COMPANY POLICIES AND PROCEDURES

Contents of the Company Policies and Procedures

1. Program Requirements. ................................................................................................. 2

2. Written Individual Programs. ......................................................................................... 2
3. Health and Safety Program Responsibility. .................................................................... 2
4. Job Safety Planning and Analysis.................................................................................... 3
5. Routine Safety and Health Inspections. .......................................................................... 4
6. Safety Meetings. ............................................................................................................ 5
7. Hazard Reporting. .......................................................................................................... 5
8. First Aid Procedures. ...................................................................................................... 5
9. Accident Investigation.................................................................................................... 6
10. General Safety Rules for all Employees. ......................................................................... 7
11. Fire Prevention and Protection. ..................................................................................... 8
12. Evacuation Procedures. .................................................................................................. 8
13. Recordkeeping requirements. ........................................................................................ 9
14. Disciplinary Actions for Willful Unsafe Acts. ................................................................. 11

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1. PROGRAM REQUIREMENTS.
<Company Name> will ensure that the hazards at our jobsites are evaluated and
communicated to its employees and that proper protective measures are provided. Safety is
also the responsibility of every employee of this company. The Safety Officer is the sole
person authorized to amend these instructions. This program will be maintained in
accordance with OSHA Regulations 29 CFR 1910 and 29 CFR 1926. In addition, <Company
Name> will review and evaluate this program on an annual basis or when operational changes
occur that require a revision of this document.

2. WRITTEN INDIVIDUAL PROGRAMS.

<Company Name> will maintain written individual procedures for the types of hazards/issues
that our employees will or could potentially be exposed to. Each program will be
reviewed/revised on an annual basis or as required by the respective governing OSHA
Standard. Each written program will be communicated to all personnel that are affected by
it. Each will encompass the total workplace, regardless of number of workers employed or
the number of work shifts. They will be designed to establish clear goals and objectives.

3. HEALTH AND SAFETY PROGRAM RESPONSIBILITY.

Company Owner Responsibilities. The Owner of <Company Name> recognizes the
importance of safety and has committed to creating a place of employment which is
free from recognized hazards. The Owner is ultimately responsible for the safety of all
employees of <Company Name>. The Owner will ensure that all levels of management
in the company are delegated the necessary authority to cultivate a safe environment
and to take the appropriate actions to correct any deviations or deficiencies relating to
safety on the job. The Owner will also be responsible for making available the funds
necessary to ensure that employees are provided with effective safety equipment to
perform their work.
Safety Officer Responsibilities. The company Safety Officer will be responsible for the
day to day management of the company safety program. The Safety Officer will assist
the company in remaining in compliance with all applicable health and safety
regulations. The Safety Officer will identify and coordinate training sessions to ensure
that all employees are equipped with the needed safety skills and knowledge. The
Safety Officer will perform inspections of jobsites and facilities and take the
appropriate actions to correct any deviations or deficiencies relating to safety on the
job. <Insert Name or Job Title> has been designated as the Safety Officer for
<Company Name>.
Project Manager Responsibilities. Project Managers will be responsible for safety on
their respective projects. They will be expected to involve the Safety Officer at the
beginning of every project even before work has started. Project Managers will take
recommendations from and work with the Safety Officer to ensure the safety of
employees on the job.

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Supervisor Responsibilities. Company Supervisors are responsible for the daily

enforcement of the policies and procedures in the <Company Name> safety program.
They will be responsible for all aspects of employee safety in their respective areas.
They will conduct periodic safety meetings for their employees. Supervisors will
monitor the safety of employees on a daily basis and take the appropriate actions to
correct any deviations or deficiencies relating to safety on the job. Supervisors will be
attentive to employee safety concerns and report them to the Safety Officer. They will
keep in communication with the Safety Officer to ensure all employees receive
training, refresher training, or retraining as needed.
Employee Responsibilities. Employees are the first lines of defense as it pertains to
safety at all <Company Name> jobsites. Employees are expected to abide by all of the
safety policies and procedures in the company safety program. They will be held
responsible for their own safety and are expected to report unsafe conditions to their
Supervisors immediately. If the Supervisor is unavailable, they will report safety
violations or concerns to the Company Owner or Safety Officer. Employees, if feasible,
are also expected to correct safety violations within their immediate areas. They will
ensure they report to work in a state of readiness, with the appropriate clothing, and
with all issued personal protective equipment. Employees will only operate equipment
on which they have been trained and authorized to use. They will report accidents,
injuries, and near misses immediately to their Supervisor.

