secured. All covers shall be color coded or bear the markings "HOLE" or "COVER."

Protection From Falling Objects

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When guardrail systems are used to prevent materials from falling from one level to another, any openings must be small enough to prevent passage of potential falling objects. No materials or equipment except masonry and mortar shall be stored within 4 feet (1.2 meters) of working edges. Excess mortar, broken or scattered masonry units, and all other materials and debris shall be kept clear of the working area by removal at regular intervals.

During roofing work, materials and equipment shall not be stored within 6 feet (1.8 meters) of a roof edge unless guardrails are erected at the edge, and materials piled, grouped, or stacked near a roof edge must be stable and self-supporting.

4 TRAINING

Employees should be trained in the following areas: (a) the nature of fall hazards in the work area; (b) the correct procedures for erecting, maintaining, disassembling, and inspecting fall protection systems; (c) the use and operation of controlled access zones and guardrail, personal fall arrest, safety net, warning line, and safety monitoring systems; (d) the limitations on the use of mechanical equipment during the performance of roofing work on low-sloped roofs; (e) employees‘ role in fall protection plans.

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HAZARD COMMUNICATION PROGRAM

1 PURPOSE AND SCOPE

Purpose

This procedure provides the guidelines to protect the safety and health of all employees through the identification, communication, dissemination of material safety data sheet information, container labeling, and employee training in the safe use of toxic or hazardous substances used on projects.

Scope

This procedure applies to all Becht personnel and subcontractors working on projects where the requirements of a Hazard Communication Program are applicable.

2 GENERAL

Every workplace contains some substances which could pose potential health problems to employees if exposed to them in concentrations or in a manner not prescribed. A hazardous substance is defined as any substance that is a physical hazard or a health hazard, i.e. compressed gases, explosives, flammables, oxidizers, carcinogens, toxins, irritants, or corrosives. Hazardous substances generally have a Material Safety Data Sheet (MSDS) provided by the manufacturer.

3 PROCEDURE

This Program is established to:

Ensure compliance with the applicable state and federal standard; safeguard the health and safety of employees of Becht

Engineering; and Create guidelines to follow for implementation and maintenance of

a hazard communication program.

The Hazard Communication Program shall be administered by the Company Safety Manager. This program defines the minimum hazard communication

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program requirements; the separate divisions will be responsible for developing and maintaining their own internal procedures in accordance with these guidelines and policies.

Chemical Inventory and Material Safety Data Sheets

Annual updates of the Chemical Information Lists (CIL) (See Attachment 1: Chemical Information Lists (CIL) to Becht Engineering Hazardous Communication Program) will be provided by the Company Safety Manager. Division Safety Officers will ensure the any chemicals listed on the CIL are properly stored in accordance with the manufactures safety instructions. The Division Safety Offices will also ensure the outside door of any location where chemicals on the CIL are stored is marked appropriately to warn the fire department should there be a fire. Division Safety Officers are to report the locations of any storage of items on the CIL.

Signs and Labels

All existing labels on containers of hazardous substances must remain intact. The labels must be legible and written in English. Where labels are not present or are not legible, a Hazardous Material Information System (HMIS) label will be affixed to those containers holding the hazardous substance.

It is the responsibility of the Division Safety Officers to assure that each container of a hazardous substance in the workplace is marked, labeled or tagged with the common/trade name of the substance and the appropriate hazard warnings: Health, flammability, reactivity, and personal protective equipment.

Portable containers filled with hazardous chemicals transferred from a labeled storage container must be labeled if the material is not used within the work shift of the employee making the transfer; the employee that made the transfer leaves the work area; the container is moved to another work area and is no longer in possession of the employee who filled the container.

Employees that work in the store room areas, where sealed containers of hazardous substances are received for distribution to other departments, must assure that the manufacturer's labels are not defaced or removed. In addition, if a spill or leak occurs in a container of hazardous substance, the employees should leave the area, go to a place of safety, and call the Division Safety Officer or the Company Safety Manager.

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In addition to the labeling requirement for containers of hazardous substances, the area where the hazardous substance is used or stored must be properly marked.

Exclusions

These regulations do not apply to any substances which are foods, drugs, cosmetics, or tobacco products intended for personal consumption by the employees while in the workplace. Additionally, these regulations do not apply to any consumer products and food stuffs packaged for distribution to (and intended for use by) the general public. Consumer products are packaged and used as a normal consumer would use the product as defined in the Consumer Product Safety Act and Federal Hazardous Substances Act.

Exposure

Exposure means that an employee is subjected to a hazardous chemical in the course of employment through any route of entry (inhalation, ingestion, skin contact or absorption, etc.), and includes potential (e.g. accidental or possible) exposure as referenced by the MSDS. When the employer discovers that an employee has received a potentially hazardous exposure to any substance or agent, the employer must immediately notify the employee and take such steps that may be necessary to provide medical evaluation, monitoring, or treatment. Likewise, an employee that has received a potentially hazardous exposure to a substance or agent must immediately notify his/her immediate supervisor of such exposure.

After the appropriate safety and health precautions have been taken, it is the responsibility of the employee's supervisor to fill out an Employee Exposure Report (EER). EER forms are available from the Company Safety Manager. (See Attachment 2: Employee Exposure Report (EER) to Becht Engineering Hazardous Communication Program).

The Company Safety Manager will retain the original EER for record keeping purposes and if the incident requires it, the EER will be the base documentation for an investigation.

Employees working in areas where exposure(s) to hazardous substances exist shall be required to perform their jobs in accordance with precautions communicated to them during training and education programs. A supervisor

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may take the appropriate disciplinary action when an employee does not comply with the precautionary measure this policy indicates.

The Division Manager or designee shall be responsible for providing the following in all departmental areas having contact with hazardous substances:

Chemical name of each hazardous substance. Correct labeling of each hazardous substance. Availability of any MSDS for each hazardous substance present in

the immediate work area. Training and education of employees on work practices, protective

measures, and emergency measures in the work place.

4 TRAINING

New Employees will receive initial training on the Hazardous Communication Program when the in-process into the company. Division Safety Officers are responsible for conducting follow up training as necessary.

Training and education provided to employees and others must be documented with detailed records of training maintained by the division.

5 FIRE SAFETY

The Company Safety Officer will conduct unannounced annual fire drills, including briefings on hazardous material stored at Becht Engineering, their locations and the safety hazards they contain.

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HEARING CONSERVATION PROGRAM

1 PURPOSE AND SCOPE

Purpose

To establish the minimum requirements for hearing conservation and hearing protective equipment at Becht facilities and job sites.

To prevent employee hearing loss resulting from exposure to industrial noise over 85 decibels (dBA) averaged over eight (8) working hours.

To identify areas / equipment that has high noise levels (over 85 decibels).

Scope

This procedure establishes minimum requirements for the use of hearing protective equipment in all working and operating areas. This procedure applies to all Becht employees, Sub-contractors and Vendors / Visitors.

The procedure specifically applies whenever there could reasonably be exposure to occupational noise levels above 85 decibels (dBA) averaged over eight (8) working hours.

2 GENERAL

Responsibilities

The Division Safety Officer / Designee are responsible for:

Providing hearing protectors to all employees exposed to an eight-hour time-weighted average of 85 decibels at no cost to the employee.

Posting and maintaining warning signs where hearing protection is required.

Conferring with the supervisors/clients to identify noise hazards and hearing protection required for a specific job / task.

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o When information indicates that employee exposure may equal/exceed the eight-hour time-weighted average of 85 decibels, Becht Engineering shall implement a monitoring program to identify employees to be included in the hearing conservation program.

Monitoring compliance with the use of proper hearing protection. Ensuring special hearing protection is available on site. Minimizing the sources of industrial noise in their areas whenever

practical. This should include the following: o Proper maintenance of equipment o Selecting machines with lower noise levels o Using mufflers, dampers, etc.

Using barriers, baffles, enclosures, absorptive materials, etc. Isolation of the operator from the noise, if possible and practical. Other engineering noise reduction controls

The Employee is responsible for:

Complying with this procedure and using the required hearing

protection. Conferring with supervision as to noise hazards involved and

hearing protection requirements associated with the job. Inspecting hearing protection equipment prior to each use and

maintaining it in a good and clean condition. Advising supervision of any suggestions to improve the Hearing

Conservation Program or the use or selection of hearing protective equipment.

Requesting information from supervision about any portion of the Hearing Conservation Program that is not fully understood.

Having hearing protectors in their possession and using them whenever exposed to elevated noise levels, regardless of the cause or duration of the noise.

Following all verbal instructions and obeying signs requiring hearing protection.

3 PROCEDURE

All hearing protection equipment used at Becht must meet the applicable OSHA and ANSI requirements.

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The Hearing Conservation Program will be covered with new employees in the orientation training. Hearing protection requirements, importance and limitations will be included in at least one safety meeting each year by each Supervisor. Visitors to the facility / site (non-employees) who enter the construction or maintenance areas must be furnished hearing protection if it is required. It is the responsibility of their Becht escort to ensure they have and wear the equipment. CLIENT FACILITY PROGRAMS Every employee working in an operations or maintenance area is required to have hearing protection with them at all times. Although most personnel are not exposed to noise on a continuous basis, unforeseen events may occur that renders a usually quiet area into an area of damaging noise. At most operating facilities the client will conduct noise level surveys and post areas requiring hearing protectors. Should Becht‘s scope of work dictate initiation of a hearing conservation program, outside of the 1926 construction standard, Becht will in most cases adopt the client‘s program. By adopting the client‘s program, Becht will include and accept the client‘s noise level survey. However, as a rule of thumb, if an employee must elevate his / her normal speaking voice to be heard, he / she is in an area where hearing protection must be worn. The following applies to the uses of hearing protectors: Client facilities with noise levels above 90 dBA should have signs posted at all entrances, which state ―Caution, Hearing Protection Required‖. Areas with noise levels above 105 dBA will be posted as ―Danger, Double Hearing Protection Required‖. Employees will be allowed to select their hearing protectors from a variety of styles designed to reduce noise to acceptable levels. Taking their exposure profile into consideration, employees will not be allowed to choose a protector with a noise reduction rating less than what they would need to reduce the noise levels which they are exposed to in their particular job assignment. Employee will be properly fitted with their selected hearing protection. In compliance with company rules, hearing protectors must be worn when working in regulated or obviously noisy areas. Audiometric Testing and Evaluation Program

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Annual audiometric testing shall be mandatory for those employees exposed to noise at or above an eight-hour TWA of 85dBA. Testing will be done at no cost to the employee. The testing equipment, calibration, record keeping, evaluation, and follow-up shall comply with all requirements listed in OSHA Standard 1910.95. RECORD KEEPING All records for noise monitoring will be kept by the Company Safety Manager. If required, audiometric tests and other medical records will also be kept by the Company Safety Manager. MANAGEMENT CONTROLS Documentation of all Hearing Conservation training is required. Facility / Site Supervision / Sub-contractor Coordinators should continue on-the-job instruction to employees on hearing conservation as necessary to ensure proper compliance with these procedures. Auditing to ensure compliance with the Hearing Conservation Procedure should be performed. Periodic audits will be conducted by supervision. All records required by this procedure will be kept in accordance with OSHA requirements. Any non-conformance with this policy will be addressed and corrected by the responsible supervision.

4 REFERENCES

The requirements of the following OSHA Occupational Safety and Health Administration (OSHA), 29 1926.101 Hearing Protection

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LEAD AWARENESS

***NOTE*** No employee is authorized to work on any equipment which may contain lead based paint etc. All work involving lead will be abated by the facility prior to our work beginning. This program is provided simply as general awareness program.

1 PURPOSE

The Lead Safety Awareness Program is to protect both our employees and the environment from lead contamination. The intent of our program is to be in full, continuous compliance with OSHA Standard and all other local, State and Federal requirements for our industry.

2 GENERAL

Responsibilities

Management will implement, maintain & monitor effectiveness of:

entire lead safety program, including semi-annual revisions and updates to reflect the current status of the program

engineering and administrative controls for lead exposure employee training and awareness medical surveillance program respiratory protection program lead disposal program housekeeping program protective clothing issue, storage and disposal

Supervisors will:

provide effective and continuous control of all lead operations immediately inform management of any deficiencies in engineering

or administrative controls

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conduct routine assigned inspections and monitoring immediate correct any deviation from operational safety

requirements provide immediate on-the-spot training for any employee who

shows lack of knowledge or application of required operational lead safety requirements

ensure all employees are properly trained before commencing any operation that may contribute to lead exposure

Employees will:

follow all operational and lead safety procedures seek immediate supervisor guidance to resolve questions conduct operations in accordance with Company provided training immediately report to a supervisor any deficiency in engineering or

administrative controls properly use, store and dispose of issued and assigned personal

protective clothing. maintain change and shower areas neat and orderly

3 PROCEDURES

Hazards

Pure lead (Pb) is a heavy metal at room temperature and pressure and is a basic chemical element. It can combine with various other substances to form numerous lead compounds. The Permissible Exposure Limit (PEL) set by OSHA is 50 micrograms of lead per cubic meter of air (50 ug/m(3)), averaged over an 8-hour workday.

Lead can be absorbed by inhalation (breathing) and ingestion (eating). Lead is not absorbed through your skin. When lead is scattered in the air as a dust, fume or mist it can be inhaled and absorbed through the lungs and upper respiratory tract. Lead can also be absorbed through the digestive system if swallowed. Handling food, cigarettes, chewing tobacco, or make-up which have lead contamination or handling them with hands contaminated with lead, will contribute to ingestion.

A significant portion of inhaled or ingested lead goes into the blood stream. Once in the blood stream, lead is circulated throughout the body and stored in various organs

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and body tissues. Some of this lead is quickly filtered out of the body and excreted, but some remains in the blood and other tissues. As exposure to lead continues, the amount stored in the body will increase. Lead stored in body tissues can cause irreversible damage, first to individual cells, then to organs and whole body systems.

Short-term (acute) effects of overexposure to lead

Lead is a potent, systemic poison. Taken in large enough doses, lead can kill in a matter of days. A condition affecting the brain called acute encephalopathy may arise which develops quickly to seizures, coma, and death from cardio-respiratory arrest. There is no sharp dividing line between rapidly developing acute effects of lead, and chronic effects which take longer to acquire. Lead adversely affects numerous body systems, and causes forms of health impairment and disease which arise after periods of exposure as short as days or as long as several years.

Long-term (chronic) effective of overexposure to lead

Chronic overexposure to lead may result in severe damage to blood-forming, nervous, urinary and reproductive systems. Some common symptoms of chronic overexposure include loss of appetite, metallic taste in the mouth, anxiety, constipation, nausea, pallor, excessive tiredness, weakness, insomnia, headache, nervous irritability, muscle and joint pain or soreness, fine tremors, numbness, dizziness, hyperactivity and colic. In lead colic there may be severe abdominal pain.

Signs

Proper signs will be posted at the entrance and exits to all lead hazard areas, no other signs or statements may appear on or near any lead hazard sign which contradicts or detracts from the meaning of the required sign. All lead hazard signs will be kept illuminated and cleaned as necessary so that the legend is readily visible. The signs will contain the following or other appropriate wording/warning:

WARNING LEAD WORK AREA POISON NO SMOKING OR EATING

4 TRAINING

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All affected employees will participate in the Companies Lead Safety Training program. All affected employees will be trained prior to the time of initial job assignment and at least annually.

A copy of the OSHA standard 1910.1025 and its appendices will be readily available to all affected employees.


1 PURPOSE

The Becht Engineering shall ensure the availability of medical personnel for advice and consultation on matters of occupational health. 1926.50(a)

When a medical facility is not reasonably accessible for the treatment of injured employees, a person qualified to render first aid shall be available at the worksite. 1926.50(c)

First-aid supplies when required will be readily available. 1926.50(d)(1)

2 PROCEDURE

Each advisor on assignment that is not expected to have a medical facility will be issued a first aid kit to accompany him/her on assignment. The Division Safety Officer/Designee shall check the First Aid Kit before being sent out on each job and the advisor will check the kit at least weekly on each job to ensure that the expended items are replaced.

The first aid kit shall consist of a weatherproof container with individual sealed packages for each type of item. The contents of such kit shall contain a sufficient quantity of at least the following types of items:

Gauze roller bandages, 1 inch and 2 inch.

