dcm-ma-rh-01-a hse program©visions 2012/mars... · web view2019. 10. 8. · 2. health, safety...

HEALTH, SAFETY AND ENVIRONMENTAL PROGRAM

Revision: 10Issued: February 3, 2012Revised by: Marc Charbonneau

Approved by: Date:Richard Gadoury Vice-President, Human Resources and HSE

DCM-MA-RH-01 Revision 10

HEALTH, SAFETY AND ENVIRONMENT PROGRAM

TABLE OF CONTENTS

1.0 CORPORATE VISION – HEALTH, SAFETY AND ENVIRONMENT............5

1.1 Corporate objectives.................................................................................................5

1.2 Legislation requirements.........................................................................................5

1.3 Due diligence............................................................................................................5

2.0 POLICIES....................................................................................................................6

2.1 Health and Safety policy..........................................................................................6

2.2 Environmental policy...............................................................................................7

2.3 Harassment and discrimination policy...................................................................8

2.4 Drug and alcohol policy..........................................................................................9

2.5 Personal Protective Equipment policy..................................................................10

2.6 Preventive maintenance program policy...............................................................11

2.7 Health and Safety training policy.........................................................................12

2.8 Inspection policy....................................................................................................13

2.9 Investigation policy................................................................................................14

3.0 RESPONSABILITIES..............................................................................................15

3.1 Management responsibilities.................................................................................15

3.2 Project Managers responsibilities.........................................................................15

3.3 Site Supervisor’s responsibilities...........................................................................16

3.4 Site Safety Personnel responsibilities....................................................................16

3.5 Employees responsibilities.....................................................................................17

3.6 Subcontractors responsibilities..............................................................................17

4.0 WORKPLACE HAZARD ASSESSMENT AND CONTROL..............................18

4.1 Company’s general hazard assessment.................................................................18

4.2 Codes of practice and safe work practices............................................................18

4.3 Project hazard assessment.....................................................................................19

4.4 Job Hazard Assessment (JHA)..............................................................................19

4.5 Field Level Hazard Assessment (FLHA)..............................................................19

5.0 CORPORATE HSE RULES AND STANDARDS.................................................20

5.1 Incident management procedure...........................................................................20

5.1.1 Modified work program...................................................................................205.2 Records, reporting and statistics...........................................................................21

DCM-MA-RH-01-A Revision 102 of 32

HEALTH, SAFETY AND ENVIRONMENT PROGRAM5.3 Inspection and audit..............................................................................................23

5.4 Behavior Management..........................................................................................24

5.4.1 Discipline.........................................................................................................245.4.2 Recognition......................................................................................................245.4.3 Observation Program......................................................................................255.5 Training..............................................................................................................25

5.6 Communication......................................................................................................26

5.6.1 Safety meetings................................................................................................275.6.2 Information board...........................................................................................275.6.3 Orientation.......................................................................................................27

5.7 Right to refuse work...............................................................................................27

5.8 WHMIS..................................................................................................................28

5.9 Equipment procurement, maintenance and inspection........................................28

5.10 Drug and alcohol policy application guide.........................................................29

5.11 Employee assistance program.............................................................................30

5.12 Environmental program......................................................................................30

6.0 EMERGENCY PREPAREDNESS, FIRE PROTECTION AND FIRST AID. . .30

6.1 Emergency services................................................................................................30

6.2 Fire protection........................................................................................................31

6.3 First aid..................................................................................................................31



APPENDIX A – FORMS

- DCM-FO-SS-01-A Fitness for Work Physician Assessment

- DCM-FO-SS-02-A Statement

- DCM-FO-SS-03-A Incident Report

- DCM-FO-SS-04-A Modified Work Offer

- DCM-FO-SS-05-A HSE Audit Checklist

- DCM-FO-SS-06-B Pause SSE hebdo / Weekly HSE Meeting

- DCM-FO-SS-07-A Safety Inspection on Site

- DCM-FO-SS-08-A Lock-out/Tag-out Log

- DCM-FO-SS-09-B Pause santé-sécurité quotidienne / Daily Tool Box Talk

- DCM-FO-SS-10-A Workers Orientation on Site

- DCM-FO-SS-11-A FLHA

- DCM-FO-SS-12-A Respirator Fit Test Medical Evaluation

- DCM-FO-SS-13-A Energized Equipment Hazard Assessment

- DCM-FO-SS-14-A Calibration Report – Report Detector

- DCM-FO-SS-15-A Respirator Fit Test

- DCM-FO-SS-16-A Tools Inspection

- DCM-FO-SS-17-A Confined Space Hazard Assessment

- DCM-FO-SS-18-A Job Hazard Assessment (JHA)

- DCM-FO-SS-20-A Work Site Hazard Assessment

- DCM-FO-SS-21-A Site Emergency Response Plan

- DCM-FO-RH-04-A Disciplinary Warning

- DCM-FO-OU-02-A Light Vehicle Inspection Sheet

- DCM-FO-OU-04-A Daily Pre-op Checklist – Forklift – Zoomboom – Aerial Platform

Scaffold Inspection Tag (yellow and red)

APPENDIX B – GENERAL HAZARD ASSESSMENT

APPENDIX C – JOB HAZARD ASSESSMENT (JHA) LIST

APPENDIX D – SAFE WORK PRACTICES LIST



1.0 CORPORATE VISION – HEALTH, SAFETY AND ENVIRONMENT

1.1 Corporate objectives

The Health, Safety and Environment Program (HSE Program) primarily objective is to eliminate, at the very source, any dangers regarding health, safety and security towards workers on our job site and the potential threat to the environment.

Nothing is more important to DCM Inc. than ensuring that applicable and effective measures are taken to protect health and security of its employees, customers, subcontractors and the employees of subcontractors.

Our HSE Program is a complete management system for health and safety mainly based on preventing accident. This includes, eliminating risk where possible and practicable, effectively controlling risk, management commitment, training, communication, ethical investigation process, incident management and an inspection program.