4. JOB SAFETY PLANNING AND ANALYSIS.

Pre-Construction. <Company Name> is dedicated to ensuring the safety of all
employees. For this reason, safety is considered even before contracts are awarded.
The Safety Officer will be involved throughout the bid process to ensure that special
tasks or procedures requiring additional safety precautions are identified as soon as
practicable. In addition, once the contract has been awarded and before the project
begins, a pre-construction safety meeting should be held with the Prime or General
Contractor, Subcontractors, and other applicable parties to discuss the following:
4.1.1. Safety Management specifics and controls.
4.1.2. Subcontractor requirements.
4.1.3. Job hazard analysis.
4.1.4. Special safety equipment, tools, hazards, or methods that will help in
completing the job efficiently and safely.
4.1.5. Safety Training and Orientation.
4.1.6. Job-site safety inspections.
Job Safety (Hazard) Analysis. Job hazard analysis is to be used to make a habit of safe
work practices. It is also beneficial as a guideline to follow during new employee
training efforts and for quickly identifying the cause of an accident should one occur.
Each analysis should be periodically reviewed for possible improvements. All

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supervisors will be familiar with the proper completion of a Job Safety (Hazard)
Analysis. The following basic steps should be followed in preparation of a job hazard
analysis:
4.2.1. Select the jobs or specific tasks for hazard analysis.
4.2.2. Consider the task to be performed and inspect the area(s) to identify potential
hazards.
4.2.3. Break the job or task into individual components or activities.
4.2.4. Identify the hazards associated with each component activity (ex. Falls, electric
shock, chemical exposure, cuts, etc.).
4.2.5. Identify what procedures or equipment are needed to perform each
component activity safely (ex. Ladders, scissor lifts, personal protective
equipment, etc.).
4.2.6. Apply the analysis to the job.

5. ROUTINE SAFETY AND HEALTH INSPECTIONS.

Routine safety and health inspections of all job sites will be conducted as necessary by the
Safety Officer or designated individual. The inspection will be conducted to discover
conditions and work practices that may lead to job accidents and industrial illnesses, through
specific, methodical auditing, checking, or inspection procedures.
Inspection elements. The following inspection elements will be checked during safety
inspections.
5.1.1. Floors Condition, slip, trip, falls
5.1.2. Aisles Marking, obstructions
5.1.3. Stairs Condition, railings, obstructions
5.1.4. Ladders Condition, Metal in electrical areas
5.1.5. Exits Obstructions, locked, lighted
5.1.6. Ventilation Adequate, fans guarded, maintained
5.1.7. Hand tools Grounded, guarded, pressure switches
5.1.8. Chemicals SDS's, labels, storage, separated
5.1.9. Compressed gas Storage, heat sources, labels, training
5.1.10. Guarding Installed, over, under, around, between
5.1.11. Lockout Tagout Procedures, training, devices, tags
5.1.12. Eye protection Used, training, Z-87 rated protectors
5.1.13. Fire protection Extinguishers, training, locations
5.1.14. First Aid Kits, OSHA logs, training

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5.1.15. Confined Spaces Marked, training, ventilation, equipment

5.1.16. Work practices Unsafe work practices observed? (list)
Inspection report. The Safety Officer will provide a safety report based on the
inspection items noted during the inspection to the appropriate supervisor.

6. SAFETY MEETINGS.
A well-ordered flow of information is essential to a good safety program. The company,
through a program of safety meetings at all levels, intends to accomplish the goals of safety
awareness, education, and participation.
We are committed to efficient and quality training that increases safety awareness
amongst all employees.
Safety meetings for employees will be held on a regular basis to demonstrate
management's commitment to accident prevention. Possible agenda items include
but are not limited to the review of accidents, safety education, safety inspections,
elimination of workplace hazards, new methods of improving job performance,
employee training, personal protective equipment, safety incentives, hazard
communication, lockout/tagout, respiratory protection, fall protection, and other
safety policies.
It is vital to this Workplace Safety Program that all safety training and meetings be
carefully documented. Written records of all safety meetings are the responsibility of
the Supervisor(s). Training activities are the responsibility of the Safety Officer.