Gauze compress bandages, 4 inch.

Adhesive bandages, 1 inch.

Triangular bandage, 40 inch.

Ammonia inhalants and ampoules.

Antiseptic applicators or swabs.

Burn dressing.

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Eye dressing.

Wire or thin board splints.

Forceps and tourniquet.

Proper equipment for prompt transportation of the injured person to a physician or hospital, or a communication system for contacting necessary ambulance service, shall be provided.

In areas where 911 is not available, the telephone numbers of the physicians, hospitals, or ambulances shall be conspicuously posted.

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

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PERSONAL PROTECTIVE EQUIPMENT PROGRAM

1 PURPOSE AND SCOPE

Purpose

The purpose of this program is to protect our employees by ensuring that Personal Protective Equipment (PPE) is provided, used, and maintained in a sanitary and reliable condition whenever it is necessary due to hazards from processes or in the work environment. To the extent that it is possible and feasible, the company will remove or eliminate hazards or exposures through engineering means to eliminate the need for PPE.

Scope

This program covers eye and face protection, head protection, foot protection, hand protection, and electrical protection. Respiratory hazards and hearing hazards are covered by other programs, but they will also be included in the Hazard Assessment described below. This program covers the responsibilities of managers, supervisors and workers, assessment of hazards, selection and use of personal protective equipment (PPE), and training.

2 GENERAL

Responsibilities

The on site supervisor will be responsible for assessing the hazards and exposures that may require the use of PPE, determining the type of equipment to be provided, and purchasing the equipment. Input from managers, supervisors, and employees will be obtained and considered in selecting appropriate equipment.

Managers/supervisors will be responsible for training employees in the use and proper care of PPE, ensuring that all employees are assigned appropriate PPE, and ensuring that PPE is worn by employees when and where it is required.

Employees are responsible for following all provisions of this program and related procedures. They are expected to wear PPE when and where it is required.

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3 PROCEDURE

Hazard Assessment:

The company will perform an assessment of the workplace to determine if hazards are present, or likely to be present, which necessitate the use of personal protective equipment (PPE). This assessment will consist of a survey of the workplace to identify sources of hazards to workers. Consideration will be given to hazards such as impact, penetration, laceration, compression (dropping heavy objects on foot, roll-over, etc.), chemical exposures, harmful dust, heat, light (optical) radiation, electrical hazards, noise, etc. Where such hazards are present, or likely to be present, we will:

o Select, and have each affected employee use, the types of

PPE that will protect the employee from the hazards identified in the hazard assessment.

o Communicate equipment selection decisions to each affected employee

o Select PPE that properly fits each affected employee o Train employees in the use and care of PPE as described

elsewhere in this program

Selection of Personal Protective Equipment:

Personal protective equipment (PPE) will be selected on the basis of the hazards to which the workers' are exposed or potentially exposed. All selections will be made by with input from managers, supervisors and workers.

Personal protective equipment will meet the following standards:

Eye & Face Protection devices - ANSI Z87.1-1989 "American National Standard Practice for Occupational and Educational Eye and Face Protection"

Head Protection devices - ANSI Z89.1-1986 "American National Standard for Personal Protection - Protective Headwear for Industrial Workers"

Foot Protection devices - ANSI Z41-1991 "American National Standard for Personal Protection - Protective Footwear"

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Hand Protection - No national standard available - selection will be based on task performed, conditions present, duration of use, and the hazards and potential hazards identified.

Electrical Protective equipment - No national standard - equipment will be tested electrically before first use and every 6 months thereafter or upon indication that insulating value is suspect.

Care of Personal Protective Equipment:

Whenever practical, PPE will be assigned to individual workers for their exclusive use. Employees will be responsible for the PPE equipment assigned to them or used by them.

PPE will be regularly cleaned, inspected and stored according to instructions given during the training sessions or as directed by supervisors or managers. Defective or damaged PPE shall not be used. Employees are to report any defective or damaged equipment to their supervisor for repair or replacement.

Protective Clothing and Equipment Requirements:

Protective Clothing: Personnel exposure to potentially harmful environments must be minimized before a job is started. Protective equipment is available to enable work to be carried on when there may be employee exposure. Experience tells us that approximately 15 percent of all accidents are caused by unsafe conditions. Most of these accidents can be eliminated or minimized by using personal protective equipment. This section describes the many types of personal protective equipment available and when they must be worn. Personal protective equipment which has been changed in any manner, thus reducing its effectiveness, shall be repaired or destroyed.

Head Protection: A safety hat shall be worn in areas under construction and in other areas where there‘s a potential hazard from falling or flying objects or from head-level obstructions. Such areas shall be posted. Only approved safety hats with properly installed headbands and support webbing shall be used in the situations described above. See OSHA 1910.135 and ANSI Z89.1-1969 for

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requirements. Electrically conductive hats shall not be worn by electricians or by others where electrical hazards exist.

When visiting foreign locations that do not recognize OSHA safety requirements, an effort should be made to determine in advance the type of safety hat provided in that location. If there is any doubt as to the adequacy of the type of hat available, a safety hat should be obtained prior to departure from the home office.

Foot protection: There are few jobs, if any, where the

protection of a safety shoe is not advisable. They protect the toes from falling objects, being pinched between objects, etc. The safety shoe also offers additional slip resistance to those employees who work in oily areas. Safety shoes are recommended for operating, mechanical, shop general utility and other assignments which might subject the feet to potential injury. Sandals, open-toed, and backless footwear shall be avoided as they afford little foot protection against falling objects or spilled liquids. Rubber overshoes, boots, or shoes with soft rubber, spongy gum rubber, or composition insulation-type soles shall not be worn where a buildup of body static charges create a hazard since the higher electrical resistance of these materials retards dissipation of the static. Becht Engineering will reimburse $50.00 towards the purchase of steel tipped safety shoes. Electrically-conductive soles may be required in conjunction with conductive, electrically grounded floors for work in certain explosion hazard areas. Rubber or insulating shoes shall not be permitted areas where conductive soles are required.

Nonconductive shoes may be required in conjunction with the work of the electricians.

Rubber boots or rubbers may be required in wet areas or where large quantities of corrosive materials are used.

Ear protection: In areas of high noise levels, the noise may

cause fatigue and distraction which could result in accidental injury. Excessive exposure to noise will cause hearing lose.

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Ear protectors should be worn when noise levels are over 90 decibels. There are a wide variety of such protectors available. The type supplied is governed by personal preference and/or by the job requirements. When the noise level is such that ordinary conversation is difficult, protection is recommended. Speech interpretation is easier in such areas with ear protection than without. Foam ear protection plugs are available at the Becht Engineering office and should be taken on trips where noise exposure is expected.

Hand Protection: Gloves of the correct type give protection

from heat and cold, corrosives, moisture, electricity, sharp or rough surfaces, flying fragments, etc.

Wear rubber gloves when handling corrosive chemicals or other hazardous liquids. Test your gloves for leaks by inflating with air and immersing in water. Do not use gloves which are perforated. Where protection hand is necessary and where extreme dexterity and sensitivity are important, special neoprene surgical or vinyl disposable gloves should be used. Always wash your gloves before removal. Clean them inside, too, before laying aside for future use. This precaution avoids the accumulation of hazardous materials inside the glove.

Some irritating chemicals are absorbed by rubber gloves; for example, acrylonitrile. Gloves used with this or similar materials shall be discarded after one week of actual use.

For wet work out-of-doors in cold weather, vinyl-coated lined gloves should be used.

Wear insulated gloves without cuffs when handling extremely cold materials such as dry ice, liquid nitrogen, etc., because cold burns are as serious as heat burns.

Terry cloth gloves should be used for protection against materials not at ambient temperatures. It is important to protect the forearm, too, when handling such objects.

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Leather palm/canvas backed gloves should be used for protection against abrasions and lacerations when working with rough or sharp materials.

Body protection: Loose gloves, clothing or long, loose

sleeves; neckties; pendant jewelry; finger rings; open jackets; etc.; shall not be worn around moving equipment. Further, fingers rings, wristwatches, and other metallic jewelry shall not be worn around electrical equipment because accidental contact could cause a potentially serious personal injury.

Cotton clothing which covers the arms and body provides considerable protection against flash burns, the sun‘s rays, insect bites, and poison ivy. Wool gives better protection from welder‘s flashes and splashed corrosive liquids. Tightly woven cloth gives better temporary splash protection than loosely woven materials.

Silk, light rayon, polyesters, and other synthetics or plastic materials, while sometimes more resistant to corrosive chemicals than cotton or wool, can melt or burn the skin when exposed to a flash and can contribute to the generation of static electricity. Their use shall be avoided in areas where flammable vapors or other materials can be ignited by a static discharge. Cotton is considered the best of untreated cloth or fabric for either flame resistance or static (see insert) charge buildup generally loses its resistance upon contact with quantities of water, such as rain, severe sink splashes, laundering, etc. Depending on laundering conditions, pretreatment may be required after each washing.

Specialized suits such as rubber and plastic aprons and acid suits for protection from chemical exposure are not normally required because Becht Engineering personnel are not expected to be exposed to such hazards. Should the potential for such exposure exist on an assignment, such protection and training shall be obtained from the host organization.

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Safety Harnesses: Approved safety harnesses must be worn when employees are exposed to falls from unprotected heights of 6 feet or less, if required by the host plant safety rules. Life lines should be secured to an independent support located above the point of operation. Some of the situations in which safety harnesses must be worn are:

When working from scaffolds, platforms, pipe racks or any other surface which may not afford sufficient protection against falling.

While working on any roof with a slope greater than one on four.

When working within six feet of the edge of any roof.

Where an oxygen deficiency exists or where the surrounding atmosphere is immediately hazardous to life.

Life vests: Life vests are required when working on barges

or directly over water.

Eye Protection: Eye protective equipment adequate for the job or area shall be worn at all times in laboratory, shop, construction, maintenance, chemical transfer, compounding, processing, and testing areas; chemical and mechanical stock sections in stockrooms; and other areas specifically posted. Also, employees on field assignments where their work takes them into areas described above shall wear eye protection. Minimum eye protection, where required, is safety spectacles or visitor safety spectacles. When in doubt, protect your eyes. An employee working in an area in which eye protection is required is responsible to inform anyone entering the area without such protection of the requirement. EYE PROTECTION IS NOT REQUIRED IN OFFICES, CAFETERIAS, RESTROOM, CORRIDORS, ELEVATORS, STAIRWELLS, SITE GROUNDS AND ON ROOFS, ETC., EXCEPT BY THOSE PERFORMING MECHANICAL OR LABORATORY TYPE WORK IN SUCH LOCATIONS.

Contact lenses do not constitute eye protection. If worn, a minimum of safety spectacles or visitor safety spectacles

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also must be worn in all situations where eye protection is required. Contact lenses shall not be worn when using a full face respirator, breathing apparatus; working in dusty or chemical fume environments; working near electrical, electronic or arc welding activities. The National Society for the prevention of Blindness strongly recommends against contact lens use by industrial employees while at work.

Becht Engineering provides prescription safety glasses, paying 100% of their cost through a program with The Eye Doctor.

Goggles: For many operations such as handling corrosives,

etc., safety spectacles are not adequate; and splash goggles or face shields are needed. The need for such goggles will generally be identified by the host company and provided by them. Splash goggles shall be worn to protect against eye exposure to chemicals by splash, spray, mist, or dust.

Chippers Goggles: shall be worn to protect against eye

exposure to falling or flying particles or chips.

A Welders Shield: shall be worn when performing or witnessing arc welding operations to protect both the face and eyes. Welders‘ goggles shall be worn for eye protection in gas welding and cutting operation, guarding against injurious ultraviolet and infrared radiation, and intense glare, as well as sparks or hot metal fragments. Darker shade lenses are required to protect the more intense glare of arc welding. Specialized lenses also are required in goggles for aluminum welding, brazing, glassblowing, and operations using sodium fluxes. See your supervisor for the proper protection

Removal of Acid Goggles (Splash goggles): If acid

goggles are sprayed with acid or caustic, you must get under a shower as soon as possible. If necessary to remove the goggles to be able to see the way to the shower, special care must be taken to keep acid or caustic out of the eyes. The following procedure must be followed:

Bend over until looking directly at the ground.

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Pull goggles down and away from the face by stretching the headbands and then slipping them over the top of the head.

Place a hand across the forehead and then straighten up and proceed to the shower. Goggles should not be removed before getting under the shower unless your vision is obstructed by the splashed material.

Face Shield: A face shield worn over safety spectacles not

only provides eye protection similar to goggles but also offers frontal and side protection of face and neck from splashing and flying fragments.

Respiratory System: Becht Engineering employees typically are not required to use respiratory equipment, but in emergencies, or when feasible engineering or administrative controls are not effective in controlling toxic substances, appropriate respiratory protective equipment shall be provided by Becht and the client’s respiratory program will be adopted. If the client‘s program is non-existent or inadequate employees shall use Becht‘s Respiratory Program in Tab L.

4 TRAINING

PPE Training is conducted at the division level. Each employee who is required to use PPE will be trained in the following:

Why PPE is necessary When PPE is necessary What PPE is necessary and any alternative choices of

equipment How to properly don, doff, adjust, and wear PPE The proper care, maintenance, storage, useful life, and disposal

of PPE The training will include an opportunity for employees to handle

the PPE and demonstrate that they understand the training and have the ability to use the PPE properly. The training will be provided by the manager or supervisor of the affected employees. The training will be documented in writing with the

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documentation including the names of each employee trained, the date(s) of the training, and the subject matter covered.

If an employee who has been trained demonstrates a lack of knowledge or behavior which leads the supervisor to believe the employee does not have a proper understanding of the PPE involved, that employee will be retrained. If there are changes in the workplace or processes that change the exposures or type of PPE to be used, all affected employees will be retrained.

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PROCESS SAFETY MANAGEMENT OF HIGHLY HAZARDOUS CHEMICALS

1 PURPOSE AND SCOPE

Purpose

This procedure provides mandatory guidelines to protect the safety and health of all employees on Becht assignments where the potential exposure to highly hazardous chemicals exists and where the release of such chemicals would result in toxic, fire, or explosion hazards.

Scope

This procedure applies to all Becht employees who provide services to facilities, which involve the following processes:

A chemical at or above the specified threshold quantities as listed in (29 CFR 1926.64 App A) (Note: The presence of a threshold quantity of a highly hazardous chemical in a process is to be at one point in time, not aggregate over a period of time.)

A process that involves a flammable liquid or gas on site, in one location, in a quantity of 10,000 lb (4535.9 kg) or more, except for:

Hydrocarbon fuels that are used solely for work place consumption as a fuel (e.g., propane used for comfort heating or gasoline for vehicle refueling), if such fuels are not a part of a process containing another highly hazardous chemical covered by this procedure.

Flammable liquids that are stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit of chilling or refrigeration.

This procedure does not apply to retail facilities, oil and gas well drilling or servicing operations, or normally unoccupied remote facilities.

2 GENERAL

Unexpected release of toxic, reactive, or flammable liquids and gases in processes that involve highly hazardous chemicals, which may be toxic, reactive, flammable, explosive, or may exhibit a combination of these properties. Regardless of the industry that uses these highly hazardous chemicals, there is a potential for an

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accidental release when they are not properly controlled. This, in turn, creates the possibility of disaster.

On February 24, 1992, the Occupational Safety and Health Administration (OSHA) published the Process Safety Management of Highly Hazardous Chemicals Standard. This law became fully effective on May 26, 1992. The purpose of this regulation is to establish procedures for process safety management that will protect employees by preventing or minimizing the consequences of chemical accidents that involve highly hazardous chemicals.

The original thrust of the regulation was aimed at chemical manufacturing. However, the scope was expanded beyond chemical manufacturing because potentially hazardous chemical releases are not limited to chemical manufacturing and similar precautions should be implemented in operations in which hazardous chemicals are used, mixed, stored, or otherwise handled.

Definitions

Atmospheric Tank - A storage tank, which has been designed to operate at, pressures from atmospheric through 0.5 psig. (Pounds per square inch gauge, 3.45 Kpa).

Boiling Point - The boiling point of a liquid at a pressure of 14.7 psia. (Pounds per square inch absolute, 760 mm).