Safety needs to be everyone’s first priority. The owners, the management, the site supervisors, our safety team and all of our employees oversee the application of this HSE Program.

1.2 Legislation requirements

The content of this HSE Program is equal to or exceeds the requirements of occupational health and safety regulations and the specifications of every contract.

Our workers, subcontractors, suppliers, visitors and Management employees will follow legal requirements on all our work sites and company properties.

Copies of applicable legislation will be available and readily available to all workers on all work sites.

The management is committed, to learning and implementing the prime contractor safety program where applicable.

1.3 Due diligence

Our HSE Program is continuously evaluated and improved for maintaining adequate and efficient policies and procedures. Those policies and procedures are monitored, communicated (through information awareness processes and training) and audited on a regular basis. Our Company strongly believes it meets the due diligence and legal requirements.

We will make sure every employee is working in a safe environment. That all workers are qualified to perform their task, have the proper tools and is trained to effectively complete their tasks to meet the standard set by our company.



2.0 POLICIES

2.1 Health and Safety policy

*The information in this policy does not take precedence over applicable government legislation for which all workers should be familiar.



2.2 Environmental policy




2.3 Harassment and discrimination policy




2.4 Drug and alcohol policy




2.5 Personal Protective Equipment policy




2.6 Preventive maintenance program policy




2.7 Health and Safety training policy




2.8 Inspection policy




2.9 Investigation policy




3.0 RESPONSABILITIES

3.1 Management responsibilities

Management at DCM agrees to take the necessary steps to ensure the health and safety towards workers on construction sites. To do so, management will:

Establish a continual improvement process to meet the zero accident goal;

Ensure policies, practices and procedures are reviewed annually;

Anticipate the health and safety needs for each project during the work planning phase;

Audit ongoing projects on a regular basis;

Measure the organization and projects HSE performance;

Make sure the workers know about the inherent risks of their tasks and will take time to train its workers;

Supply the safest tools and equipments, in good condition and in sufficient number;

Promote health and safety at work;

Make sure that every incident on site will be investigated;

Implement and follow a return to work policy to minimize human cost following incident.

3.2 Project Managers responsibilities

The Project Manager, as the official Company’s representative, is responsible to implement and apply our HSE Program. To do so, the project manager will:

Ensure all established Health and Safety requirements are administered and enforced;

Ensure all new workers on job sites are informed and trained on our Safety rules, specific site safety requirements and potential hazard;

Participate in Project Health and Safety Committees;

Ensure workers are informed on ongoing new hazards, rules and regulations;

Ensure tools and equipments brought on site allows to perform work safely;

Communicate to the Prime Contractor or the owner any issue related to safety.



3.3 Site Supervisor’s responsibilities

Plan safe work practices, (pre-job, JHA, FLHA). Revise, approve, implement and maintain it;

Apply corrective actions;

Apply disciplinary measures when required;

Participate and lead the incident investigation process;

Do inspections of the job site as required and document it;

Lead by example, respect safety rules at all time;

Lead weekly safety meetings;

Plan and follow our site emergency plan.

3.4 Site Safety Personnel responsibilities

Assist site supervisors implementing and applying our HSE Program. To do so:

Inspect the job site on a daily basis;

Responsible for the daily administration of the HSE Program;

Assist Project Supervision to investigate incidents and to prepare incident reports;

Participate in project hazard assessment and job hazard analysis;

Assist Project Supervision in preparing and presenting Safety Meetings;

Establish inspection and audit schedule;

Update the incident log and maintain various inspection logs;

Manage documentation concerning safety. Ensure that pertinent reports are submitted as required;

Maintain current knowledge of health and safety literature, legislation, and Codes of practice. Post all Health and Safety information;

Manage site specific safety training and educate where required all personnel on safety protocols.



3.5 Employees responsibilities

Workers must;

Respect the provisions of the law;

Understand and comply with the HSE Program;

Take the necessary measures to protect their health and bodily security;

Be careful not to endanger the health, safety or bodily security of other persons at or near the work sites;

Undergo the health exams required under the occupational health and safety laws and regulations;

Remain sober while at work and fit for duty. Working while under the influence of alcohol or drugs is strictly prohibited;

Cooperate with any person in charge of applying safety regulations;

Report any hazard on the construction site;

Report any injury, no matter how minor, to the foreman;

Attend safety meetings;

Wear personal protective equipment when necessary.

3.6 Subcontractors responsibilities

Subcontractors must:

Design a program to prevent work-related illnesses and injuries based on the type of work to be performed;

Provide their employees with the training and supervision necessary to perform their work safely;

Hold safety meetings with their employees or make them participate to DCM safety meetings;

Ensure the application of DCM and customer safety programs and the respect of occupational health and safety laws and regulations;

Comply with DCM Subcontractors Management Program (DCM-PG-SS-02-A).



4.0 WORKPLACE HAZARD ASSESSMENT AND CONTROL

4.1 Company’s general hazard assessment

General hazards have been evaluated for all company’s activities to control and eliminate them (see appendix B).

List of general hazard assessment

Hazard assessment1 Electrical work2 Instrumentation work3 Piping work4 Welding5 Insulation work6 Scaffolding work

4.2 Codes of practice and safe work practices

Our general hazard assessment process have identified and upraise high risk special task requiring to follow strict methods of work define in Codes of practice (see appendix E).

List of Codes of practice

Document No. Name

DCM-PR-SS-01-A Lock out and tag out

DCM-PR-SS-02-A Work in high and medium voltage

DCM-PR-SS-03-A Work on energized equipment

DCM-PR-SS-04-A Respiratory protection program

DCM-PR-SS-06-A Work in confined spaces

DCM-PR-SS-08-A Fall protection plan

DCM-PR-SS-09-A Asbestos

DCM-PR-SS-10-A Noise

DCM-PR-SS-12-A Behaviour based safety

Our hazard assessment process leads as well to specific hazard evaluation for task performed or tools used by our employees. Safe work practices have been developed to give direction and instruction to eliminate the applicable risks (see appendix D for the list of Safe work practices).