7. HAZARD REPORTING.
All employees are required to report potential or known hazards immediately upon
identification. If possible, the hazard should be eliminated immediately when found.
Otherwise, the immediate supervisor must be notified and all work where employees are
exposed to the hazard must be discontinued until the hazard has been removed.

8. FIRST AID PROCEDURES.

Serious Injuries. Supervisors will be responsible to ensure all employees report serious
accidents or injuries immediately to the Safety Officer. Where employees require
professional medical attention, the Supervisor will accompany the employee to the
hospital or clinic and observe the employees condition and status. The supervisor will
report directly to the Safety Officer the condition of the employee and ensure that
proper accident investigation procedures are followed.
Minor injuries. Minor injuries, such as cuts, scratches, bruises, and burns that do not
require a doctor’s treatment, may be handled by the employee at the jobsite.
Recurring first aid injuries will be reported to the Safety Officer to ensure they do not
become serious.

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First Aid Kits. First aid kits will be maintained at each jobsite by the Supervisor. All
employees will be made aware of the location and availability of the first aid kit. The
type of first aid kit to be maintained will be for minor emergencies such as cuts and
skin abrasions.

9. ACCIDENT INVESTIGATION.
Accident investigation is primarily a fact-finding procedure; the facts revealed are used to
prevent recurrences of similar accidents. The focus of accident investigation will be to
prevent future accidents and injuries to increase the safety and health of all our employees.
Immediate concerns.
9.1.1. Ensure any injured person receives proper care.
9.1.2. Ensure co-workers and personnel working with similar equipment or in similar
jobs are aware of the situation. This is to ensure that procedural problems or
defects in certain models of equipment do not exist.
9.1.3. Start the investigation promptly.
Accident Investigation Form. An investigation form which details specific company
requirements for investigation will be used to gather data to determine causes and
corrective actions. As a minimum the form will contain the following areas of concern.
9.2.1. Accident investigation form data.
- Injured employee's name
- Date and time of injury
- Occupation or task being performed when injured
- Employee's address
- Sex/age/DOB
- Social security number
- Length of service
- Length of time at specific job
- Time shift started
- Overtime length when injury occurred
- Physician's and hospital name (if transported)
- Type of injury
- Resulting fatalities
- Description and analysis of accident
- Action taken to prevent recurrence and person
- Employee's statement
- Witnesses' statement
- Person completing form and date
- Person reviewing form and date
Supervisors are responsible for ensuring that employees follow safe work practices and
receive appropriate training to enable them to do this. Supervisors will be responsible

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to fill out accident reporting/investigation requirement forms and to reinforce the

<Company Name> safety program.

10. GENERAL SAFETY RULES FOR ALL EMPLOYEES.

The following safety rules are established by this company as general safety rules for all
Employees.
Never operate any machine or equipment unless you are authorized and trained to do
so.
Do not operate defective equipment. Do not use broken hand tools. Report them to
your supervisor immediately.
Never start on any hazardous job without being completely familiar with the safety
techniques which apply to it. Check with your supervisor if in doubt.
Make sure all safety attachments are in place and properly adjusted before operating
any machine.
Do not operate any machine or equipment at unsafe speeds. Shut off equipment
which is not in use.
Wear all protective garments and equipment necessary to be safe on the job. Wear
proper shoes. Sandals or other open-toed or thin-soled shoes should not be worn.
Do not wear loose, flowing clothing or long hair while operating moving machinery.
Never repair or adjust any machine or equipment unless you are specifically authorized
to do so by your foreman.
Never oil, clean, repair, or adjust any machine while it is in motion.
Never repair or adjust any electrically driven machine without opening and properly
tagging the main switch.
Put tools and equipment away when they are not in use.
Do not lift items which are too bulky or too heavy to be handled by one person. Ask
for assistance.
Keep all aisles, stairways, and exits clear of skids, boxes, air hoses, equipment, and
spillage.
Do not place equipment and materials so as to block emergency exit routes, fire boxes,
sprinkler shutoffs, machine or electrical control panels, or fire extinguishers.
Stack all materials neatly and make sure piles are stable.
Keep your work area, machinery and all company facilities which you use clean and
neat.
Do not participate in horseplay, or tease or otherwise distract fellow workers.