Catastrophic Release - A major uncontrolled emission, fire, or explosion, involving one or more highly hazardous chemical that presents serious danger to employees in the work place.

Facility - The buildings, containers, or equipment that contains a process.

Highly Hazardous Chemical - substances that possesses toxic, reactive, flammable, or explosive properties and is present in quantities specified in the scope.

Hot Work - Work involving electric or gas welding, cutting, brazing, or similar flame or spark-producing operations.

Flammable Gas - A gas that, at ambient temperature and pressure, forms a flammable mixture with air at a concentration of 13 percent by volume or less; or a gas that, at ambient temperature and pressure, forms a range of flammable mixtures with air wider than 12 percent by volume, regardless of the lower limit.

Flammable Liquid - except any mixture having components with a flash point of 100°F (37.8°C) or higher, the total of which make up 99 percent or more of the total volume of the mixture.

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Normally Unoccupied Remote Facility - A facility which is operated, maintained, or serviced by employees who visit the facility only periodically to check its operation and to perform necessary operating or maintenance tasks. No employees are permanently stationed at the facility. Facilities meeting this definition are not contiguous with, and must be geographically remote from, all other buildings, processes, or persons.

Process - Any activity involving a highly hazardous chemical, including any use, storage, manufacturing, handling, or onsite movement of such chemicals or a combination of these activities. For the purpose of this definition, any group of vessels which are interconnected and separate vessels which are located such that a highly hazardous chemical could be involved in a potential release shall be considered a single process.

Responsibilities

The Becht Division Safety Officers’ are responsible for implementing and enforcing this procedure.

The Becht Company Safety Manager or designee is responsible for monitoring compliance with this procedure.

3 PROCEDURE

OCEDURE

The OSHA Process Safety Management standard clarifies the responsibilities of facility owners/operators and contractors involved in work that affects or takes place near covered processes to ensure that the safety of both plant and contractor employees is considered. The standard also mandates written operating procedures; employee training; pre-startup reviews; evaluation of mechanical integrity of critical equipment; and written procedures for managing change. Process Safety Management specifies a permit system for hot work; investigation of incidents involving releases or near misses of covered chemicals; emergency action plans; compliance audits at least every three years; and trade secret protection.

The key provision of Process Safety Management is process hazard analysis—a careful review of what could go wrong and what safeguards must be implemented to prevent releases of hazardous chemicals.

Process Safety Information

Facility owners/operators shall complete a compilation of written process safety information before conducting any process hazard analysis required

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by the OSHA standard. The compilation of written process safety information, completed under the same schedule required for process hazard analysis, will enable the facility owner/operator and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals.

The process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.

Information on the hazards of the highly hazardous chemicals in the process shall consist of at least the following:

Toxicity

Permissible exposure limits

Physical data

Reactivity data

Corrosivity data

Thermal and chemical stability data and hazardous effects of inadvertent mixing of different materials

Information on the technology of the process shall include at least the following:

A block flow diagram or simplified process flow diagram

Process chemistry

Maximum intended inventory

Safe upper and lower limits for such items as temperatures, pressures, flows, or compositions

An evaluation of the consequences of deviations including those affecting the safety and health of employees.

Where the original technical information no longer exists such information may be developed in conjunction with the process hazard analysis in sufficient detail to support the analysis.

Information on the equipment in the process shall include the following:

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Materials of construction

Piping and instrument diagrams (P&IDs)

Electrical classification

Relief system design and design basis

Ventilation system design

Design codes and standards employed

Material and energy balances for processes built after May 26, 1992

Safety systems (e.g., interlocks, detection or suppression systems)

The facility owner/operator shall document that equipment complies with recognized and generally accepted good engineering practices. For existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, the employer shall determine and document that the equipment is designed, maintained, inspected, tested, and operated in a safe manner.

Process Hazard Analysis

The facility owner/operator shall perform an initial process hazard analysis (hazard evaluation) on processes covered by the OSHA standard. The process hazard analysis methodology selected must be appropriate to the complexity of the process and must identify, evaluate, and control the hazards involved in the process.

The facility owner/operator shall determine and document the priority order for conducting process hazard analysis based on a rationale that includes such considerations as the extent of the process hazards, the number of potentially affected employees, the age of the process, and the operating history of the process.

The process hazard analysis shall be conducted as soon as possible, but not later than the following schedule:

No less than 25 percent of the initial process hazards analyses shall be completed by May 26, 1994.



All initial process hazards analyses shall be completed by May 26, 1997.

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Process hazards analyses completed after May 26, 1987, which meet the requirements of the OSHA process safety management standard, are acceptable as initial process hazards analyses. All process hazards analyses shall be updated and revalidated based on their completion date, at least every 5 years.

The facility owner/operator shall use one or more of the following methodologies that are appropriate to determine and evaluate the hazards of the process being analyzed:

What-If

Checklist

What-If/Checklist

Hazard and Operability Study (HAZOP)

Failure Mode and Effects Analysis (FMEA)

Fault Tree Analysis

An Appropriate Equivalent Methodology

The process hazard analysis shall address the following:

The hazards of the process.

The identification of any previous incident that had a potential for catastrophic consequences in the work place.

Engineering and administrative controls applicable to the hazards and their interrelationships, such as appropriate application of detection methodologies to provide early warning of releases. Acceptable detection methods might include process monitoring and control instrumentation with alarms and detection hardware such as hydrocarbon sensors.

Consequences of failure of engineering and administrative controls.

Facility siting.

Human factors.

A qualitative evaluation of a range of the possible safety and health effects on employees in the work place if there is a failure of controls.

The process hazard analysis shall be performed by a team with expertise in

engineering and process operations, and the team shall include at least one employee who has experience and knowledge in the specific process hazard analysis methodology being used.

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The facility owner/operator shall establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance, and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.

At least every 5 years after the completion of the initial process hazard analysis, the process hazard analysis shall be updated and revalidated by a team meeting the OSHA standard's requirements to ensure that the hazard analysis is consistent with the current process.

Facility owners/operators shall keep on file and make available to OSHA, on request, process hazard analyses and updates or revalidation for each process covered by the process safety management, as well as the documented resolution of recommendations, for the life of the process.

Operating Procedures

The facility owner/operator shall develop and implement written operating procedures, consistent with the process safety information, that provide clear instructions for safely conducting activities involved in each covered process. The operating procedures must address at least the following elements:

Steps for each operating phase:

a.) Initial startup b.) Normal operations c.) Temporary operations d.) Emergency shutdown, including the conditions under

which emergency shutdowns are required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner

e.) Emergency operations f.) Normal shutdown g.) Startup following a turnaround or after an emergency

shutdown

Operating limits:

a.) Consequences of deviation b.) Steps required to correct or avoid deviation

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Safety and health considerations:

a.) Properties of, and hazards presented by, the chemicals used in the process

b.) Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment

c.) Control measures to be taken if physical contact or airborne exposure occurs

d.) Quality control for raw materials and control of hazardous chemical inventory levels

e.) Safety systems (e.g., interlocks, detection or suppression systems) and their functions

Operating procedures shall be readily accessible to employees who work in

or maintain a process.

The operating procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The facility owner/operator shall certify annually that these operating procedures are current and accurate.

The facility owner/operator shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. The safe work practices shall apply to facility employees and contractors' employees.

Contractors

Application

This procedure applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process.

This procedure does not apply to contractors providing incidental services which do not influence process safety, such as janitorial work, food and drink services, laundry, delivery, or other supply services.

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Facility Owner/Operator Responsibilities

The facility owner/operator, when selecting a contractor, shall obtain and evaluate information regarding the contractor's safety performance and programs.

The facility owner/operator shall inform contractors of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process.

The facility owner/operator shall explain to contractors the applicable provisions of the emergency action plan required by this procedure.

The facility owner/operator shall develop and implement safe work practices to control the entrance, presence, and exit of contractors and contractors' employees in covered process areas.

The facility owner/operator shall periodically evaluate the performance of contractors in fulfilling their obligations and responsibilities.

The facility owner/operator shall maintain a contractor employee injury and illness log related to the contractor's work in process areas.

Contractor Responsibility

Becht shall assure that each employee is trained in the work practices necessary to safely perform his/her job.

Becht shall assure that each employee is instructed in the known potential fire, explosion, or toxic release hazards related to his/her job and the process, and the applicable provision of the facility's emergency action plan.

Becht shall document that each employee has received and understood the required training. Becht must prepare a record which contains the identity of each employee, the date of training, and the means used to verify that the employee understood the training.

Becht shall assure that each employee follows the safety rules of the facility, including the safe work practices.

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Becht shall advise the facility owner/operator of any unique hazards presented by Becht‘s work or of any hazards found by Becht employees.

Pre-Startup Safety Reviews

The facility owner/operator shall perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information.

Prior to the introduction of a highly hazardous chemical to a process, the pre-startup safety review must confirm the following:

Construction and equipment are in accordance with design specifications.

Safety, operating, maintenance, and emergency procedures are in place and are adequate.

A process hazard analysis has been performed for new facilities and recommendations have been resolve or implemented before startup, and modified facilities meet the management of change requirements.

Training of each employee involved in operating a process has been completed.

Mechanical Integrity

The process safety management mechanical integrity requirements apply to the following equipment:

Pressure vessels and storage tanks

Piping systems (including piping components such as valves)

Relief and vent systems and devices

Emergency shutdown systems

Controls (including monitoring devices, sensors, alarms, and interlocks)

Pumps

The facility owner/operator shall establish and implement written procedures to maintain the ongoing integrity of process equipment.

The facility owner/operator must train each employee involved in maintaining the ongoing integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee's job task to assure that the employee can perform the job tasks in a safe manner.

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Inspection and testing shall be performed on process equipment, using procedures that follow recognized and generally accepted good engineering practices. The frequency of inspections and tests of process equipment shall conform with manufacturers' recommendations and good engineering practices, or more frequently if determined to be necessary by prior operating experience. Each inspection and test on process equipment shall be documented, identifying the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.

The facility owner/operator shall correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information) before further use or in a safe and timely manner when necessary means are taken to assure safe operation.

In constructing new plants and equipment, the facility owner/operator shall ensure that equipment, as it is fabricated, is suitable for the process application for which it will be used. Appropriate checks and inspections must be performed to ensure that equipment is installed properly and is consistent with design specifications and the manufacturer's instructions.

The facility owner/operator shall also ensure that maintenance materials, spare parts, and equipment are suitable for the process application for which they will be used.

Hot Work Permits

The facility owner/operator must issue a hot work permit for hot work operations conducted on or near a covered process.

The permit shall document that the fire prevention and protection requirements in 29 CFR 1910.252 (a) have been implemented prior to beginning the hot work operations; it shall indicate the date(s) authorized for hot work; and it shall identify the object on which hot work is to be performed. The permit shall be kept on file until completion of the hot work.

Management of Change

The facility owner/operator shall develop and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures and change to facilities that affect a covered process. The written procedures must ensure that the following considerations are addressed prior to any change:

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The technical basis for the proposed change

Impact of the change on employee safety and health

Modification to operating procedures

Necessary time period for the change

Authorization requirements for the proposed change

Facility employees involved in operating a process and maintenance and contractors' employees whose job task will be affected by a change in the process shall be informed of, and trained in, the change prior to startup of the process or affected part of the process.

If a change occurs that affects the process safety information and/or the operating procedures, such information shall be updated accordingly.

Incident Investigation

The facility owner/operator shall investigate each incident which results in, or could reasonably have resulted in, a catastrophic release of highly hazardous chemical in the work place.

The incident investigation shall be initiated as promptly as possible, but not later than 48 hours following an incident.

An incident investigation team shall be established and consist of at least one person knowledgeable in the process involved, including a contractor's employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident.

A report shall be prepared at the conclusion of the investigation which includes, at a minimum:

Date of incident

Date investigation began

Description of the incident

Factors that contributed to the incident

Recommendations resulting from the investigation

The facility owner/operator shall establish a system to promptly address and resolve the incident report findings and recommendations. Resolutions and corrective actions shall be documented.

The report shall be reviewed with all affected personnel, whose job tasks are relevant to the incident findings, including contractors' employees where applicable.

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Incident investigation reports shall be retained for five years.

Emergency Planning and Response

The facility owner/operator shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38 (a). In addition, the emergency action plan must include procedures for handling small releases.

Facility owner/operators covered under process safety management may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR 1910.120 (a), (p) and (q).

Compliance Audits

To be certain process safety management is effective, facility owners/operators shall certify that they have evaluated compliance with the provisions of the OSHA standard at least every 3 years. This will verify that the procedures and practices developed are adequate and are being followed.

The compliance audit shall be conducted by at least one person knowledgeable in the process.

A report of the findings of the audit shall be developed and documented, noting deficiencies that have been corrected.

The two most recent compliance audit reports must be kept on file.

Trade Secrets

Facility owners/operators shall make available all information necessary to comply with process safety management to those responsible for compiling the process safety information, those developing the process hazard analysis, those responsible for developing the operating procedures, and those performing incident investigations, emergency planning and response, and compliance audits, without regard to the possible trade secret status of such information.

Nothing in the OSHA standard, however, precludes the facility owner/operator from requiring those persons to enter into confidentiality agreements not to disclose the information.

Subject to the rules and procedures set forth in 29 CFR 1910.1200(i)(1) through 1910.1200(I)- (12), employees and their designated representatives shall have access to trade secret information contained within the process hazard analysis and other documents required to be developed by process safety management.

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4 TRAINING

Initial Training

Each facility employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures as specified in Section 5.3 of this procedure. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job task.

In lieu of initial training for those facility employees already involved in operating a process on May 26, 1992, the facility owner/operator may certify, in writing, that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as specified in the operating procedures.

Refresher Training

Refresher training shall be provided at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process.

The facility owner/operator, in consultation with the employees involved in operating the process, shall determine the appropriate frequency of refresher training.

Training Documentation

The facility owner/operator shall ascertain that each employee involved in operating a process has received and understood the training required by the OSHA standard.

The facility owner/operator shall prepare a record which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.

5 REFERENCES


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OSHA Instruction CPL 2-2.45A, September 28, 1992, Process Safety Management of Highly Hazardous Chemicals, Compliance Guidelines and Enforcement Procedures.

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RESPIRATORY PROTECTION PROGRAM

1 PURPOSE AND SCOPE

Purpose

This procedure outlines the requirements for appropriate selection and use of respiratory protection equipment in emergencies or when it is not feasible to implement engineering controls to adequately prevent harmful exposure to employees who are working in areas that require respiratory protection.

Scope

This procedure applies to all Becht employees and subcontractors working on field projects or in offices where respiratory protection is required.

2 GENERAL

In the control of those occupational diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors, the primary objective shall be to prevent atmospheric contamination. This shall be accomplished as far as feasible by accepted engineering control measures (for example, enclosure or confinement of the operation, general or local ventilation, and substitution of less toxic materials). When effective engineering controls are not feasible, or while they are being instituted, appropriate respirators shall be used pursuant to this procedure. Respirators shall be provided when such equipment is necessary to protect the health of the employee. Respirators, which are applicable and suitable for the purpose intended, shall be provided. Becht shall be responsible for the establishment and maintenance of a respiratory protection program that includes the requirements of this procedure. Each field site and office facility shall ensure that employees are provided a safe and healthful working atmosphere, free of hazards that could adversely affect their personal health and safety. It is the policy of Becht to use the most up-to-date and efficient respiratory protective equipment available and the most effective work methods to eliminate or minimize atmospheric hazards. The latter shall be accomplished by accepted engineering control measures. When effective engineering controls are not feasible, appropriate respirators shall be used according to this procedure.

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Definitions

Air Purifying Respirator (APR) - A respirator with an air-purifying filter, cartridge, or canister that removes specific air contaminants by passing ambient air through the air-purifying element.

Atmosphere Supplying Respirator - A respirator which provides a clean breathable atmosphere that is independent of the surrounding environment. They are designed for use in uncharacterized environments or where contaminant concentrations are too high for APRs. This classification includes supplied-air respirators (SARs) and self-contained breathing apparatus (SCBA) units.

Canister or Cartridge - A container with a filter, sorbent, or catalyst, or combination of these items, which removes specific contaminants from the air, passed through the container.

Demand Respirator - An atmosphere-supplying respirator that admits breathing air to the facepiece only when a negative pressure is created inside the face piece by inhalation.