4.3 Project hazard assessment

For every project starting, a risk assessment is conducted involving the Corporate Safety Manager and the Project supervision team (Form DCM-FO-SS-20-A). This assessment is aimed at defining and documenting a project specific HSE plan.

Employee’s orientation is adjusted to address site specific requirements and a HSE Management System is established and organized accordingly.

4.4 Job Hazard Assessment (JHA)

Before a project begins and during its course of action, specific tasks or activities lead to specific hazard, critical task, new task or high hazard for which individual and detailed evaluation is carried out.

The Job Hazard Assessment (JHA) and the code of practice process support these task evaluations to appropriately identify the hazards or potential hazards and the way to properly eliminate or control them.

The JHA form is used by the supervisor in collaboration with our safety staff to document these evaluations and inform our employees. JHA reflecting our standard activities are available to be used or adapted to specific task or hazard (see Appendix C for the list of JHA).

4.5 Field Level Hazard Assessment (FLHA)

Construction sites have daily specific hazards to be identified, evaluated and eliminated. The FLHA process has to be followed by all of our crew for each new activity and at least once a day (Form DCM-FO-SS-11-A).

At the beginning of the shift, each foreman prepares an FLHA form that identifies the scheduled task, the hazard and the way to avoid or minimize its repetition. Each employee has to participate in its review and sign the FLHA. At the beginning of the shift each worker goes out to the job site and looks around. As a group they must identify the hazards and write the controls down. The hierarchy of controls is the system used.



5.0 CORPORATE HSE RULES AND STANDARDS

5.1 Incident management procedure

Any incident including first aid, medical aid, near miss, environmental spill, vehicle incident and property damage needs to be investigated and documented.

A full collaboration has to be maintained with any OH&S Officer attending the investigation. All existing WCB requirements as per the act in the province of the incident will be maintained by the company claims manager.

5.1.1 Modified work program

DCM is committed to facilitating the early and safe return of employees to employment. Upon hiring, during the orientation process, all workers will be made



aware that they are expected to participate in the modified work program and that DCM will assist them in getting back to work.

When a worker suffers a work related injury, DCM will offer him or her a temporary work assignment that respects the physician’s recommendations (re: DCM-FO-SS-01-A) and will have the workers supervisor acknowledge and abide to those recommendations by signing the return to work form (Modified word offer (DCM-FO-SS-04-A).

DCM will make every reasonable effort to provide a safe, suitable, meaningful and productive employment environment to the injured employee. DCM will compile and update all required documents to track the injured worker’s progress.

The goals of the program are:

1. Enhance the physical and psychological recovery process for the injured workers by promoting the gradual restoration to the worker’s pre-accident level of employment.

2. Reduce medical, disability and lost time costs.

3. Minimize the chance of re-injury.

4. Encourage cooperation between employees and management.

Modified work includes any changes, restrictions or limitations to a worker’s regular job duties required as a result of a work-related injury. This includes changes in:

Tasks or functions – such as changes in the worker’s regular tasks including redesigning, reorganizing or eliminating tasks;

Hours or work schedules – such as changes in the number of hours, shift cycles, or volume of work;

Environment or work area – such as changes in the location or access to the work area, restrictions to avoid exposure to heat, cold or chemicals etc;

Equipment – such as changes to the equipment used;

The main goal is to offer modified duties mainly related to the worker’s pre-injury occupation and/or trade.

5.2 Records, reporting and statistics

Project Records

On a project basis, the following records need to be kept and sent to the head office as follows; Project Safety documentation is archived for 5 years.



Record On site filling Forward to Head OfficeWorkers Safety Training evidence X XOrientation form / exam X XSafety meeting minutes XHazard Assessment (JHA, FLHA, etc.) XInspection XIncident documentation X X

Every incident is kept in a log book on site.

Corporate records

All incident documentation is kept at the Corporate Safety department on a case basis, such as:

Investigation documentation;

Medical documentation;

WCB documentation.

A Corporate incident log book is kept up to date indicating the incident information such as;

Company;

Project;

Incident description;

Classification (first aid, medical aid, etc.);

Root Cause analysis.

Reporting

Any near miss or incident has to be reported to the immediate supervisors and documented.

Any recordable or potential recordable injury has to be verbally reported to the Corporate Safety Manager immediately.

Recordable injury has to be reported as following:

ReportingClassification Title 24 hours Monthly Quarterly YearlyLost time Operation Manager X

HR Vice-President XPresident X

Other recordables Operation Manager XHR Vice-President XPresident X



All incident documentation needs to be submitted to the Corporate Safety Manager.

Statistics

Information is compiled as per standard OSHA 301 (See DCM guide DCM-GU-RH-01) for each project and for the entire organization in a data base that allows us to generate various detailed reports. These statistics are reported quarterly to the Corporate and Project Management in a balance scorecard. Statistics are used as Key Performance Indicators and compared to the current identified objectives and targets, which are revised annually.

Statistics are calculated following those indicators:

Injury frequency rate = Accident cases x 200 000 Hours worked

Severity rate = Day Lost x 200 000 Hours worked

5.3 Inspection and audit

Work site HSE inspection matrix

Position Minimum requirementsPresident YearlyUpper management QuarterlyCorporate Safety manager MonthlyHighest level of project supervisor Week/ProjectForeman Daily/ongoing (non documented)

Audit

Each major project and the organization’s HSE Management System are regularly audited by Corporate Management to measure the application and the efficiency of our HSE Management System.

Activities audited FrequencyHSE Management system YearlyHSE safe job practices and procedures YearlyMajor projects Each project

The Corporate Safety Manager tracks and measures on a regular basis the organization and the projects in regards to laws, regulations, and corporate standards and clients requirements. Audits are documented as well as corrective actions.



5.4 Behavior Management

Knowing that a safe behavior from our employees is an essential element to obtain a safe workplace, DCM implements a Behavioral Management Program focuses on the following means to achieve his goals:

Discipline management

Recognition Program

Observation Program

5.4.1 Discipline

Adherence to DCM health and safety regulations being mandatory, any employee who does not respect them on a voluntarily manner is liable to disciplinary measures.