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Power-truck operators must safeguard other workers at all times; workers must show
courtesy to power-truck operators.
Floor mounted extension cords should be placed so that they are flush to the ground
at all times.
Frayed or damaged electrical cords should be replaced.
Never take chances. If you're unsure, you’re unsafe!
Ask for help, if needed.

11. FIRE PREVENTION AND PROTECTION.

Fire and explosion pose a serious risk to our employees during operations involving open
flames or high heat sources such as the use of propane or electric torches. Flames can be
produced which could quickly become uncontrollable under certain situations. For this
reason, all employees will be trained in these procedures:
Basic safety precautions. Heat, open flame, or any operations where sparks may be
produced will be permitted only in areas that are or have been made fire safe. When
work cannot be moved practically, as in most construction work, the area will be made
safe by removing combustibles or protecting combustibles from ignition sources.
Fire extinguishers. Suitable fire extinguishing equipment will be maintained in a state
of readiness for instant use. Such equipment may consist of hose or portable
extinguishers depending upon the nature and quantity of the combustible material
exposed. Employees will not use portable fire extinguishers unless they have been
trained.
Housekeeping. All employees will be familiar with the Housekeeping Program and
will follow all applicable requirements as stated therein to ensure that flammable or
combustible materials do not accumulate in the work area.
Chemical Storage. <Company Name> will ensure that proper storage locations are
provided to employees using chemicals. Flammable chemicals will be stored in
approved locations or flammable liquids cabinets designed in accordance with 29 CFR
1910.106. Toxic and corrosive chemicals will be stored apart from flammable
chemicals and will be further segregated according to acidity and/or alkalinity. All
chemical storage location will be approved by the Safety Officer before use.
Authorization. Employees performing heat or open flame operations must obtain
authorization from their Supervisor. Where required, employees will fill out a Hot
Work permit.

12. EVACUATION PROCEDURES.

All employees upon receipt of an evacuation order will exit the work area via the Nearest
Unaffected Exit. They will proceed to the designated evacuation muster point for the area
they were in at the time of the evacuation order, quickly and quietly. They will also upon
request, aid their supervisor in taking role or by being a runner.

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Egress Routes. All employees will become familiar with the location of all posted
egress routes of the facility areas that they frequent and will know the primary and
secondary egress routes of their work area.
Evacuation Muster Points. All employees will become familiar with the marked
evacuation muster points and will know the primary evacuation muster point of the
facility areas that they frequent and for their work area. NO ONE WILL LEAVE AN
EVACUATION MUSTER POINT WITHOUT THE EXPRESS PERMISSION OF THE SENIOR
EMPLOYEE PRESENT.
Severe Weather Safe Spots. All employees will become familiar with posted Severe
Weather Safe Spots, and will know the location of the nearest Severe Weather Safe
Spot for the areas that they frequent and their work area. Upon the announcement of
severe weather, proceed to the designated safe spot.
Arrival Actions. Upon arrival at an evacuation muster point, each employee will seek
out the senior employee present to assure that they have been accounted for. They
will also, upon request, aid area supervisors or managers in taking a role or by being a
runner.
Visitor Escorts. Each visitor at the facility must be escorted at all times throughout the
facility or jobsite by a company employee. The escort will ensure their visitor is
escorted to an evacuation muster point or safe spot as required. Upon arrival at an
evacuation muster point, the visitor's name will be forwarded to the employee in
charge at the evacuation muster point.