Emergency Situation - Any occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment that may, or does result in an uncontrolled release of an airborne contaminant.

Employee Exposure - Exposure to a concentration of an airborne contaminant that would occur if the employee were not using respiratory protection.

End-of-Service-Life-Indicator (ESLI) - A system that warns the respirator user of the approach to the end of adequate protection. The sorbent is approaching saturation, or is no longer effective.

Escape-only Respirator - A respirator intended to be used only for emergency exit.

Filter of Air Purifying Element - A component used in respirators to remove solid or liquid aerosols from the inspired air.

Filtering Facepiece (Dust Mask) - A negative pressure particulate respirator with a filter as an integral part of the facepiece or with the entire facepiece composed of the filtering medium.

Fit Factor - A quantitative estimate of the fit of a particular respirator to a specific individual, and typically estimates the ratio of the

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concentration of a substance in ambient air to its concentration inside the respirator when worn.

Fit-Test - The use of a protocol to qualitatively or quantitatively evaluate the fit of a respirator on an individual.

High Efficiency Particulate Air Filter (HEPA) - A filter that is at least 99.97% efficient in removing monodisperse particles of 0.3 micrometers in diameter.

Helmet - a rigid respirator inlet covering that also provides head protection against impact and penetration.

Hood - A respiratory inlet covering that completely covers the head and neck and may also cover portions of the shoulders and torso.

Immediately dangerous to life and health (IDLH) - An atmosphere that poses an immediate threat to life, would cause irreversible adverse health effects, or would impair an individual's ability to escape from a dangerous atmosphere.

Loose-Fitting Facepiece - A respiratory inlet covering that is designed to form a partial seal with the face.

Negative Pressure Respirator (tight fitting) - A respirator in which the air pressure inside the facepiece is negative during inhalation with respect to the ambient air pressure outside the respirator.

Oxygen Deficient Atmosphere - Atmosphere with an oxygen content that is below 19.5 % by volume.

Physician or Licensed Health Care Professional (PLHCP) - An individual whose legally permitted scope of practice (i.e. license, registration, or certification) allows him/her to independently provide, or be delegated the responsibility to provide, some or all of the health care services required in this procedure.

Positive Pressure Respirator - A respirator in which the pressure inside the respiratory inlet covering exceeds the ambient air pressure outside the respirator.

Powered Air-Purifying Respirator (PAPR) - An air-purifying respirator that uses a blower to force the ambient air through air-purifying elements to the inlet covering.

Pressure Demand Respirator - A positive pressure atmosphere-supplying respirator that admits breathing air to the facepiece when the positive pressure is reduced inside the facepiece by inhalation.

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Qualitative Fit Test (QLFT) - A pass/fail test to assess the adequacy of respirator fit that relies on the individual‘s response to the test agent.

Quantitative Fit Test (QNFT) - An assessment of the adequacy of respirator fit by numerically measuring the amount of leakage into the respirator.

Respiratory Inlet Covering - That portion of a respirator that forms the protective barrier between the user‘s respiratory tract and an air-purifying device or breathing air source, or both. It may be a facepiece, helmet, hood, suit, or a mouthpiece respirator with nose clamp.

Self-Contained Breathing Apparatus - An atmosphere-supplying respirator for which the breathing air source is designed to be carried by the user.

Service Life - The period of time for which a respirator, filter or sorbent, or other respiratory equipment provide adequate protection to the wearer.

Supplied-air Respirator (SAR) or Airline Respirator - An atmosphere-supplying respirator for which the source of breathing air is not designed to be carried by the user.

Tight-Fitting Facepiece - A respiratory inlet covering that forms a complete seal with the face.

User Seal Check - An action conducted by the respirator user to determine if the respirator is properly seated to the face.

Responsibilities

The Manager/Supervisor is responsible for implementing and enforcing this procedure and the site respiratory protection program.

The Safety Representative is responsible for monitoring compliance with this procedure. The Safety Representative shall act as the Respiratory Protection Program Administrator and must be knowledgeable of the complexity of the program, conduct evaluations, and be properly trained.

The Employee, whose tasks require the use of respiratory equipment, is responsible to use the appropriate type of respiratory equipment.

The Subcontractor is responsible for providing Becht a written respiratory protection program which, at a minimum, shall meet the

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requirements of the Becht program. The subcontractor shall also provide evidence of current respiratory training, medical evaluation, and qualitative or quantitative fit testing for those employees required to use respiratory equipment

3 PROCEDURE

Respiratory Protection Program

In any workplace where respirators are necessary to protect the health of the employee, the clients written respiratory protection program shall be adopted. The following element shall be included in the written program:

Procedures for selecting respirators for use in the workplace.

Medical evaluations of employees required to use respirators.

Fit testing procedures for tight-fitting respirators.

Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations.

Procedures and schedules for cleaning, disinfecting, storing, inspection, repairing, discarding, and otherwise maintaining respirators.

Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators.

Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations.

Training of employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance.

Procedures for regularly evaluating the effectiveness of the program.

The voluntary use of respiratory equipment where not required is prohibited without written authorization from Becht‘s Company Safety Manager.

The use of employee owned respirators is prohibited.

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The use of dust mask is prohibited without written authorization from Becht‘s Company Safety Manager.

Becht shall designate a program administrator, at both the corporate and site level, who is qualified by appropriate training or experience to oversee the respiratory protection program and conduct the required evaluations of program effectiveness.

All required training and medical evaluation shall be provided at no cost to the employee.

Selection of Respirators

Selection of appropriate respirators shall be based on the respiratory hazard(s) to which the employee is exposed and workplace and user factors that affect respirator performance and reliability.

A NIOSH-certified respirator must be selected. The respirator shall be used in compliance with the conditions of its certification.

Respirators shall be selected from a sufficient number of respirator models and sizes so that the respirator is acceptable to and correctly fits the user.

Respirator hazard(s) in the work area shall be identified and evaluated. This evaluation shall include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant‘s chemical state and physical form. Where the employee exposure cannot be identified or reasonably estimated, the atmosphere shall be considered IDLH.

The following respirators shall be provided for employee use in IDLH atmospheres:

Certified by NIOSH for a minimum service life of thirty minutes, or

A combination full facepiece pressure demand supplied-air respirator (SAR) with auxiliary self-contained air supply.

Respirators provided only for escape from IDLH atmospheres shall be NIOSH-certified for escape from the atmosphere in which they will be used.

All oxygen-deficient atmospheres shall be considered IDLH.

For atmospheres that are not IDLH, a respirator shall be provided that is adequate to protect the health of the employee and ensure compliance

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with all other statutory and regulatory requirements, under routine and reasonably foreseeable emergency situations.

The respirator selected shall be appropriate for the chemical state and physical form of the contaminant.

For protection against gases and vapors,

An atmosphere-supplying respirator, or

An air-purifying respirator shall be provided.

a.) If an air-purifying respirators is used it should be equipped with an end-of-service-life indicator (ESLI) certified by NIOSH for the contaminant.

b.) If there is no ESLI appropriate for conditions in the workplace, a change schedule for canisters and cartridges shall be implemented that is based on objective information or data that will ensure that canisters and cartridges are changed before the end of their service life. The workplace respirator program shall describe the information and data relied upon and the basis for the canister and cartridge change schedule and the basis for reliance on the data.

For protection against particulates, the following shall be provided:

An atmosphere-supplying respirator; or

An air-purifying respirator equipped with a filter certified by NIOSH as a high efficiency particulate air (HEPA) filter, or an air-purifying respirator equipped with a filter certified for particulates by NIOSH; or

For contaminants consisting primarily of particles with mass median aerodynamic diameters (MMAD) of at least 2 micrometers, an air-purifying respirator equipped with any filter certified for particulates by NIOSH.

Medical Evaluation

Medical evaluations associated with the use of respiratory protection equipment shall be coordinate and/or performed by Becht‘s Company Safety Manager. The need for such medical evaluations must be coordinated through Becht‘s Company Safety Manager.

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A medical evaluation, to determine the employee‘s ability to use a respirator before the employee is fit tested or required to use the respirator in the workplace, shall be provided.

A physician or other licensed health care professional (PLHCP) shall be identified to perform medical evaluations using a medical questionnaire or an initial medical examination that obtains the same information as the medical questionnaire. SEE 29 CFR 1910.134 Appendix 3

The medical questionnaire and evaluation shall be administered confidentially during the employee‘s normal working hours or at a time and place convenient to the employee. The medical questionnaire shall be administered in a manner that ensures the employee understands the content.

The employee shall be given the opportunity to discuss the medical questionnaire and evaluation results with the PLHCP.

The following information must be provided to the PLHCP before the PLHCP makes a recommendation concerning an employee‘s ability to use a respirator:

The type and weight of the respirator to be used by the employee;

The duration and frequency of respirator use (including use for rescue and escape);

The expected physical work effort;

Additional protective clothing and equipment to be worn; and

Temperature and humidity extremes that may be encountered.

A copy of the workplace written respiratory program and a copy of the respiratory standard shall be provided to the PLHCP.

A written recommendation regarding the employee‘s ability to use the respirator shall be obtained from the PLHCP. The recommendation shall provide only the following information:

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Any limitations on respirator use related to the medical condition of the employee, or relating to the workplace conditions in which the respirator will be used, including whether or not the employee is medically able to use he respirator;

The need, if any, for follow-up medical evaluations; and

A statement that the PLHCP has provided the employee with a copy of the PLHCP‘s written recommendation.

If the respirator is a negative pressure respirator and the PLHCP finds a medical condition that may place the employee‘s health at increased risk if the respirator is used, a PAPR shall be provided if the PLHCP‘s medical evaluation finds that the employee can use such a respirator. If a subsequent medical evaluation finds the employee is medically able to use a negative pressure respirator, then there is no longer a requirement d to provide a PAPR.

Additional medical evaluations shall be provided whenever there is any indication that a reevaluation is appropriate. At a minimum, this would occur:

If an employee reports any signs or symptoms that are related to the ability to use a respirator;

If the PLHCP, program administrator, or supervisor determines that a reevaluation is necessary;

If information from the respiratory protection program indicates a need for reevaluation; or

If a change in workplace conditions could affect the physiological burden placed on the employee.

Fit Testing

Before an employee is required to use any respirator with a negative or positive pressure tight-fitting facepiece, the employee must be fit tested with the same make, model, style and size of respirator that will be used.

If an employee is allowed to voluntarily use a respirator, it is Becht‘s policy that a fit test shall be conducted.

All employees who are required to use a tight-fitting respirator must pass an appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT).

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QLFT may only be used to fit test negative pressure air-purifying respirators that must achieve a fit factor of 100 or less.

QLFT involves the introduction of a gas, vapor, or aerosol test agent into an area around the health of the respirator user. If the respirator user can detect the presence of the test agent through subjective means, such as odor, taste, or irritation, the respirator fit is inadequate.

In a QNFT, the adequacy of respirator fit is assessed by measuring the amount of leakage into the respirator, either by generating a test aerosol as test atmosphere, using ambient aerosol as the test agent, or using controlled negative pressure to measure the volumetric leak rate. Appropriate instrumentation is required to quantify respirator fit in QNFT.

Appropriate fit tests shall be performed as follows:

Prior to initial use of the respirator;

Whenever a different respirator facepiece (size, style, model or make) is used;

Whenever an employee reports physical condition changes that could affect respirator fit;

Whenever the employee is observed to have undergone physical changes that could affect respirator fit; and

At least annually.

RESPIRATOR USE

Procedures for the proper use of respirators shall be established and implemented. Such procedures must include:

Prohibiting conditions that may result in facepiece seal leakage;

Actions to ensure continued effective respirator operation;

Preventing employees from removing respirators in hazardous environments; and

Use of respirators in IDLH atmospheres.

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Respirators with tight-fitting facepieces shall not be worn by employees who have:

Facial hair that comes between the sealing surface of the facepiece and the face, or that interferes with value function; or

Any condition that interferes with the face-to-facepiece seal or with value function.

If an employee wears corrective glasses or goggles or other personal protective, it must be ensured that the equipment is worn in a manner that does not interfere with the seal of the facepiece to the face of the user.

A user seal check must be performed each time an employee puts on a tight-fitting respirator.

Appropriate awareness of workplace conditions and degree of employee exposure or stress must be maintained. When there is a change in work conditions or degree of employee exposure or stress that may affect respirator effectiveness, a reevaluation of the respirator‘s continued effectiveness must be performed.

If an employee detects vapor or gas breakthrough, changes in breathing resistance, or leakage of the facepiece, the respirator that is not functioning properly must be replaced, repaired, or discarded before the employee can return to the work area.

Employees must leave the respirator use area under the following conditions:

To wash their faces and respirator facepieces as necessary to prevent eye or skin irritation, and to reduce the amount of contamination;

If they detect vapor or gas breakthrough, changes in breathing resistance, or leakage of the facepiece; or

To replace the respirator or the filter, cartridge, or canister elements.

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When employees are working in IDLH atmospheres, you must ensure:

Employee(s) located outside the IDLH atmosphere is trained and equipped to provide effective emergency rescue;

One employee or, when needed, more than one employee is located outside the IDLH atmosphere;

Visual, voice, or signal line communication is maintained between the employee(s) in the IDLH atmosphere and the employee(s) located outside the IDLH atmosphere;

Employee(s) located outside the IDLH atmosphere make appropriate notification prior to entering the IDLH atmosphere to provide emergency rescue;

Authorized personnel provide assistance necessary to an emergency situation; and

Employee(s) located outside the IDLH atmospheres are equipped with pressure demand or other positive pressure SCBAs or a pressure demand or other positive pressure supplied-air respirator with auxiliary SCBA. Also required is either appropriate retrieval equipment for removing the employee(s) who enters these hazardous atmospheres where retrieval equipment would contribute to the rescue and would not increase the overall risk resulting from entry or equivalent means for rescue where retrieval equipment is not required.

Respirator Maintenance and Care

Each respirator wearer must be provided with a respirator that is clean, sanitary, and in good working order.

Respirators are required to be provided in a clean and sanitary manner using procedures in OSHA 1910.134 Appendix 2 or equally effective manufacturer's procedures.

Respirators issued for the exclusive use of an employee shall be cleaned and disinfected as often as necessary to be maintained in a sanitary condition.

Respirators issued to more than one employee shall be cleaned and disinfected after each use.

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Respirators maintained for emergency use shall be cleaned and disinfected after each use.

Respirators used in fit testing and training shall be cleaned and disinfected after each use.

All respirators must be stored so they are protected from damage, contamination, harmful environmental conditions and damaging chemicals, and deformation of the facepiece and exhalation valve.

In addition to the above storage requirements, emergency use respirators must be:

Kept accessible to the work area;

Stored in compartments or covers that are clearly marked as containing emergency respirators; and

Stored in accordance with any applicable manufacturer‘s instructions.

Regular inspections to ensure the continued reliability of respiratory equipment must be made. The frequency of inspection and procedures to be followed depend on whether the respirator is intended for non-emergency, emergency, or escape-only use.

Respirators for use in non-emergency situations must be inspected before each use and during cleaning.

Respirators designated for use in emergency situations must be inspected at least monthly and in accordance with the manufacturer‘s instructions. In addition, emergency respirators must be examined to ensure that they are working properly before and after each use. The inspection must be certified including the date of inspection, the name or signature of the inspector, the findings of the inspection, any required remedial action, and a serial number of other means of identifying the inspected respirator. This information must be tagged to the respirator or its storage compartment, or otherwise stored in the form of inspection reports and be maintained until replaced following a subsequent certification.

Emergency escape-only respirators shall be inspected before being carried into the workplace for use.

The inspection will include a check of the respirator function, tightness of connections, and the condition of the various parts including but not limited to, the facepiece, head straps, valves, connecting tube, and

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cartridges, canister or filters; and a check of the elastomeric parts for pliability and signs of deterioration.

SCBAs must be inspected monthly. Cylinders shall be maintained in a fully charged state and shall be recharged when the pressure falls below 90% of the manufacturer‘s recommended pressure level.