Depending on the seriousness of the gestures and on the incidence of the inadequate behaviours, the following rules must be applied:

Minor Incident

Example: Not wearing its safety goggles or hat1st incident: Verbal notice (this must be written on disciplinary sheet)2nd incident: Written notice3rd incident: Discharge or possible suspension with or without pay.

Serious Incident

Example: Not being tied-off when required 1st incident: Written notice2nd incident: Discharge

Voluntary compromising the life of another person or seriously injuring another person

1st incident: Discharge

Depending on the prime contractor some rules maybe as contractually agreed to and will override disciplinary actions. For example, zero tolerance rules or absolutes. The more stringent policy will apply where contractually obligated.

5.4.2 Recognition

Within the context of its projects, DCM implements programs that promote safe behaviours. Handing over gifts or having various draw events are ways to emphasize



safe behaviour from the employees for good performances regarding health and safety.

On certain project, safety bonus programs linked to the safety performance are established.

5.4.3 Observation Program

The company identifies and selects projects on which Observation Program will be implemented. Trained workers will conduct regularly scheduled observation and document it. Our Behavior Observation Program is based on trust and promotes positive and confidential feedback to coworker.

Observations are evaluated to identify improvement opportunities.

5.5 Training

All workers must have received adequate training that will allow them to perform their work safely. The supervisory staff will ensure that workers have the necessary qualifications to perform their duties.

In addition to knowledge of their duties, workers must receive special health and safety training. DCM Inc. provides the necessary training so that its workers are prepared to work safely.

Training records are maintained for each employee in a data base regarding their trades qualification, equipment operations and safety trainings. Copies of cards or certificates are kept in the employee records (project and head office). The corporate training log is documented with the according attendance sheets signed by each participant as well as copies of exams if applicable. Here is an example of some of the trainings that are provided and recorded.



Site specific or client specific training is monitored and documented on a project basis to meet the client’s expectations. Some client training could be recognized as equivalent to our own training.

5.6 Communication

DCM-MA-RH-01-A Revision 10

Training/J ob Title

Health and safety integration (DCM safety orientation) 2 X X X X X X X X X

OSSA orientation (Alberta) 2 X X X X X X X XFirst aid 16 3 * * * * * * * * *WHMIS (already included in ASP construction and CSTS Alberta) 1 X X X * * X XFall arrest protection 8 2 X X X

Confined space/gas detection (based on specific model of device) 4 * * X

Lock Out/Tag Out of energized equipment 2 X X X XAWP (less than 80 feet) 8 3 X X XAWP (more than 80 feet) 8 3 * * * Forklift Training 8 3 X X XBehavior Based Safety training 2 X X X X X

Safety leadership, module 1 (must be given in the first week of work ) 4 X X X XSafety leadership, module 2 (must be given in the first three months of work ) 4 X X X X

Safety leadership, module 3 4 X X X X



H2S, Nitrogen and radiation 2 * * * * *

Fire watch 2 X X X

Transportation dangerous goods 2 * * * * *

SABA / SCBA /Respiratory Protection Equipment 2 * * * * *

Asbestos 2 * * * * *

Respirator Fit Test and Pulmonary Function test (Spirometry) 2 N/A * * * * *

National Construction Safety Officer 128 *

AWP Trainer 16 3 *

Fall arrest protection trainer 16 3 *

Confined space trainer 16 3 *

Train the Trainer

Internal Health & Safety Training

Additional Development

Legend: X-mandatory *-optional

26 of 32


5.6.1 Safety meetings

All information regarding workplace health and safety must be given to the workers during daily or weekly toolbox meetings. Minutes of meeting are kept. Corrective actions are documented and a follow up is made to answer questions or comments raised by the employees.

5.6.2 Information board

As soon as a project starts, each trailer will have a health and safety information board that will show, amongst others, DCM’s HSE Program, safety data sheets, first-aid attendants name, a site map (when available), emergency numbers and any other relevant information.

5.6.3 Orientation

Newly hired workers will follow a general orientation presentation and receive a document entitled "Workers Orientation on Site – Health and Safety Policy of DCM" which they must read, answer the questionnaire and sign.

Newly hired workers are also given a copy of DCM HSE Orientation and rules which they are required to sign on before to start working. (Form DCM-FO-SS-10-A)

Afterward, each employee will be introduced to the members of his or her new work team and to the work site.

5.7 Right to refuse work

By application of the law, no worker shall carry out any work, on reasonable grounds, if he believes an imminent danger exists that will put at risk his health and safety or another person present on the work site.

All workers will be informed of their right upon orientation and of the following rules of application:

A worker who refuses to carry out work shall, as soon as possible, notify the employer of the refusal;

Upon notification, DCM supervisor staff will immediately investigate and take action, if required, to eliminate the danger;

The worker will be reassigned to another task and no other worker will be required to accomplish the dangerous work unless the danger has been eliminated or the danger does not exist for that other worker;

A written report will be prepared and given to the worker and his union representative (if applicable);


HEALTH, SAFETY AND ENVIRONMENT PROGRAM If the worker who receives the report agrees an imminent danger still exists, he

can file a complaint to an official OH&S staff member.

5.8 WHMIS

All workers must have received the necessary information about dangers associated with hazardous materials at the worksite as well as the Workplace Hazardous Materials Information System (WHMIS).

DCM will ensure that its workers are familiar with the hazardous products they are using.

The list of hazardous products and the safety data sheets for these products will be located in an area known by workers and accessible.

Hazardous products are stored in accordance with the manufacturer's instructions.

5.9 Equipment procurement, maintenance and inspection

Standards for procurement of equipment and tools are established by the purchasing and the Safety departments.

A maintenance schedule has been implemented to set the inspection standard of the most used and/or common equipment based on experience, manufacturer’s recommendation and regulation requirements.

Maintenance personal will be competent and acknowledgeable.