13. RECORDKEEPING REQUIREMENTS.

<Company Name> 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. Records will be established on a calendar year
basis.
<Company Name> will report to OSHA, as required by 29 CFR 1904.39, all fatalities,
hospitalizations, amputations, and losses of an eye as a result of work-related
incidents. Incidents that will be reported to the nearest OSHA Area Office include:
13.1.1. Fatalities within eight hours after the occurrence to one or more employees,
and
13.1.2. Within 24 hours of learning of any incident which results in hospitalization,
amputation, or loss of an eye of an employee.
Log and summary of occupational injuries and illnesses. This employer will:
13.2.1. Maintain a log and summary of all recordable occupational injuries and
illnesses by calendar year.
13.2.2. Enter each recordable injury and illness on the log and summary as early as
practicable but no later than 7 working days after receiving information that a

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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 will be completed in the
detail provided in the form and instructions on form OSHA No. 300.
Supplementary record. In addition to the log of occupational injuries and illnesses
(OSHA 300) <Company Name> will have available for inspection at each of our facilities
within 7 working days after receiving information that a recordable case has occurred,
a supplementary record for each occupational injury or illness for that establishment.
The record will 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 no
acceptable alternative record is maintained for other purposes, Form OSHA No. 301
will be used or the necessary information will be otherwise maintained.
Annual summary. <Company Name> will post an annual summary of occupational
injuries and illnesses for each facility under our control. This summary will consist of a
copy of the year's totals from the form OSHA No. 300A and the following information
from that form:
13.4.1. Calendar year covered.
13.4.2. Company Name and establishment address.
13.4.3. Certification signature, title, and date.
13.4.4. A form OSHA No. 300A will be used in presenting the summary. If no injuries
or illnesses occurred in the year, zeros will be entered on the totals line, and
the form posted.
13.4.5. The summary will be completed by February 1 of each calendar year. This
company, or the officer or employee of <Company Name> who supervises the
preparation of the log and summary of occupational injuries and illnesses, will
certify that the annual summary of occupational injuries and illnesses is true
and complete. The certification will be accomplished by affixing the signature
of the employer, or the officer or employer who supervises the preparation of
the annual summary of occupational injuries and illnesses, at the bottom of
the last page of the summary.
13.4.6. <Company Name> will post a copy of the establishment's summary in each
facility. The summary covering the previous calendar year will be posted no
later than February 1, and will 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 will 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. (NOTE: For multi-establishment employers

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where operations have closed down in some establishments during the

calendar year, it will not be necessary to post summaries for those
establishments).
Records retention. Records will be retained for 5 years following the end of the year
to which they relate.

14. DISCIPLINARY ACTIONS FOR WILLFUL UNSAFE ACTS.

Employee safety is paramount at <Company Name>. The willful commitment of an unsafe
act cannot be condoned. Employees who willfully jeopardize their own or coworkers’ safety
will be disciplined. The type of discipline can range from a verbal warning to dismissal. The
Safety Officer, and supervisory personnel in the administrative chain of any employee may
give employees a verbal warning for a known unsafe act or procedural, or operational
infraction. Disciplinary action other than a release from shift without pay must be reviewed
by the company Owner.
Forms of discipline.
14.1.1. Verbal warning. The company Safety Officer, and supervisory personnel in the
administrative chain of any employee may give employees a verbal warning
for a known unsafe act or procedural, or operational infraction. A second
verbal warning in the same shift will be grounds for release from the current
work shift without pay. The immediate supervisor will be consulted in all cases
and will make the determination for release.
14.1.2. Written warning. A written warning will be issued automatically for a second
verbal warning for an unsafe act. The written warning will become part of the
employee’s permanent personnel record.
14.1.3. Retraining. It must be considered that the possibility exists that lack of proper
training may be a cause of any unsafe act. Supervisors will review the need
for employee remedial training in their job skill to enable them to better
accomplish their jobs.
14.1.4. Dismissal hearing. The employee concerned will be notified of his or her rights
in advance of termination. The option of dismissal will be reviewed by the
company Owner before termination. The immediate supervisor will be
consulted to determine if a lesser form of discipline is warranted. The
employees' rebuttal (if provided) will be considered along with the severity of
the act, the supervisor’s recommendation and any other supporting
information provided at the time of the time of the hearing.

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