Respirators that fail inspection, or are otherwise defective, are to be removed from service and discarded, repaired, or adjusted according to the following specified procedures:

Repairs or adjustments to respirators are to be made only by persons appropriately trained to perform such operations and shall use only the respirator manufacturer‘s NIOSH-approved parts designed for the respirator;

Repairs shall be made according to the manufacturer‘s recommendations and specifications for the type and extent of repairs to e performed; and

Reducing and admission valves, regulators, and alarms shall be adjusted or repaired only by the manufacturer or a technician trained by the manufacturer.

Breathing air, quality and use

Breathing air for atmosphere-supplying respirators must be of high purity, meet quality levels for content, and not exceed certain contaminant levels and moisture requirements. Current regulations set performance standards for the operation and maintenance of breathing air compressors and cylinders, establishes methods for ensuring breathing air quality, and sets requirements for the quality of purchased breathing air.

Air must be Grade D or better. Oxygen is not used in compressed air units, cylinders shall meet DOT requirements, and Compressors shall be located in a "clean" atmosphere, with in-line purification and tagged to indicate date or change out. Carbon monoxide monitor shall be in place & set to alarm at 10 PPM or monitored frequently. Fittings are incompatible for non-respirable gases and containers.

Breathing air must be of Grade D and requires certification from supplier.

Identification of Filters, Cartridges, and Canisters

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All filters, cartridges, and canisters used in the workplace shall be labeled and color-coded with the NIOSH approval label. The label must remain legible and affixed to the cartridge, filter, or canister while in service.

4 TRAINING

Respirator Training

Effective training must be provided to all employees who are required to wear respirators. Employees must be trained sufficiently to:

Show a knowledge of why the respirator is necessary;

How improper fit, usage, or maintenance can compromise the protective effect of the respirator;

Know the limitations and capabilities of the selected respirator;

Deal with emergency situations involving the use of respirators or with respirator malfunction;

Inspect, don, remove, and check the respirator seal;

Understand procedures for respirator maintenance and storage;

Know the medical symptoms and signs that may limit or prevent the effective use of respirators; and

Understand the general requirements of the regulatory requirements.

Training must be understandable and be given to an employee prior to using a respirator, and annually thereafter. Additionally, if there is reason to believe that any employee who has already been trained does not have sufficient understanding and skill to use the respirator, the employee must be retrained in those areas in which his or her knowledge or skill is deficient. Retraining is also required when changes in the workplace or in the type of respirator used render previous training obsolete.

Program Evaluation

An evaluation of the workplace shall be conducted, as necessary, to ensure that the provisions of the current written respiratory program are being effectively implemented and that it continues to be effective.

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Employees, required to use respirators, shall be consulted regularly to assess their views on program effectiveness and to identify any problems that need correcting. Factors to be assessed include, but are not limited to:

Respirator fit;

Appropriate respirator selection for the hazards to which the employee is exposed;

Proper respirator use under the workplace conditions the employee encounters; and

Proper respirator maintenance.

Recordkeeping

Written information regarding medical evaluations, fit testing, and respirator program must be established and retained.

Medical evaluation record shall be retained for each employee subject to medical evaluation.

A record of the qualitative and quantitative fit tests administered to an employee shall be established and maintained. The record shall include:

The name or identification of the employee tested;

Type of fit test performed;

Specific make, model, style, and size of respirator tested;

Date of test; and

The pass/fail results for QLFT or the fit factor and strip chart recording or other recording of the test results for QNFTs.

Fit test records shall be retained for respirator users until the next fit test is administered.

A written copy of the current respirator program shall be retained at the workplace.

5 REFERENCES


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American National Standards Institute (ANSI) Z88.2-1992, Practices for Respiratory Protection.

American National Standards Institute (ANSI), Z88.6-1984, Physical Qualifications for Respirator Use.

American Conference of Governmental Industrial Hygienists, Threshold Limit Values and Biological Exposure Indices, Current Edition.

Compressed Gas Association, Commodity Specification G-7.1-1973.

Department of Health and Human Services, NIOSH Guide to Industrial Respiratory Protection, Publication Number 87-116.

6 APPENDIX

Appendix 1 – Respiratory Equipment Selection Chart

Appendix 2 - Medical Questionnaire

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Appendix 1 - Respiratory Equipment Selection Chart, p. 1

HAZARD ANALYSIS/RESPIRATORY EQUIPMENT SELECTION CHART

Hazard Respirator (see note) 1. Oxygen deficiency Self-contained breathing apparatus. Hose

mask with blower. Combination air-line respirator with auxiliary self-contained air supply or an air-storage receiver with alarm.

2.A Gas and vapor contaminants immediately dangerous to life and health



Air-line respirator. Air-purifying, half-mask or mouthpiece respirator with chemical cartridge.

3.A Particulate contaminants immediately dangerous to life and health

Self-contained breathing apparatus. Hose mask with blower. Self-rescue mouthpiece respirator (for escape only). Combination air-liner respirator with auxiliary self-contained air supply or an air-storage receiver with alarm.


Air-purifying, half-mask or mouthpiece respirator with filter pad or cartridge. Air-liner respirator with auxiliary self-contained air supply or an air-storage receiver with alarm.

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4.A Combination gas, vapor, and

particulate contaminants immediately dangerous to life and health



Air-line respirator. Air-purifying, half-mask or mouthpiece respirator with chemical cartridge and appropriate filter.

Note: For the purpose of this chart, ―immediately dangerous to life and health‖ is defined as a condition that poses either an immediate threat to life and health or an immediate threat of severe exposure to contaminants, such as radioactive materials and asbestos, which are likely to have an adverse delayed effect on health.

Appendix 1 - Respiratory Equipment Selection Chart, p. 2

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Appendix 2 – Respirator Medical Questionnaire, p. 1

To the employer:

Answers to questions in Section 1, and to question 9 in Section 2 of Part A, do not require a medical examination.

To the employee:

Can you read (circle one): Yes/No

Your employer must allow you to answer this questionnaire during normal working hours, or at a time and place that is convenient to you. To maintain your confidentiality, your employer or supervisor must not look at or review your answers, and your employer must tell you how to deliver or send this questionnaire to the health care professional who will review it.

Part A - Section 1. (Mandatory) The following information must be provided by every employee who has been selected to use any type of respirator (please print).

1. Today's date:________

2. Your name:__ ____

3. Your age (to nearest year):_________________________________________

4. Sex (circle one): Male/Female

5. Your height: __________ ft. __________ in.

6. Your weight: ____________ lbs.

7. Your job title:__________________ _________________________________

8. A phone number where you can be reached by the health care professional who reviews this questionnaire (include the Area Code): ___________________

9. The best time to phone you at this number: ________ ________

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10. Has your employer told you how to contact the health care professional who will review this questionnaire (circle one): Yes/No

11. Check the type of respirator you will use (you can check more than one category): a. ______ N, R, or P disposable respirator (filter-mask, non- cartridge type only). b.______Other type (for example, half- or full-facepiece type, powered-air purifying, supplied-air, self-contained breathing apparatus).

12. Have you worn a respirator (circle one): Yes/No

If "yes," what type(s):

Part A - Section 2. (Mandatory) Questions 1 through 9 below must be answered by every employee who has been selected to use any type of respirator (please circle "yes" or "no").

1. Do you currently smoke tobacco, or have you smoked tobacco in the last month: Yes/No

2. Have you ever had any of the following conditions?

a. Seizures (fits): Yes/No b. Diabetes (sugar disease): Yes/No c. Allergic reactions that interfere with your breathing: Yes/No d. Claustrophobia (fear of closed-in places): Yes/No e. Trouble smelling odors: Yes/No

3. Have you ever had any of the following pulmonary or lung problems?

a. Asbestosis: Yes/No b. Asthma: Yes/No c. Chronic bronchitis: Yes/No d. Emphysema: Yes/No e. Pneumonia: Yes/No f. Tuberculosis: Yes/No g. Silicosis: Yes/No h. Pneumothorax (collapsed lung): Yes/No i. Lung cancer: Yes/No

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j. Broken ribs: Yes/No k. Any chest injuries or surgeries: Yes/No l. Any other lung problem that you've been told about: Yes/No

4. Do you currently have any of the following symptoms of pulmonary or lung illness?

a. Shortness of breath: Yes/No b. Shortness of breath when walking fast on level ground or walking up a

slight hill or incline: Yes/No c. Shortness of breath when walking with other people at an ordinary pace

on level ground: Yes/No d. Have to stop for breath when walking at your own pace on level ground:

Yes/No e. Shortness of breath when washing or dressing yourself: Yes/No f. Shortness of breath that interferes with your job: Yes/No g. Coughing that produces phlegm (thick sputum): Yes/No h. Coughing that wakes you early in the morning: Yes/No i. Coughing that occurs mostly when you are lying down: Yes/No j. Coughing up blood in the last month: Yes/No k. Wheezing: Yes/No l. Wheezing that interferes with your job: Yes/No m. Chest pain when you breathe deeply: Yes/No n. Any other symptoms that you think may be related to lung problems:

Yes/No

5. Have you ever had any of the following cardiovascular or heart problems?

a. Heart attack: Yes/No b. Stroke: Yes/No c. Angina: Yes/No d. Heart failure: Yes/No e. Swelling in your legs or feet (not caused by walking): Yes/No f. Heart arrhythmia (heart beating irregularly): Yes/No g. High blood pressure: Yes/No h. Any other heart problem that you've been told about: Yes/No

6. Have you ever had any of the following cardiovascular or heart symptoms?

a. Frequent pain or tightness in your chest: Yes/No

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b. Pain or tightness in your chest during physical activity: Yes/No c. Pain or tightness in your chest that interferes with your job: Yes/No d. In the past two years, have you noticed your heart skipping or missing a

beat: Yes/No e. Heartburn or indigestion that is not related to eating: Yes/ No f. Any other symptoms that you think may be related to heart or circulation

problems: Yes/No

7. Do you currently take medication for any of the following problems?

a. Breathing or lung problems: Yes/No b. Heart trouble: Yes/No c. Blood pressure: Yes/No d. Seizures (fits): Yes/No

8. If you've used a respirator, have you ever had any of the following problems? (If you've never used a respirator, check the following space and go to question 9:)

a. Eye irritation: Yes/No b. Skin allergies or rashes: Yes/No c. Anxiety: Yes/No d. General weakness or fatigue: Yes/No e. Any other problem that interferes with your use of a respirator: Yes/No

9. Would you like to talk to the health care professional who will review this questionnaire about your answers to this questionnaire: Yes/No

Questions 10 to 15 below must be answered by every employee who has been selected to use either a full-facepiece respirator or a self-contained breathing apparatus (SCBA). For employees who have been selected to use other types of respirators, answering these questions is voluntary.

10. Have you ever lost vision in either eye (temporarily or permanently): Yes/No

11. Do you currently have any of the following vision problems?

a. Wear contact lenses: Yes/No b. Wear glasses: Yes/No c. Color blind: Yes/No

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d. Any other eye or vision problem: Yes/No

12. Have you ever had an injury to your ears, including a broken ear drum: Yes/No

13. Do you currently have any of the following hearing problems?

a. Difficulty hearing: Yes/No b. Wear a hearing aid: Yes/No c. Any other hearing or ear problem: Yes/No

14. Have you ever had a back injury: Yes/No

15. Do you currently have any of the following musculoskeletal problems?

a. Weakness in any of your arms, hands, legs, or feet: Yes/No b. Back pain: Yes/No c. Difficulty fully moving your arms and legs: Yes/No d. Pain or stiffness when you lean forward or backward at the waist: Yes/No e. Difficulty fully moving your head up or down: Yes/No f. Difficulty fully moving your head side to side: Yes/No g. Difficulty bending at your knees: Yes/No h. Difficulty squatting to the ground: Yes/No i. Climbing a flight of stairs or a ladder carrying more than 25 lbs: Yes/No j. Any other muscle or skeletal problem that interferes with using a

respirator: Yes/No

Part B - Any of the following questions, and other questions not listed, may be added to the questionnaire at the discretion of the health care professional who will review the questionnaire.

1. In your present job, are you working at high altitudes (over 5,000 feet) or in a place that has lower than normal amounts of oxygen: Yes/No

If "yes," do you have feelings of dizziness, shortness of breath, pounding in your chest, or other symptoms when you're working under these conditions: Yes/No

2. At work or at home, have you ever been exposed to hazardous solvents, hazardous airborne chemicals (e.g., gases, fumes, or dust), or have you come into skin contact with hazardous chemicals: Yes/No

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If "yes," name the chemicals if you know them:_______________ __________ ________________________________________________________________________________________________________________________________

3. Have you ever worked with any of the materials, or under any of the conditions, listed below?

a. Asbestos: Yes/No b. Silica (e.g., in sandblasting): Yes/No c. Tungsten/cobalt (e.g., grinding or welding this material): Yes/No d. Beryllium: Yes/No e. Aluminum: Yes/No f. Coal (for example, mining): Yes/No g. Iron: Yes/No h. Tin: Yes/No i. Dusty environments: Yes/No j. Any other hazardous exposures: Yes/No

If "yes," describe these exposures:____________________________________ ________________________________________________________________________________________________________________________________

4. List any second jobs or side businesses you have:____ _______________ ________________________________________________________________

5. List your previous occupations:_____________________________________ ________________________________________________________________

6. List your current and previous hobbies:_______________________________ ________________________________________________________________

7. Have you been in the military services? Yes/No

If "yes," were you exposed to biological or chemical agents (either in training or combat): Yes/No

8. Have you ever worked on a HAZMAT team? Yes/No

9. Other than medications for breathing and lung problems, heart trouble, blood pressure, and seizures mentioned earlier in this questionnaire, are you taking

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any other medications for any reason (including over-the-counter medications): Yes/No

If "yes," name the medications if you know them:_______________________

10. Will you be using any of the following items with your respirator(s)?

a. HEPA Filters: Yes/No b. Canisters (for example, gas masks): Yes/No c. Cartridges: Yes/No

11. How often are you expected to use the respirator(s) (circle "yes" or "no" for all answers that apply to you)?:

a. Escape only (no rescue): Yes/No b. Emergency rescue only: Yes/No c. Less than 5 hours per week: Yes/No d. Less than 2 hours per day: Yes/No e. 2 to 4 hours per day: Yes/No f. Over 4 hours per day: Yes/No

12. During the period you are using the respirator(s), is your work effort:

a. Light (less than 200 kcal per hour): Yes/No

If "yes," how long does this period last during the average shift:____________hrs.____________mins.

Examples of a light work effort are sitting while writing, typing, drafting, or performing light assembly work; or standing while operating a drill press (1-3 lbs.) or controlling machines.

b. Moderate (200 to 350 kcal per hour): Yes/No


Examples of moderate work effort are sitting while nailing or filing; driving a truck or bus in urban traffic; standing while drilling, nailing, performing assembly work, or transferring a moderate load (about 35 lbs.) at trunk level; walking on a level

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surface about 2 mph or down a 5-degree grade about 3 mph; or pushing a wheelbarrow with a heavy load (about 100 lbs.) on a level surface.

c. Heavy (above 350 kcal per hour): Yes/No


Examples of heavy work are lifting a heavy load (about 50 lbs.) from the floor to your waist or shoulder; working on a loading dock; shoveling; standing while bricklaying or chipping castings; walking up an 8-degree grade about 2 mph; climbing stairs with a heavy load (about 50 lbs.).

13. Will you be wearing protective clothing and/or equipment (other than the respirator) when you're using your respirator: Yes/No

If "yes," describe this protective clothing and/or equipment:_________________

14. Will you be working under hot conditions (temperature exceeding 77 deg. F): Yes/No

15. Will you be working under humid conditions: Yes/No

16. Describe the work you'll be doing while you're using your respirator(s): ________________________________________________________________________________________________________________________________

17. Describe any special or hazardous conditions you might encounter when you're using your respirator(s) (for example, confined spaces, life-threatening gases:

18. Provide the following information, if you know it, for each toxic substance that you'll be exposed to when you're using your respirator(s):

Name of the first toxic substance: Estimated maximum exposure level per shift: Duration of exposure per shift: Name of the second toxic substance:

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Estimated maximum exposure level per shift: Duration of exposure per shift: Name of the third toxic substance: Estimated maximum exposure level per shift: Duration of exposure per shift: The name of any other toxic substances that you'll be exposed to while using your respirator: Describe any special responsibilities you'll have while using your respirator(s) that may affect the safety and well-being of others (for example, rescue, security):

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B

BACK INJURY PREVENTION

MAY/ 2010

Three key components to preventing back injuries are proper posture, conditioning and body mechanics. Many American workers will suffer from back pain in their life time. Strains and sprains of back muscles, ligaments or soft tissue are the major cause of back pain. These conditions generally heal completely, but often recur if injury prevention strategies are not used. Other back pains are due to more serious conditions such as degenerative disk disease or herniated disks. However, even these cases may be prevented – or treated – with proper posture, conditioning and body mechanics.