Type of equipment Type of inspection Schedule

Light VehiclesVisual inspectionFormal inspection by the userMechanical inspection and maintenance

DailyWeekly5000 km

Aerial platform Operator Formal inspectionMechanical inspection and maintenance

Before each use200hrs of operation

Ladders and stepladders Visual inspectionComplete inspection

Before each useWhen back from job site and before shipment

Electrical tool Visual inspectionComplete inspection

Before each useWhen back from job site and before shipment

Slings, shackles, chokers, lifting devices

Visual inspectionComplete inspection

Daily or before each useYearly

Fall arrest equipment Visual inspection Before each useYearly

Miscellaneous Complete inspection Before put to work



5.10 Drug and alcohol policy application guide

In order to implement and support the company drug and alcohol policy, the following measures and instructions are applicable to all company employees.

Drug testing

Pre-employment drug testing:

Based on the specific nature of certain projects or tasks at risks, pre-employment tests will be performed for all employees.For cause drug testing:

In reasonable suspicion where an employee is suspected to be under the influence of an illicit substance, DCM can request drug testing while respecting the Canadian Charter of Rights and Freedoms;

When a safety related incident occurs on the work site, post-incident/accident drug testing can be undertaken in those involved in the incident.

Random drug testing:Random testing is permitted for workers on work sites where critical tasks are performed. Unannounced screening may involve any member of a designated workforce selected on a random basis depending on substance abuse professional recommendations.

Follow-up drug testing:A worker who has tested positive for drugs or alcohol or who has voluntary come forward for confidential assistance may be subject to further testing for a designated period. This will be done on a case basis to ensure rehabilitation is being followed.

Steps of intervention on construction site when a worker has weakened faculties

On site Supervisor:

Handle the worker respectfully;

Take the appropriate measures to ensure health and safety of the worker, his peers and to avoid any accident to occur;

Clearly inform the worker that this behaviour is inappropriate and explain how this can affect the security of all the other workers on site;

Indicate the expected changes as well as the consequences: sobriety at work or disciplinary measures leading to dismissal;

Offer support and guide the worker towards an aid resource (employee assistance program or an intermediate intervener);

Evict the worker from the site for the remaining of the working shift;DCM-MA-RH-01-A Revision 1029 of 32

HEALTH, SAFETY AND ENVIRONMENT PROGRAM Inform the Safety or Human Resources Department.

Human Resources Department:

Evaluate the applicable sanctions to apply according to the progression steps of the disciplinary process*:

Give a verbal notice and guide the worker towards the employee assistance program. Proceed to the eviction of the employee from the construction site for the day;

Written notice;

Dismissal;

Aim to change the behaviour;

Establish a reasonable rehabilitation deadline if the worker suffers from a dependency problem.

* The disciplinary process is not a rule of absolute application. Thus, the employer reserves the right to apply immediate dismissal in case of a serious fault.

5.11 Employee assistance program

All our employees have access to the company or union assistance program.

5.12 Environmental program

In order to implement and support the company environmental policy, the following measures and instructions are applicable for all our activities;

A corporate environmental program (PG-EN-01) is implemented, maintained, evaluated and updated to reflect our environmental policy, our activities and our commitment has a corporate citizen;

Environment risks and method of controlling them are identified in every project hazard assessment and monitored through our HSE project specific plan and our various risk assessment during the course of those projects;

Employees are trained to address any potential environmental emergencies.

6.0 EMERGENCY PREPAREDNESS, FIRE PROTECTION AND FIRST AID

6.1 Emergency services

When a contract begins, the Site supervisor will have the accountability for emergency preparedness and to ensure that emergency response plans are in place. A generic site emergency response plan has been developed to help the Site supervisor



in implementing a response plan (Form DCM-FO-SS-21-A) . A more detailed plan can be elaborated on certain job sites.

Emergency information will be posted:

Telephone numbers for emergency services;

Site map or an evacuation plan.

Orientation:

Each worker knows where to locate the emergency tools such as first aid kits, emergency showers and fire extinguishers;

The meeting point and/ or, the muster point, in case of an evacuation, must be known by all workers.

Emergency evacuation:

A list of the employees is readily available in order to make a roll call and ensure all the workers are present.

Emergency plan testing:

The emergency plan will be tested regularly for training purposes as well as for testing its efficiency Modification will be done as requested. These drills will be recorded and kept for key performance measuring.

6.2 Fire protection

Fire extinguishers, inspected on a regular basis, will be available in each trailer near the doors, in the store, in each vehicle and near all tasks that could present a fire hazard. Inspections are done monthly and a yearly inspection is required as per NFPA codes.

6.3 First aid

DCM Inc. has trained many of its workers to provide first aid in the event of an accident.

We will ensure that the number of first-aid attendants on site respects the number required under first response and OH&S regulations.

At any time, our first-aid attendants are dispatched on the different sites where we work to ensure maximum safety for the workers.



Specific work requires mandatory First aid attendants:

Manhole work; High voltage work.

A first aid kit will be located in the company's construction site trailer and will contain at least the minimum supplies listed by first response regulations and needs identified in the emergency response plan. The site supervisor will check the kit on a regular basis and purchase any missing material.

First aid kits are also available in the company trucks.



APPENDIX A - FORMS


APPENDIX B – GENERAL HAZARD ASSESSMENT

HSE PROGRAMELECTRICAL WORK

HOW AND WHEN TO IMPLEMENT MEASURESNO. ELEMENTS HAZARDS IDENTIFIED SPECIFIC SAFETY MEASURES

(SOURCES) (NEEDS IDENTIFIED) INSPECTION / FOLLOW-UP

1 Handling of heavy parts: transformers, apparatus, etc.

Crushing of limbs: fingers, feetSprainsBlowsBack injuries

- Personal protective equipment; hard hats, gloves, shoes, levers, cables, hand winch, hoisting apparatus. Signalman, method (if required)- Teamwork

The foreman must, at each operation, inform the team, establish an action plan, name a person to direct, stop (pause) as necessary during the operation to inspect.

2 Threader use Danger of getting caught, electrocution, fall by slipping, falling at ground level

- Place threader in proper location, avoid loose-fitting clothes, wear eye protectors and gloves, and check grounding. - Ensure that there is no oil on the ground or pipe cuttings.

The foreman and the users must, each time they use the threader, make sure the elements mentioned in the safety measures section are respected. An inspection must be conducted as often as necessary.

3 Installing cable trays Danger of falling, injuries to eyes and hands

- Personal protective equipment: hard hats, gloves, safety glasses, shoes, safety harness.

The foreman and the users must ensure they wear the appropriate personal protective equipment daily. Ensure these measures are met when work begins.

4 Installing cable reel and pulleys for cable pulling

Crushing, sprain, hand injuries, falling objects

- Personal protective equipment: hard hats, gloves, protective glasses, shoes, hazard signs. Stepladder of correct size.

The foreman and the users must ensure they wear the appropriate personal protective equipment. Ensure these measures are met when work begins.

5 Cable pulling Hand injuries, sprain, back injuries - Personal protective equipment: hard hats, gloves, protective glasses, shoes. Enough team members to avoid overexertion. Rotate tasks.

- Tugger, pulley and roller system to reduce the effort.

Written work method if required.The foreman and the users must ensure they wear the appropriate personal protective equipment daily. Ensure these measures are met when work begins.

6 Cable termination Hand and eye injuries, electrocution - Personal protective equipment: hard hats, gloves, protective glasses and insulated gloves if working with an energized panel.

The foreman and the users must ensure they wear the appropriate personal protective equipment daily. Ensure these measures are met when work begins.

7 Work on energized equipment Electric shocks - Follow the lock-out/tag out policy.- Work method.- Appropriate personal protective equipment such as: face shield, clothes covering body and hands.

The foreman and the users must make sure the safety measures are respected before work begins.

8 Electrical heat tracing cable installation

Electric shocksCut, skin puncture

- LOTO if applicable- Wear high-wrist leather gloves

LOTO procedureGloves purchasing standards

HSE PROGRAM

ELECTRICAL WORK

HOW AND WHEN TO IMPLEMENT MEASURESNO. ELEMENTS HAZARDS IDENTIFIED SPECIFIC SAFETY MEASURES

(SOURCES) (NEEDS IDENTIFIED) INSPECTION / FOLLOW-UP9 Electrical cords Electrocution

ShocksFireFalling

- All extension cords must be grounded and suspended 8 feet from the ground or along the walls.- Must be explosion proof in hazardous area.- Disconnect when not in use.- Maintain in good working order.

Each user must make sure to regularly check the extension cords and have them check too. Unplug the extension cords after use.

10 Electric tools and equipment ElectrocutionCutsEye injuries

- All tools and equipment must be grounded or provided with double insulation.- Wear safety glasses, face shield and gloves when using power saws, grinders and press drill. Gloves and safety glasses for threaders.- Ensure that all tools are in good working order.- Remove defective tools from the construction site.- Face shield for overhead power tool use or respiratory protection for overhead concrete drilling.

The contractor and the storekeeper are in charge of verifying, before use, the electric tools and equipment.

11 Lift trucks CrushingTrapping

- Move loads close to the ground, slowly and with a signalman when necessary.- Must be operated by a qualified person.

The foreman must ensure, upon arrival and regularly afterwards, that the person operating the equipment has the required qualifications in accordance with the standards.

12 Cisor-lift and Manlift FallingOverturningElectrocution

- Delimit the work zone.- Must be secured to the manlift.- Respect the maximum load.- Drive slowly on the construction site.- Must be level with the cisor-lift.- Make sure not to jam the extension cords used. - Close the railings.- Keep at a distance from electrical lines.

The foreman and each user, upon arrival of the equipment on site and before each use, must make sure that an equipment inspection be done, that the user holds the required qualifications to operate the equipment and that there is no falling hazard.

13 Cranes Broken cablesOverturningDropped load

- Ensure that all hoisting equipment meets requirements upon arrival at the worksite, under section 2.15.6 in its entirety.- Signalman when necessary.- Delimit and close surrounding zone.- Use slings that are in good condition.- Signalman should be clearly identified (with visible attire)

The owner and the operator must ensure, upon arrival at the site and every day, that an inspection has been conducted and they must verify the log book. The crane must be operated by a person that has the necessary qualifications in accordance with the standards, and supervision of the operation and of positioning must be done.

14 Ladders and stepladders Falling - All ladders and/or stepladders must comply with the standard (class 1).- Do not step on the last rung.- Place according to the type of work.- Fasten the ladders.- Rest it on a firm and even footing.- Must exceed the landing to be reached by one meter.- Stepladder must be completely open.- Ladders must be tied off.- Use the 4 : 1 rule.

The foreman and the users must, when work begins, plan for correctly sized ladders and stepladders and always monitor their condition and use.

15 Temporary electrical installations

ElectrocutionBurnsFire

- Installations that comply with electrical standards, by qualified persons using quality material.

The foreman and the workers must verify the electrical material that arrives on site, by doing regular rounds and during use. Any anomaly or defect must immediately be reported and corrected by a qualified person.

HSE PROGRAM

INSTRUMENTATION WORK

HOW AND WHEN TO IMPLEMENT MEASURES

NO. ELEMENTS HAZARDS IDENTIFIED SPECIFIC SAFETY MEASURES(SOURCES) (NEEDS IDENTIFIED) INSPECTION / FOLLOW-UP

1 Heavy parts handling Crushing of limbs: fingers, feetSprainsBlowsBack injuries

- Personal protective equipment: hard hats, gloves, shoes, levers, cables, hand winch, hoisting apparatus. Signalman, method or process.- Teamwork

The foreman must, at each operation, inform the team, establish an action plan, name a person to direct, stop (pause) as necessary during the operation to inspect.