POSTURE

Proper posture includes standing and sitting in an upright position without slouching, rounding of the shoulders or accentuating the natural curves of the spine. Poor posture typically involves holding the head too far forward or allowing the belly to pull the back forward. If possible, get in the habit of holding in the belly to keep it from protruding and putting excess force on the spine. When standing, bend your knees slightly. Years of poor posture can lead to weakened spine and abdominal muscles that contribute to back pain and injury. Proper sleeping posture is also important to prevent and relieve back pain. Sleep on a mattress that is firm, not sagging, but not too hard. Do not sleep on your stomach. Instead, sleep on your side with a pillow between your knees or sleep on your back with a pillow under your knees.

CONDITIONING

Proper conditioning involves overall conditioning of the body and cardiovascular system with aerobic exercise, as well as strengthening and stretching core muscles of the spine and abdomen. Studies have shown that smoking can contribute to back pain and injury, so if you still smoke, you have yet another reason to think about quitting. Walking, swimming, bicycling and, for some people, slow, short-distance running are excellent ways to condition the entire body and improve cardiovascular health. In addition to improving general levels of health and fitness, these activities increase blood flow to the spine. Aerobic activity, along with a healthy diet, helps prevent weight gain,

which is a risk factor for back injury. To begin exercising, try walking for 10

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minutes twice per day at a moderate pace and build up to at least one 30-minute walk per day three days a week; walking every day is preferable.

Stretching to increase back and abdomen flexibility should be done 5-7 days per week, and strengthening exercises should be done at least 4-5 days per week. Because back conditions vary, strengthening and stretching the muscles of the spine and abdomen should be done under the direction of a physician or physical therapist. These stabilizing exercises improve support for the spine itself, but proper technique is essential.

BODY MECHANICS

Body mechanics refers to the way we use our bodies to complete various tasks during activities of daily life. When lifting, bending or stretching, we should think of how we are using our back to avoid provoking an acute injury. There may be a simpler, less strenuous method or posture that can be used to get something done. Don’t be afraid to ask for help. Instead of bending at the back to pick something up off the floor, stoop

down at the knees. Keep the back as straight as possible and maintain proper posture.

Instead of reaching overhead, use a sturdy stepstool. Push or pull with your entire body, not just your arms. Wear comfortable, low-heeled shoes. When lifting, avoid reaching too far out for the object to be moved; instead,

stand close and grasp the object close to the body. Maintain proper posture with back straight and head up. Bend at the knees and hips, not at the back or waist, and use your legs to lift. Pivot at the hips, not the back. If possible, lift from a tabletop or from waist height, rather than from the floor or over your head.

When working, whether sitting or standing, pace your activities and take frequent breaks. Vary the position of your body when standing. Stand on a cushioned mat, if possible. When sitting at a desk, think in terms of right angles (90°, or the shape of an L). Knees should be at 90° angles when the soles of the feet are touching the floor. The back and thighs should form 90° angles when the body is sitting properly in a chair. Wrists should be straight and elbows at 90° angles when the hands are on the desk or keyboard. Use a chair with proper low-back support and keep your head back and shoulders relaxed.

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Some studies have found that back belts worn to prevent back injuries while lifting are not effective; however, they may help remind you to lift with proper body mechanics. When doing something that you haven‘t done in months, whether it‘s yard work or golfing, do some simple stretches for your entire body and for the particular muscles involved, before, during and after the activity. Maintaining your level of fitness throughout the year will make injury less likely.

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1 GENERAL

Heavy industrial operations where high air temperatures, radiant heat sources, high humidity, direct physical contacts with hot objects or strenuous physical activities are present have a high potential for heat stress. Outdoor operations conducted in hot weather, especially those that require semi-permeable or impermeable protective clothing be worn are also likely to cause heat stress among exposed workers. Age, weight, degree of physical fitness, degree of acclimatization, metabolism, use of alcohol or drugs, and a variety of medical conditions affect a person's sensitivity to heat. Environmental factors include more than the ambient air temperature; radiant heat, air movement, conduction, and relative humidity are all factors. The continued success in preventing heat related injuries and illnesses relies heavily on management, supervisors, and personnel working together to utilize their knowledge and experience in applying these guidelines.

2 PROCEDURE

The following guidelines and control measures should be followed to assist in heat stress prevention:

Modify work / rest schedules according to temperature and workload.

Rotate personnel; alternate job functions to minimize over-stress or overexertion at one task.

Add additional personnel to work teams.

Ventilation, air cooling, fans, shielding, and insulation are the five major types of engineering controls used to reduce heat stress in hot work environments. One or more of these items may be required to be put into place during the project based on heat factors found in/or around the furnace.

Reduce the physical demands of work such as excessive lifting or digging with heavy objects where feasible to do so.

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Limit worker occupancy, or numbers of workers present, especially in confined or enclosed spaces.

Ample supplies of liquids should be placed close to the work area. Cool (50-60 F degree) water or other liquids should be made available to workers in such a way that they are stimulated to frequently drink small amounts, e.g., one 5-7oz serving every 20 minutes during high temperatures.

Start drinking water before the beginning of the work period. Thirst is not an adequate stimulus to maintain the proper amount of fluid in the body. (If you get thirsty, it‘s taken too long).

Pay close attention to other co-workers during the day to help identify early signs of heat related problems and encourage fluid replenishment.

Ensure employees are in a shaded area during cool down periods, and help to minimize contact with direct sunlight as they rest in hot working conditions.

Cool vests, wetting areas, and increased ventilation measures are to be considered if the heat conditions become extreme.

SUMMARY OF HEAT RELATED DISORDERS, SYMPTOMS, AND TREATMENTS

DISORDER SYMPTOMS TREATMENT

HEAT STROKE (Least common, but most dangerous) Occurs when body's system of temperature regulation fails and the body's temperature rises to critical levels. This disorder is associated with high fatality rates; so early recognition and treatment are critical.

Red or flushed skin Confusion, irrational

behavior Lack of sweating, hot dry

skin(although person may have been sweating earlier)

High body temperature Dizziness, convulsions,

nausea, vomiting, and headache can result

Loss of consciousness

If heat stroke suspected, contact Medical personnel immediately

Do not delay transportation to medical facility

Sponge body with cool water and fan individual

If patient is alert, give sips of cool water

No one suspected of being ill from heat stroke should be sent home without medical evaluation

HEAT EXHAUSTION

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may occur after working in hot environments without adequate fluid replacement. Heat exhaustion may be confused with heat stroke, which is a medical emergency.

Weakness, fatigue Headache, nausea,

vomiting, and/or loss of appetite, thirst

Pale, clammy skin with large amount of sweating

Lightheadedness, fainting

Call for medical assistance and move employee to cool environment

Remove unnecessary clothing Person should lie flat If person is alert, offer small amounts of cool water

HEAT CRAMPS may occur after working in moderate to hot environments. This disorder usually occurs after hard physical work. Heat cramps may occur during or after work.

Cramps in skeletal muscles or abdominal muscles

Cramps may be recurrent Muscle pain may continue

after cramps subside

Move person to cool environment Remove unnecessary clothing Provide water or electrolyte solution Seek Medical attention if necessary

HEAT RASH Is the most common heat related disorder. Aggravated by restrictive or impermeable clothing

Skin rash commonly occurs on the arms, shoulders, chest, and behind the knees

may be accompanied by a tingling or prickly feeling

Move to cool environment Remove restrictive or impermeable

clothing, if present Avoid scratching Seek medical attention if necessary Shower and dry skin thoroughly after

working in hot environments

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Heat Stress Program

Category

Ambient Temp.

(F) wearing regular

clothing1

Ambient Temp. (F)

wearing PPE2

Action Steps

I <90 <70 I. No specific heat stress action steps.

II 90-100 70-90 II. Ready access to water, consumption should be 1 cup every 20 min.

Periodic breaks

Monitoring of individuals for symptoms by supervision

III 100-110 90-100 All II, plus a communicated work/rest schedule and at least one of:

Use shading

Use temporary insulation

Use spot cooling (fan or air conditioning)

Use personal cooling devices - cooling vests or vortex tubes

Supplied air respiratory protection

Reflective barriers for radiant heat

>110 >100 All II, plus a documented work/rest schedule; at least one of III, plus:

No work without approval from CLIENT

1

Regular Clothes - (FRC, Nomex, cotton coveralls, etc.) 2

PPE - slicker suits (e.g., for acids or caustics), impermeable coveralls (e.g., for asbestos, lead), disposable coveralls, welding leathers, etc.

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GUIDELINE FOR WORK/REST SCHEDULES

Work Load with Regular Work Clothes for Acclimatized Work/Rest Schedule in Each Hour Workers (Temperature in Degrees F)

Work Rest


95 90 85 continuous

100 95 90 75% 25%

105 100 95 50% 50%

110 105 100 25% 75%

Work Load with PPE for Acclimatized Workers Work/Rest Schedule in Each Hour (Temperature in Degrees F)

Work Rest


85 80 75 continuous

90 85 80 75% 25%

95 90 85 50% 50%

100 95 90 25% 75%

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JOB SAFETY RISK ASSESSMENT

MAY/ 2010

Becht Engineering Advisor: Client Site & Project: Job Function:

Work Area

Is the area a true construction site? Yes No

Are there live process lines in the area? Yes No

Are there live bare electrical lines overhead? Yes No

Are the rules different in the work area than in the base plant? Yes No

Working from Elevated Platforms

Are any of the advisors required to work on ladders, scaffolding, or platforms with unguarded sides?

Yes No

What are the site requirements on yellow and green tagged scaffolding?

Entries Are the advisors required to enter tanks, vessels, excavations (greater

than 4 feet), pits, or trenches?

Yes No

Is there concern about the air quality in these confined spaces? Yes No

Are advisors required to use personal monitors for Hydrogen sulfide, carbon monoxide or any other gas?

Yes No

Rigging & Slings Are the advisors involved with any type of crane rigging or slings? Yes No

Are any of the advisors required to signal cranes? Yes No

Exposures

What types of chemical, natural materials, or human fluids could advisors be reasonably exposed to? (Not possibly, but reasonably exposed.)

Are they in areas with live flange openings operations? Yes No

Are there chemical storage areas close to the work site? Yes No

Are advisors exposed to chemicals or harmful dusts/mists/fumes? (Chemicals which pose a health hazard include asbestos, welding fumes, solder fumes, silica, blood borne pathogens, benzene, etc.)

Yes No

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Energy Sources Indicate energy sources, if any, which could be harmful if accidental

release or startup occurs?

Electrical What kinds of electrical tools are they using?

Yes No

Pneumatic Yes No

Hydraulic Yes No

Thermal Yes No

Mechanical Yes No

Gravity Yes No

Flying Debris Will advisor be operating, or be exposed to, tools/equipment which

may generate flying debris? Yes No

Hammering Yes No

Sawing Yes No

Chipping Yes No

Grinding Yes No

Drilling Yes No

Buffing Yes No

Sharp Objects Are there sharp objects which could cut or pierce the body? Yes No

Glass Yes No

Knife blades Yes No

Sheet metal Yes No

Nail guns Yes No

Needles Yes No

Splinters (wood) Yes No

Burrs (metal) Yes No

Are there hot or cold surfaces which could burn or freeze advisors? Yes No

Welded parts Yes No

Cryogenic materials Yes No

Hot or cold piping/vessels/tanks Yes No

Ovens/stoves Yes No

Molten metals Yes No

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Light Radiation Is there light radiation which could be harmful to the skin or eyes? Yes No

Welding and cutting Yes No

Lasers Yes No

Fire Hazards Is there the potential for a fire or explosion? Yes No

Is there a fire brigade on site? Yes No

Are there any expectations from the site for fire fighting skills? Yes No

Is there a need for fire extinguisher use in any area? Yes No

Workstations Are the work stations properly lighted? Yes No

Are the chairs comfortable and at the right level? Yes No

Are computer screens at the correct height? Yes No

Are advisors arms at a neutral position when typing? Yes No

Excessive Noise Will advisor be operating, or be exposed to, tools/equipment which

may generate excessive noise? Yes No

Jack-hammering Yes No Woodworking machinery Yes No Metalworking machinery Yes No Operating heavy equipment Yes No

Weather Related Hazards Is sun exposure a problem? Yes No

Is cold weather a problem? Yes No

Falling Objects Are there objects which may fall from above onto advisors? Yes No

Are there advisors working overhead? Yes No

Tools or materials handled above their head? Yes No

Are advisors exposed to chemicals or harmful dusts/mists/fumes? (Chemicals which pose a health hazard include asbestos, welding fumes, solder fumes, silica, blood borne pathogens, benzene, etc.)

Yes No

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Office Buildings

Are exits clearly marked? Yes No

Are exits doors blocked or locked? Yes No

Are building evacuation plans in placed and understood? Yes No

BECHT ENGINEERING ADVISOR: PROJECT SAFETY MANAGER (if applicable)

Signature Signature

Printed or Typed Name Printed or Typed Name

Date Date

CLIENT SUPERVISOR: Signature

Printed or Typed Name

Date

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Charles Becht, IV

President

Tom Smith

Safety Manager

Rachel Shannon

Safety Coordinator

Gulf Coast Division

Harry Costner Division Manager/ Building Warden

Texas Division Glinda Hawthorne Building Warden

Advisor Resources Bonnie Winkler

Division Manager

California Division Arcot

Radhakrishnan Division Manager/ Building Warden

Corporate Headquarters, NJ Dan McEnerney Building Warden

W. Virginia Division Tony Scribner

Building Warden

Nuclear Division George Antaki

Division Manager/ Building Warden

Employees

Advisors

Employees

Employees

Employees

Canada Division Trevor Seipp

Division Manager/ Building Warden

Rachel Shannon

Safety Coordinator

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BECHT ENGINEERING HAZARDOUS WASTE OPERATIONS

/ EMERGENCY RESPONSE (HAZWOPER)

OSHA's Hazardous Waste Operations and Emergency Response Standard 29 Code of Federal Regulations (CFR) 1910.120, also known as the HAZWOPER standard, establishes safety and health requirements for "emergency response operations for release of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard."

1 PURPOSE

To ensure all employees who may have exposure to hazardous materials are adequately trained and equipped to keep them safe while performing their job duties and to satisfy OSHA regulations. Also, to ensure their familiarity with Emergency Response procedures and safe zones at the Client site to which an employee is temporarily assigned.

2 GENERAL

Becht Engineering will evacuate our employees from the worksite location when an emergency occurs. We do not permit any of our employees to assist in handling the emergency. Consequently, Becht Engineering is exempt from the requirements of paragraph (p)(8).

This policy is for general information purposes only. It does not apply to Becht Engineering employees,

who will be evacuated if an emergency occurs.

Elements of an emergency response plan:

Pre-emergency planning and coordination with outside parties.

Personnel roles, lines of authority, training, and communication.

Emergency recognition and prevention.

Safe distances and places of refuge.

Site security and control.

Evacuation routes and procedures.

Decontamination procedures.

Emergency medical treatment and first aid.

Emergency alerting and response procedures.

Critique of response and follow-up. PPE and emergency equipment.

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3 PROCEDURE

Procedures for handling emergency response.

The senior emergency response official responding to an emergency shall become the individual in charge of a site-specific Incident Command System (ICS). All emergency responders and their communications shall be coordinated and controlled through the individual in charge of the ICS assisted by the senior official present for each employer. The "senior official" at an emergency response is the most senior official on the site who has the responsibility for controlling the operations at the site. Initially it is the senior officer on the first-due piece of responding emergency apparatus to arrive on the incident scene. As more senior officers arrive (i.e., battalion chief, fire chief, state law enforcement official, site coordinator, etc.) the position is passed up the line of authority which has been previously established.

The individual in charge of the ICS shall identify, to the extent possible, all hazardous substances or conditions present and shall address as appropriate site analysis, use of engineering controls, maximum exposure limits, hazardous substance handling procedures, and use of any new technologies.

Based on the hazardous substances and/or conditions present, the individual in charge of the ICS shall implement appropriate emergency operations, and assure that the personal protective equipment worn is appropriate for the hazards to be encountered. However, personal protective equipment shall meet, at a minimum, the criteria contained in 29 CFR 1910.156(e) when worn while performing fire fighting operations beyond the incipient stage for any incident.

Employees engaged in emergency response and exposed to hazardous substances presenting an inhalation hazard or potential inhalation hazard shall wear positive pressure self-contained breathing apparatus while engaged in emergency response, until such time that the individual in charge of the ICS determines through the use of air monitoring that a decreased level of respiratory protection will not result in hazardous exposures to employees.

The individual in charge of the ICS shall limit the number of emergency response personnel at the emergency site, in those areas of potential or actual exposure to incident or site hazards, to those who are actively performing emergency operations. However, operations in hazardous areas shall be performed using the buddy system in groups of two or more.

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Back-up personnel shall be standing by with equipment ready to provide assistance or rescue. Qualified basic life support personnel, as a minimum, shall also be standing by with medical equipment and transportation capability.

The individual in charge of the ICS shall designate a safety officer, who is knowledgeable in the operations being implemented at the emergency response site, with specific responsibility to identify and evaluate hazards and to provide direction with respect to the safety of operations for the emergency at hand.

When activities are judged by the safety officer to be an IDLH and/or to involve an imminent danger condition, the safety officer shall have the authority to alter, suspend, or terminate those activities. The safety official shall immediately inform the individual in charge of the ICS of any actions needed to be taken to correct these hazards at the emergency scene.

After emergency operations have terminated, the individual in charge of the ICS shall implement appropriate decontamination procedures.

When deemed necessary for meeting the tasks at hand, approved self-contained compressed air breathing apparatus may be used with approved cylinders from other approved self-contained compressed air breathing apparatus provided that such cylinders are of the same capacity and pressure rating. All compressed air cylinders used with self-contained breathing apparatus shall meet U.S. Department of Transportation and National Institute for Occupational Safety and Health criteria.

Skilled support personnel.

Personnel, not necessarily an employer's own employees, who are skilled in the operation of certain equipment, such as mechanized earth moving or digging equipment or crane and hoisting equipment, and who are needed temporarily to perform immediate emergency support work that cannot reasonably be performed in a timely fashion by an employer's own employees, and who will be or may be exposed to the hazards at an emergency response scene, are not required to meet the training required in this paragraph for the employer's regular employees. However, these personnel shall be given an initial briefing at the site prior to their participation in any emergency response. The initial briefing shall include instruction in the wearing of appropriate personal protective equipment, what chemical hazards are involved, and what duties are to be performed. All other appropriate safety and health precautions provided to the employer's own employees shall be used to assure the safety and health of these personnel.

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Specialist employees.

Employees who, in the course of their regular job duties, work with and are trained in the hazards of specific hazardous substances, and who will be called upon to provide technical advice or assistance at a hazardous substance release incident to the individual in charge, shall receive training or demonstrate competency in the area of their specialization annually.

First responder awareness level.

First responders at the awareness level are individuals who are likely to witness or discover a hazardous substance release and who have been trained to initiate an emergency response sequence by notifying the proper authorities of the release. They would take no further action beyond notifying the authorities of the release. First responders at the awareness level shall have sufficient training or have had sufficient experience to objectively demonstrate competency in the following areas:

An understanding of what hazardous substances are, and the risks associated with them in an incident.

An understanding of the potential outcomes associated with an emergency created when hazardous substances are present.

The ability to recognize the presence of hazardous substances in an emergency.

The ability to identify the hazardous substances, if possible.

An understanding of the role of the first responder awareness individual in the employer's emergency response plan including site security and control and the U.S. Department of Transportation's Emergency Response Guidebook.

The ability to realize the need for additional resources, and to make appropriate notifications to the communication center.

First responder operations level.

First responders at the operations level are individuals who respond to releases or potential releases of hazardous substances as part of the initial response to the site for the purpose of protecting nearby persons, property, or the environment from the effects of the release. They are trained to respond in a defensive fashion without actually trying to stop the release. Their function is to contain the release from a safe distance, keep it from spreading, and prevent exposures. First responders at the operational level shall have received at least eight hours of training or have had sufficient experience to objectively demonstrate competency in the following areas in addition to those listed for the awareness level and the employer shall so certify:

Knowledge of the basic hazard and risk assessment techniques.

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Know how to select and use proper personal protective equipment provided to the first responder operational level.

An understanding of basic hazardous materials terms.

Know how to perform basic control, containment and/or confinement operations within the capabilities of the resources and personal protective equipment available with their unit.

Know how to implement basic decontamination procedures.

An understanding of the relevant standard operating procedures and termination procedures.

Hazardous materials technician.

Hazardous materials technicians are individuals who respond to releases or potential releases for the purpose of stopping the release. They assume a more aggressive role than a first responder at the operations level in that they will approach the point of release in order to plug, patch or otherwise stop the release of a hazardous substance. Hazardous materials technicians shall have received at least 24 hours of training equal to the first responder operations level and in addition have competency in the following areas and the employer shall so certify:

Know how to implement the employer's emergency response plan.

Know the classification, identification and verification of known and unknown materials by using field survey instruments and equipment.

Be able to function within an assigned role in the Incident Command System.

Know how to select and use proper specialized chemical personal protective equipment provided to the hazardous materials technician.

Understand hazard and risk assessment techniques.

Be able to perform advance control, containment, and/or confinement operations within the capabilities of the resources and personal protective equipment available with the unit.

Understand and implement decontamination procedures.

Understand termination procedures.

Understand basic chemical and toxicological terminology and behavior.

Hazardous materials specialist.

Hazardous materials specialists are individuals who respond with and provide support to hazardous materials technicians. Their duties parallel those of the hazardous materials technician, however, those duties require a more directed or specific knowledge of the various substances they may be called upon to contain. The hazardous materials specialist would also act as the site liaison with Federal, state, local and other government authorities in regards to site activities. Hazardous materials specialists shall have received at least 24 hours of training equal to the technician level

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and in addition have competency in the following areas and the employer shall so certify:

Know how to implement the local emergency response plan.

Understand classification, identification and verification of known and unknown materials by using advanced survey instruments and equipment.

Know the state emergency response plan.

Be able to select and use proper specialized chemical personal protective equipment provided to the hazardous materials specialist.

Understand in-depth hazard and risk techniques.

Be able to perform specialized control, containment, and/or confinement operations within the capabilities of the resources and personal protective equipment available.

Be able to determine and implement decontamination procedures.

Have the ability to develop a site safety and control plan.

Understand chemical, radiological and toxicological terminology and behavior.

On scene incident commander.

Incident commanders, who will assume control of the incident scene beyond the first responder awareness level, shall receive at least 24 hours of training equal to the first responder operations level and in addition have competency in the following areas and the employer shall so certify:

Know and be able to implement the employer's incident command system.

Know how to implement the employer's emergency response plan.

Know and understand the hazards and risks associated with employees working in chemical protective clothing.

Know how to implement the local emergency response plan.

Know of the state emergency response plan and of the Federal Regional Response Team.

Know and understand the importance of decontamination procedures.

Medical surveillance and consultation.

Members of an organized and designated HAZMAT team and hazardous materials specialist shall receive a baseline physical examination and be provided with medical surveillance.

Any emergency response employees who exhibit signs or symptoms which may have resulted from exposure to hazardous substances during the course of an emergency incident either immediately or subsequently, shall be provided with medical at no cost to the employee.

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Chemical protective clothing. Chemical protective clothing and equipment to be used by organized and designated HAZMAT team members, or to be used by hazardous materials specialists, shall meet the requirements of paragraphs (g)(3) through (5) of this section.

Post-emergency response operations.

Becht Engineering does not remove from a Client’s site hazardous substances, health hazards, or materials contaminated with them.

This section is for informational purposes only.

Upon completion of the emergency response, if it is determined that it is necessary to remove hazardous substances, health hazards and materials contaminated with them (such as contaminated soil or other elements of the natural environment) from the site of the incident, the employer conducting the clean-up shall comply with one of the following:

Meet all the requirements of paragraphs (b) through (o) of this section; or

Where the clean-up is done on plant property using plant or workplace employees, such employees shall have completed the training requirements of the following: 29 CFR 1910.38, 1910.134, 1910.1200, and other appropriate safety and health training made necessary by the tasks they are expected to perform such as personal protective equipment and decontamination procedures.

4 TRAINING

Training shall be based on the duties and function to be performed by each responder of an emergency response organization. The skill and knowledge levels required for all new responders, those hired after the effective date of this standard, shall be conveyed to them through training before they are permitted to take part in actual emergency operations on an incident. Employees who participate, or are expected to participate, in emergency response, shall be given training in accordance with the following paragraphs:

Training for emergency response employees shall be completed before they are called upon to perform in real emergencies. Such training shall include the elements of the emergency response plan, standard operating procedures the employer has established for the job, the personal protective equipment to be worn and procedures for handling emergency incidents.

Exception #1: an employer need not train all employees to the degree specified if the employer divides the work force in a manner such that a sufficient number of employees who have responsibility to control emergencies have the training specified, and all other

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employees, who may first respond to an emergency incident, have sufficient awareness training to recognize that an emergency response situation exists and that they are instructed in that case to summon the fully trained employees and not attempt control activities for which they are not trained.

Exception #2: An employer need not train all employees to the degree specified if arrangements have been made in advance for an outside fully-trained emergency response team to respond in a reasonable period and all employees, who may come to the incident first, have sufficient awareness training to recognize that an emergency response situation exists and they have been instructed to call the designated outside fully-trained emergency response team for assistance.

Employee members of TSD facility emergency response organizations shall be trained to a level of competence in the recognition of health and safety hazards to protect themselves and other employees. This would include training in the methods used to minimize the risk from safety and health hazards; in the safe use of control equipment; in the selection and use of appropriate personal protective equipment; in the safe operating procedures to be used at the incident scene; in the techniques of coordination with other employees to minimize risks; in the appropriate response to over exposure from health hazards or injury to themselves and other employees; and in the recognition of subsequent symptoms which may result from over exposures.

Becht Engineering shall certify that each covered employee has attended and successfully completed eight (8) hours of training, or shall certify the employee's competency for certification of training shall be recorded and maintained.

Trainers. Trainers shall have satisfactorily completed a training course for teaching the subjects they are expected to teach, such as the courses offered by the U.S. National Fire Academy, or they shall have the training and/or academic credentials and instructional experience necessary to demonstrate competent instructional skills and a good command of the subject matter of the courses they are to teach.

Refresher training.

Those employees who are trained in accordance with paragraph (q)(6) of this section shall receive annual refresher training of sufficient content and duration to maintain their competencies, or shall demonstrate competency in those areas at least yearly.

A statement shall be made of the training or competency, and if a statement of competency is made, the employer shall keep a record of the methodology used to demonstrate competency.

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/ RESOURCE CONSERVATION (HAZWOPER)

OSHA's Hazardous Waste Operations and Emergency Response Standard 29 Code of Federal Regulations (CFR) 1910.120, also known as the HAZWOPER standard, establishes safety and health requirements for "emergency response operations for release of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard."

1 PURPOSE AND SCOPE

Purpose

To ensure all employees who may have exposure to hazardous materials are adequately trained and equipped to keep them safe while performing their job duties and to satisfy OSHA regulations. Scope

The HAZWOPER Policy applies to all Becht Engineering employees, especially those providing services at a Client‘s site.

2 GENERAL

To ensure the greatest possible protection for employees in the workplace, the cooperative efforts of both employers and employees will help in establishing and maintaining a safe and healthful work environment.

Definitions

―Buddy System‖ a system of organizing employees into work groups in such a manner that each employee of the work group is designated to be observed by at least one other employee in the work group. The purpose of the buddy system is to provide rapid assistance to employees in the event of an emergency. ―Clean-up operation‖ an operation where hazardous substances are removed, contained, incinerated, neutralized, stabilized, cleared-up, or in any other manner processed or handled with the ultimate goal of making the site safer for people or the environment. ―Decontamination‖ means the removal of hazardous substances from employees and their equipment to the extent necessary to preclude the occurrence of foreseeable adverse health effects. ―Emergency response or responding to emergencies‖

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a response effort by employees from outside the immediate release area or by other designated responders (i.e., mutual aid groups, local fire departments, etc.) to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance. Responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel are not considered to be emergency responses within the scope of this standard. Responses to releases of hazardous substances where there is no potential safety or health hazard (i.e., fire, explosion, or chemical exposure) are not considered to be emergency responses. ―Facility‖ (A) any building, structure, installation, equipment, pipe or pipeline (including any pipe

into a sewer or publicly owned treatment works), well, pit, pond, lagoon, impoundment, ditch, storage container, motor vehicle, rolling stock, or aircraft,

(B) any site or area where a hazardous substance has been deposited, stored, disposed of, or placed, or otherwise come to be located; but does not include any consumer product in consumer use or any water-borne vessel.

―Hazardous materials response (HAZMAT) team‖ an organized group of employees, designated by the employer, who are expected to perform work to handle and control actual or potential leaks or spills of hazardous substances requiring possible close approach to the substance. The team members perform responses to releases or potential releases of hazardous substances for the purpose of control or stabilization of the incident. A HAZMAT team is not a fire brigade nor is a typical fire brigade a HAZMAT team. A HAZMAT team, however, may be a separate component of a fire brigade or fire department. ―Hazardous substance‖ any substance designated or listed under (A) through (D) of this definition, exposure to which results or may result in adverse effects on the health or safety of employees: [A] Any substance defined under section 101(14) of CERCLA; [B] Any biologic agent and other disease causing agent which after release into the environment and upon exposure, ingestion, inhalation, or assimilation into any person, either directly from the environment or indirectly by ingestion through food chains, will or may reasonably be anticipated to cause death, disease, behavioral abnormalities, cancer, genetic mutation, physiological malfunctions (including malfunctions in reproduction) or physical deformations in such persons or their offspring. [C] Any substance listed by the U.S. Department of Transportation as hazardous materials under 49 CFR 172.101 and appendices; and [D] Hazardous waste as herein defined. ―Hazardous waste‖

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[A] A waste or combination of wastes as defined in 40 CFR 261.3, or [B] Those substances defined as hazardous wastes in 49 CFR 171.8.

―Hazardous waste operation‖ any operation conducted within the scope of this standard.

―Hazardous waste site or Site‖ any facility or location within the scope of this standard at which hazardous waste operations take place. ―Health hazard‖ means a chemical, mixture of chemicals or a pathogen for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. The term "health hazard" includes chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes. It also includes stress due to temperature extremes. Further definition of the terms used above can be found in Appendix A to 29 CFR 1910.1200. ―IDLH or Immediately dangerous to life or health‖ an atmospheric concentration of any toxic, corrosive or asphyxiant substance that poses an immediate threat to life or would interfere with an individual's ability to escape from a dangerous atmosphere.

―Oxygen deficiency‖ concentration of oxygen by volume below which atmosphere supplying respiratory protection must be provided. It exists in atmospheres where the percentage of oxygen by volume is less than 19.5 percent oxygen.

―Permissible exposure limit‖ the exposure, inhalation or dermal permissible exposure limit specified in 29 CFR Part 1910, Subparts G and Z.

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―Published exposure level‖ the exposure limits published in "NIOSH Recommendations for Occupational Health Standards" dated 1986, which is incorporated by reference as specified in § 1910.6, or if none is specified, the exposure limits published in the standards specified by the American Conference of Governmental Industrial Hygienists in their publication "Threshold Limit Values and Biological Exposure Indices for 1987-88" dated 1987, which is incorporated by reference as specified in § 1910.6. ―Post emergency response‖ that portion of an emergency response performed after the immediate threat of a release has been stabilized or eliminated and clean-up of the site has begun. If post emergency response is performed by an employer's own employees who were part of the initial emergency response, it is considered to be part of the initial response and not post emergency response. However, if a group of an employer's own employees, separate from the group providing initial response, performs the clean-up operation, then the separate group of employees would be considered to be performing post-emergency response and subject to paragraph (q)(11) of this section. ―Qualified person‖ a person with specific training, knowledge and experience in the area for which the person has the responsibility and the authority to control.