2 Use of a threader Hand and eye injuriesDanger of getting caught, electrocution, fall by slipping, falling at ground level

- Wear safety gloves and glasses. The workers and the foreman must ensure the safety measures are respected before work begins.

3 Works on energized equipment Electric shocks - Follow the lock-out/tag out policy.- Work method.- Wear clothes covering body and hands.

The foreman and the users must make sure the safety measures are respected before work begins.

4 Seam test Pipe or joint break - Test conducted by a qualified person.- Establish a test method.- Inspect all piping elements before proceeding. - Delimit the test zone and limit workers presence.- Increase pressure gradually.

- The foreman delimits the test zone and limits workers presence.- Workers know the method.

5 Air system supply Pipe accidental break or opening - Identify the supplied lines.- Delimit the zone during pressure increase.

Workers know the method.

6 Works on existing line Line still under pressure - Before disconnecting or repairing a pressurized piping section, make sure it is completely depressurized. - Lock-out / Tag-out

- Foreman and worker.- Method and check with the customer.

HSE PROGRAM

PIPING WORK



1 Pipes or equipment positioning Load fallingSticking

- Method if required- Appropriate sling and hoisting apparatus- Safety perimeter- Wear gloves

The foreman informs the workers about the method, if required. The foreman verifies that handling and hoisting are made with the appropriate equipment and safely, while delimiting a safety perimeter.

2 Removal or opening of existing pipes.

Pipe wrongly purged or not purged - Personal protective equipment.- Lock out/Tag out.- Work methods.- Make sure to depressurize or purge.

The foreman, if necessary, checks that nobody disconnects or begins to repair a pressurized line before making sure all the precautions has been taken.

3 Scaffoldings Falling - Inspected and conforming assembly.- Railing or harness.- The floors must comply with the Safety Code.

The foreman, if necessary, sees to it that the scaffoldings are examined by an experienced person.

4 Manual hoisting apparatus Objects falling - Use solid anchoring and fasteners. - Know the load weight and make sure the hoisting capacity is respected.

The foreman, if necessary, verifies if the hoisting apparatus is used in accordance with good practices.

5 Seam test Pipe or joint break - Test conducted by a qualified person.- Establish a test method.- Inspect all piping elements before proceeding. - Delimit the test zone and limit workers presence.

The foreman delimits the test zone and limits workers presence.

6 Weld test Radioactive source - Delimit a protection zone.- Inform the workers.

The foreman, if necessary, ensures that only the authorized workers are in the zone.

7 Piping storage Objects fallingBack sprain

- Store piping appropriately to avoid mixing of irregular formats or sticking of worker’s hands or foot.

The foreman insures an appropriate storage at the start and reorganizes storage on a regular basis.

8 Electrical cords Electrocution ShocksFireFalling

- All extension cords must be grounded and suspended eight feet from the ground or along the walls.- Disconnect when not in use.- Maintain in good working order.

Each user must make sure to check regularly the extension cords and have them check too. Unplug the extension cords after use.

9 Electric tools and equipment ElectrocutionCutsEye injuries

- All tools and equipment must be grounded or provided with double insulation.- Wear eye protectors and gloves when using power saws, grinders and threaders.- Ensure that all tools are in good working order.- Remove defective tools from the construction site.

The contractor and the storekeeper are in charge of verifying, before use, the electric tools and equipment.

HSE PROGRAM

PIPING WORK (SUITE)



10 Lift trucks CrushingTrapping

- Move loads close to the ground, slowly and with a signalman when necessary.- Must be operated by a qualified person.

The foreman must ensure, upon arrival and regularly afterwards, that the person operating the equipment has the required qualifications in accordance with the standards.

11 Cisor-lift and Manlift FallingOverturningElectrocution

- Delimit the work zone.- Must be secured to the manlift.- Respect the maximum load.- Drive slowly on the construction site.- Must be level with the cisor-lift.- Make sure not to jam the extension cords used. - Close the railings.- Keep at a distance from electrical lines.

The foreman and each user, upon arrival of the equipment on-site and before each use, must make sure that an equipment inspection be done, that the user holds the required qualifications to operate the equipment and that there is no falling hazard.

12 Cranes Broken cablesOverturningDropped load

- Ensure that all hoisting equipment meets requirements upon arrival at the worksite, under section 2.15.6 in its entirety.

- Signalman when necessary.- Delimit and close surrounding zone.- Use slings that are in good condition.

The owner and the operator must ensure, upon arrival at the site and every day, that an inspection has been conducted and must verify the log book. The crane must be operated by a person that has the necessary qualifications in accordance with the standards, and supervision of the operation and of positioning must be done.

13 Ladders and stepladders Falling - All ladders and/or stepladders must comply with the standard (class 1).- Do not step on the last rung.- Place according to the type of work.- Fasten the ladders.- Rest it on a firm and even footing.- Must exceed the landing to be reached by one meter.- Stepladder must be completely open.- Ladders must be tied off.- Use the 4 : 1 rule.

The foreman and the users must, when work begins, plan for correctly sized ladders and stepladders and always monitor their condition and use.

HSE PROGRAM

WELDING AND CUTTING WORK



1 Gas cylinders Fire, explosion - Keep cylinders vertical and securely fastened to a cart.- Cylinder must comply with standards. - Equipped with protective valve closure.

The foreman and the welders must make sure, at each use and when necessary, to enforce the prescribed safety measures.

2 Welding Fire, explosion - Do not work on a vessel, reservoir or pipe unless residues have been removed. Air samples must be taken or procedures must be taken in accordance with the "Safety in Welding" standard (CAN/CSA-W117.2-M87).

The foreman and the welders must, when welding and cutting works begin, plan the work and check the works before performing.

3 Welding Fire, explosion - Welding or cutting operations are prohibited close to combustible material or in areas containing flammable dusts, gases or vapours unless precautions are taken to prevent fire.

The foreman and the welders must, before welding and cutting works begin, make sure there is no fire hazard.

4 Welding Fire, explosion - A fire extinguisher must always be within reach during operations. The foreman and the welders must, before welding and cutting works begin, ensure an extinguisher is at their disposal, operational and in good condition.