―Site safety and health supervisor (or official)‖

the individual located on a hazardous waste site who is responsible to the employer and has the authority and knowledge necessary to implement the site safety and health plan and verify compliance with applicable safety and health requirements. ―Small quantity generator‖ a generator of hazardous wastes which in any calendar month generates no more than 1,000 kilograms (2,205) pounds of hazardous waste in that month. ―Uncontrolled hazardous waste site‖ an area identified as an uncontrolled hazardous waste site by a governmental body, whether Federal, state, local or other where an accumulation of hazardous substances creates a threat to the health and safety of individuals or the environment or both. Some sites are found on public lands such as those created by former municipal, county or state landfills where illegal or poorly managed waste disposal has taken place. Other sites are found on private property, often belonging to generators or former generators of hazardous substance wastes. Examples of such sites include, but are not limited to, surface impoundments, landfills, dumps, and tank or drum farms. Normal operations at TSD sites are not covered by this definition.

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3 PROCEDURE

Becht Engineering‘s primary objective is to prevent all accidents and/or incidents through training and strict adherence to the policies and procedures outlined in this Safety Manual.

When a Becht Engineering employee is placed on an assignment at a Client site, the following procedures shall take place in conjunction with the initial proposal of work and meeting site access requirements: Preliminary evaluation. A preliminary evaluation of a site's characteristics shall be performed prior to site entry by a qualified person in order to aid in the selection of appropriate employee protection methods prior to site entry. Immediately after initial site entry, a more detailed evaluation of the site's specific characteristics shall be performed by a qualified person in order to further identify existing site hazards and to further aid in the selection of the appropriate engineering controls and personal protective equipment for the tasks to be performed. Pre-entry briefing Pre-entry briefings shall be held prior to initiating any site activity, and at such other times as necessary to ensure that employees are apprised of the site safety and health plan and that this plan is being followed. The information and data obtained from the site characterization and required analysis work shall be used to prepare and update the safety training program for each employee at that site. Hazard identification All suspected conditions that may pose inhalation or skin absorption hazards that are immediately dangerous to life or health (IDLH) or other conditions that may cause death or serious harm shall be identified during the preliminary survey and evaluated during the detailed survey. Examples of such hazards include, but are not limited to, confined space entry, potentially explosive or flammable situations, visible vapor clouds, or areas where biological indicators such as dead animals or vegetation are located.

A critical Location and approximate size of the site.

Description of the response activity and/or the job task to be performed.

Duration of the planned employee activity.

Site topography and accessibility by air and roads.

Safety and health hazards expected at the site.

Pathways for hazardous substance dispersion.

Present status and capabilities of emergency response teams that would provide assistance to on-site employees at the time of an emergency.

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Hazardous substances and health hazards involved or expected at the site and their chemical and physical properties.

Personal Protective Equipment Based upon the results of the preliminary site evaluation, an ensemble of PPE shall be selected and used during initial site entry which will provide protection to a level of exposure below permissible exposure limits and published exposure levels for known or suspected hazardous substances and health hazards and which will provide protection against other known and suspected hazards identified during the preliminary site evaluation. If positive-pressure self-contained breathing apparatus is not used as part of the entry ensemble, and if respiratory protection is warranted by the potential hazards identified during the preliminary site evaluation, an escape self-contained breathing apparatus of at least five minute's duration shall be carried by employees during initial site entry. If the preliminary site evaluation does not produce sufficient information to identify the hazards or suspected hazards of the site an ensemble providing equivalent to Level B PPE shall be provided as minimum protection, and direct reading instruments shall be used as appropriate for identifying IDLH conditions. Once the hazards of the site have been identified, the appropriate PPE shall be selected and used. Monitoring

The following monitoring shall be conducted during initial site entry when the site evaluation produces information which shows the potential for ionizing radiation or IDLH conditions, or when the site information is not sufficient reasonably to eliminate these possible conditions:

Monitoring with direct reading instruments for hazardous levels of ionizing radiation.

Monitoring the air with appropriate direct reading test equipment for (i.e., combustible gas meters, detector tubes) for IDLH and other conditions that may cause death or serious harm (combustible or explosive atmospheres, oxygen deficiency, toxic substances.)

Visually observing for signs of actual or potential IDLH or other dangerous conditions.

An ongoing air monitoring program in accordance with paragraph (h) of this section shall be implemented after site characterization has determined the site is safe for the start-up of operations.

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Risk identification Once the presence and concentrations of specific hazardous substances and health hazards have been established, the risks associated with these substances shall be identified. Employees who will be working on the site shall be informed of any risks that have been identified.

Risks to consider include, but are not limited to:

Exposures exceeding the permissible exposure limits and published exposure levels.

IDLH Concentrations.

Potential Skin Absorption and Irritation Sources.

Potential Eye Irritation Sources.

Explosion Sensitivity and Flammability Ranges.

Oxygen deficiency. Medical Surveillance The medical surveillance program shall include the following employees:

All employees who are or may be exposed to hazardous substances or health hazards at or above the established permissible exposure limit, above the published exposure levels for these substances, without regard to the use of respirators, for 30 days or more a year;

All employees who wear a respirator for 30 days or more a year.

All employees who are injured, become ill or develop signs or symptoms due to possible overexposure involving hazardous substances or health hazards from an emergency response or hazardous waste operation; and

Members of HAZMAT teams. Frequency of medical examinations and consultations. Medical examinations and consultations shall be made available by Becht Engineering to each employee who has or may be exposed to hazardous substances or health hazards at or above the established permissible exposure limit as follows:

Prior to assignment.

At least once every twelve months for each employee covered unless the attending physician believes a longer interval (not greater than biennially) is appropriate;

At termination of employment or reassignment to an area where the employee would not be covered if the employee has not had an examination within the last six months.

As soon as possible upon notification by an employee that the employee has developed signs or symptoms indicating possible overexposure to hazardous substances or health hazards, or that the employee has been injured or exposed above the permissible exposure limits or published exposure levels in an emergency situation;

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At more frequent times, if the examining physician determines that an increased frequency of examination is medically necessary.

For employees covered under paragraph (f)(2)(iii) and for all employees including of employers covered by paragraph (a)(1)(iv) who may have been injured, received a health impairment, developed signs or symptoms which may have resulted from exposure to hazardous substances resulting from an emergency incident, or exposed during an emergency incident to hazardous substances at concentrations above the permissible exposure limits or the published exposure levels without the necessary personal protective equipment being used:

As soon as possible following the emergency incident or development of signs or symptoms;

At additional times, if the examining physician determines that follow-up examinations or consultations are medically necessary.

All medical examinations and procedures shall be performed by or under the supervision of a licensed physician, preferably one knowledgeable in occupational medicine, and shall be provided without cost to the employee, without loss of pay, and at a reasonable time and place.

Engineering controls, work practices, and personal protective equipment for employee protection.

Substances regulated in Subparts G and Z.

Engineering controls and work practices shall be instituted to reduce and maintain employee exposure to or below the permissible exposure limits for substances regulated by 29 CFR Part 1910, to the extent required by Subpart Z, except to the extent that such controls and practices are not feasible.

Engineering controls which may be feasible include the use of pressurized cabs or control booths on equipment, and/or the use of remotely operated material handling equipment. Work practices which may be feasible are removing all non-essential employees from potential exposure during opening of drums, wetting down dusty operations and locating employees upwind of possible hazards.

Whenever engineering controls and work practices are not feasible, or not required, any reasonable combination of engineering controls, work practices and PPE shall be used to reduce and maintain to or below the permissible exposure limits or dose limits for substances regulated by 29 CFR Part 1910, Subpart Z.

Becht Engineering shall not implement a schedule of employee rotation as a means of compliance with permissible exposure limits or dose limits except when there is no other feasible way of complying with the airborne or dermal dose limits for ionizing radiation.

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Engineering controls, work practices, and PPE for substances not regulated in Subparts G and Z.

An appropriate combination of engineering controls, work practices, and personal protective equipment shall be used to reduce and maintain employee exposure to or below published exposure levels for hazardous substances and health hazards not regulated by 29 CFR Part 1910, Subparts G and Z. Becht Engineering may use the published literature and MSDS as a guide in making the employer's determination as to what level of protection the employer believes is appropriate for hazardous substances and health hazards for which there is no permissible exposure limit or published exposure limit.

Personal protective equipment selection.

Personal protective equipment (PPE) shall be selected and used which will protect employees from the hazards and potential hazards they are likely to encounter as identified during the site characterization and analysis.

Personal protective equipment selection shall be based on an evaluation of the performance characteristics of the PPE relative to the requirements and limitations of the site, the task-specific conditions and duration, and the hazards and potential hazards identified at the site.

Positive pressure self-contained breathing apparatus, or positive pressure air-line respirators equipped with an escape air supply shall be used when chemical exposure levels present will create a substantial possibility of immediate death, immediate serious illness or injury, or impair the ability to escape.

Totally-encapsulating chemical protective suits shall be used in conditions where skin absorption of a hazardous substance may result in a substantial possibility of immediate death, immediate serious illness or injury, or impair the ability to escape.

The level of protection provided by PPE selection shall be increased when additional informationor site conditions show that increased protection is necessary to reduce employee exposures below permissible exposure limits and published exposure levels for hazardous substances and health hazards. (See Appendix B for guidance on selecting PPE ensembles.)

The level of employee protection provided may be decreased when additional information or site conditions show that decreased protection will not result in hazardous exposures to employees.

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Monitoring

Air monitoring shall be used to identify and quantify airborne levels of hazardous substances and safety and health hazards in order to determine the appropriate level of employee protection needed on site.

Upon initial entry, representative air monitoring shall be conducted to identify any IDLH condition, exposure over permissible exposure limits or published exposure levels, exposure over a radioactive material's dose limits or other dangerous condition such as the presence of flammable atmospheres, oxygen-deficient environments.

Periodic monitoring shall be conducted when the possibility of an IDLH condition or flammable atmosphere has developed or when there is indication that exposures may have risen over permissible exposure limits or published exposure levels since prior monitoring. Situations where it shall be considered whether the possibility that exposures have risen are as follows:

When work begins on a different portion of the site.

When contaminants other than those previously identified are being handled.

When a different type of operation is initiated (e.g., drum opening as opposed to exploratory well drilling.)

When employees are handling leaking drums or containers or working in areas with obvious liquid contamination (e.g., a spill or lagoon.)

Decontamination

All employees leaving a contaminated area shall be appropriately decontaminated; all contaminated clothing and equipment leaving a contaminated area shall be appropriately disposed of or decontaminated.

Decontamination procedures shall be monitored by the site safety and health supervisor to determine their effectiveness. When such procedures are found to be ineffective, appropriate steps shall be taken to correct any deficiencies.

Location. Decontamination shall be performed in geographical areas that will minimize the exposure of uncontaminated employees or equipment to contaminated employees or equipment.

Equipment and solvents. All equipment and solvents used for decontamination shall be decontaminated or disposed of properly.

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Personal protective clothing and equipment.

Protective clothing and equipment shall be decontaminated, cleaned, laundered, maintained or replaced as needed to maintain their effectiveness.

Employees whose non-impermeable clothing becomes wetted with hazardous substances shall immediately remove that clothing and proceed to shower. The clothing shall be disposed of or decontaminated before it is removed from the work zone.

Unauthorized employees. Unauthorized employees shall not remove protective clothing or equipment from change rooms.

Commercial laundries or cleaning establishments. Commercial laundries or cleaning establishments that decontaminate protective clothing or equipment shall be informed of the potentially harmful effects of exposures to hazardous substances.

Showers and change rooms. Where the decontamination procedure indicates a need for regular showers and change rooms outside of a contaminated area, they shall be provided. If temperature conditions prevent the effective use of water, then other effective means for cleansing shall be provided and used.

4 TRAINING

All employees working on site (such as but not limited to equipment operators, general laborers and others) exposed to hazardous substances, health hazards, or safety hazards and their supervisors and management responsible for the site shall receive training before they are permitted to engage in hazardous waste operations that could expose them to hazardous substances, safety, or health hazards . Employees shall not be permitted to participate in or supervise field activities until they have been trained to a level required by their job function and responsibility. The training shall thoroughly cover the following:

Names of personnel and alternates responsible for site safety and health;

Safety, health and other hazards present on the site;

Use of personal protective equipment;

Work practices by which the employee can minimize risks from hazards;

Safe use of engineering controls and equipment on the site;

Medical surveillance requirements including recognition of symptoms and signs which might indicate over exposure to hazards.

General site workers (such as equipment operators, general laborers and supervisory personnel) engaged in hazardous substance removal or other activities which expose or potentially expose workers to hazardous substances and health hazards shall receive a

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minimum of 40 hours of instruction off the site, and a minimum of three days actual field experience under the direct supervision of a trained experienced supervisor. Workers on site only occasionally for a specific limited task (such as, but not limited to, ground water monitoring, land surveying, or geophysical surveying) and who are unlikely to be exposed over permissible exposure limits and published exposure limits shall receive a minimum of 24 hours of instruction off the site, and the minimum of one day actual field experience under the direct supervision of a trained, experienced supervisor. Workers regularly on site who work in areas which have been monitored and fully characterized indicating that exposures are under permissible exposure limits and published exposure limits where respirators are not necessary, and the characterization indicates that there are no health hazards or the possibility of an emergency developing, shall receive a minimum of 24 hours of instruction off the site, and the minimum of one day actual field experience under the direct supervision of a trained, experienced supervisor. Management and Supervisor Training Onsite management and supervisors directly responsible for, or who supervise employees engaged in, hazardous waste operations shall receive 40 hours initial training, and three days of supervised field experience. All training shall meet the standards and comprehensive curriculum of the OSHA Institute of America.

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BECHT ENGINEERING

SAFE DRIVING POLICY

1 PURPOSE

To establish policy, procedure and safety guidelines for the operation of vehicles for Becht Engineering company business purposes.

2 GENERAL

It is Becht Engineering‘s objective that any person who drives a vehicle while performing official company business be qualified to drive under state laws and also have the ability to operate the vehicle in a safe manner. The policy encompasses operation of both personal vehicles and company owned vehicles while on company business and defines expected driving practices. The goal of the safe driving policy is to assure that operators of company vehicles have sufficient knowledge, skill and ability, measured in part through a safe driving history, to protect themselves, coworkers, clients and the public from an unsafe driver.

3 PROCEDURE

The following are basic guidelines for operating vehicles on company business: Driver must be at least 19 years old and in possession of a valid United States or

Canadian driver's license at all times when operating a vehicle as a Becht employee.

Driver shall observe all rules and regulations for safe driving as defined by the

New Jersey Motor Vehicle Department, or by the Department in whose state the vehicle is operated.

The vehicle shall be used for its purpose, according to design and intended use. Safety belts shall be used by all occupants traveling either in a vehicle owned,

leased, or rented by Becht or in private vehicles while on company business. Seats should be occupied from front to back.

Drinking or possessing alcohol and/or illegal drugs in vehicles or driving while

under the influence of alcohol or drugs is strictly prohibited.

If an individual is currently taking prescription or over-the-counter medication that may impair driving skills, they will not be allowed to operate a vehicle.

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BECHT ENGINEERING

SAFE DRIVING POLICY

Conditions that lead to loss of control should be avoided (e.g., driving while sleepy or inattentive, or driving too fast for road conditions).

If the weather is inclement, stop and stay overnight in a safe place. The

additional lodging cost is worth avoiding the risk of an accident. Do not use a telephone or text while driving. Stop the vehicle in a safe area to

text or use a cell phone, or have a passenger operate it. Texting while driving is illegal in many states.

Employees are responsible for reporting all accidents to their supervisor.

All departments owning vehicles will schedule regular maintenance of vehicles

and their tires. Worn or underinflated tires can increase the risk of rollover. A commercial driver‘s license (CDL) is required of anyone who drives a vehicle

with a gross vehicle weight of more than 26,000 pounds; a vehicle designed to transport more than 16 passengers, including driver; and any size vehicle which requires a hazardous materials placard.

If a load is being transported, the load must be secured and shall not exceed the manufacturer‘s specifications and legal limits for the vehicle.

4 TRAINING

None

5 REFERENCES

None

6 APPENDICES

None