5 Welding Blindness - The welder must wear a face protector and protective screens must be installed to protect persons in the vicinity.

The foreman and the welders must, before the welding work begins, ensure that the use of a face protector is respected.

6 Storing gas cylinders Fire, explosion - It is prohibited to store oxygen cylinders less than six meters from a flammable gas cylinder unless the cylinders are separated by a wall.- Cylinders must be kept away from any heat source liable to increase the temperature of the contents to more than 55 Celsius.

The foreman and the welders must make sure there is a suitable area to store gas cylinders as soon they are received on site or when they are used.

7 Personal safety Burns - In addition to a face protector, the welder must wear welder’s gloves and clothing to protect the body.

The foreman must ensure that the proper safety equipment for welding work is worn.

8 Respiratory protection DiscomfortDisease

- Wear a chemical-cartridge respirator, appropriate to the works performed. At the beginning of the work and afterwards, make sure the good cartridges are used.

HSE PROGRAM

INSULATION WORK



1 Accessing work area Falls, slip, trips

Strains, overexertion

100% tie off, if required. Be aware of any element which may change the performance of your PPE. Walk the route and remove all possible tripping hazards.Use of 3-point contact when climbing ladders.Use of proper lifting procedures.Note: All knives have to be sheathed or in a carry when going to work location.

Plan access / egress in advance.

2 Conducting the work Congested work area

Insulation – inhalation, skin hazard

Extreme hot piping, radiant heat from live pipe

Cladding – cuts

Pinch points

Defective tools

Falling debris

Be aware of the tasks being performed above, below and beside you.Barricade / flag and tag the area when lifting and hoisting material.Note: Lanyards especially made for knives must be attached and used at all times when working.

Read MSDS before using product. Wear appropriate PPE (CSA safety glasses, CSA hardhat, standard work gloves (note: Kevlar gloves are mandatory while working with stainless steel), coveralls and half mask respirators with HEPA/organic filters.

Treat every pipe as a potential hazard. When pipe is exposed, always cover up with temporary overlap to eliminate radiant heat. Use proper material, when using layer stagger joints to prevent radiant heat.

Mandatory use of hand protection when handling of cutting metal. Note: when using stainless steel, worker must wear Kevlar gloves.Have a garbage container / pail nearby to place shards and small pieces.

Be aware of body positioning and where you are putting your hands and fingers.

Inspect tools before use to ensure that they are in proper and safe working order. If tools are defective, remove them from service and return for repair. Use the right tools for the job.

Use drop sheets / hoarding where applicable to contain insulation and metal debris.Flag and tag area.

Coordinate work in the area with others.

Update MSDS log.

Control PPE use.

3 Task completion Housekeeping Clean up material and dispose of in a site approved manner. If material is left behind for another shift, ensure that material is secured and not piled higher than railing. Also ensure that material is left in a secure manner for coffee and lunch breaks.Remove barricade / flagging and tagging and dispose.

HSE PROGRAM

SCAFFOLDING ERECTION WORK



1 Planning and design scaffold Under design, collapse Must be designed by a qualified person.Minimum evenly distributed load of 25lbs/ft for light duty to 75lbs /ft for heavy dutyDesign to support at least 4 times the load.

2 Base erection Bad stability

Collapse

Must be to level and plumbed.

Freestanding scaffold shall not exceed a height of three times the smallest dimension of its base.

Mud sills are required for surfaces such as gravelWheels must have locking device.

3 Structure erection Collapse, fall of employee Anchors as per regulation or as per designBracing as required100% fall arrest protection for scaffolder (unless secured by guardrail)

4 Platform Fall of employee or tools Guardrail above 10 feet (or fall arrest equipment and yellow tagging)CSA lumber plank (2’’x10’’) exceeding the frame structure of 6’’ minimum to 12’’ maximumToeboard and intermediate railWheels with locking devices

5 Inspection and tagging Use of unsafe scaffold Tagging system- Red: do not use- Yellow: caution, use by following tag special requirements- Green: safe to use

Inspected by a qualified person.

Inspection as per the tag date validity.

6 Electrical line Electrocution Respect distance of approach:- 3 meters for less than 125kV lines- 5 meters for 125kV to 250kV lines


APPENDIX C – JOB HAZARD ASSESSMENT (JHA)


List of all JHA

# Job Hazard AssessmentDCM-FO-SS-18-A (JHA 01) Rigging and liftingDCM-FO-SS-18-A (JHA 02) MobilizationDCM-FO-SS-18-A (JHA 03) Mobile equipment use DCM-FO-SS-18-A (JHA 04) Loading, unloading and warehousing materialDCM-FO-SS-18-A (JHA 05) Lifting with cranesDCM-FO-SS-18-A (JHA 06) Work in trenches and excavationDCM-FO-SS-18-A (JHA 07) De-icingDCM-FO-SS-18-A (JHA 08) Installing structural steelDCM-FO-SS-18-A (JHA 09) Concrete workDCM-FO-SS-18-A (JHA 10) Scaffolding erection and dismantlingDCM-FO-SS-18-A (JHA 11) Piping installationDCM-FO-SS-18-A (JHA 12) Piping removalDCM-FO-SS-18-A (JHA 13) Inspect and repair mechanical equipmentDCM-FO-SS-18-A (JHA 14) Heat exchanger pull out (bundle puller use) DCM-FO-SS-18-A (JHA 15) Pump workDCM-FO-SS-18-A (JHA 16) Valves workDCM-FO-SS-18-A (JHA 17) Welding and cuttingDCM-FO-SS-18-A (JHA 18) Pneumatic testingDCM-FO-SS-18-A (JHA 19) Equipment installation and removalDCM-FO-SS-18-A (JHA 20) Hydro testingDCM-FO-SS-18-A (JHA 21) Insulation workDCM-FO-SS-18-A (JHA 22) Working inside vessels and confined spaceDCM-FO-SS-18-A (JHA 23) Generic electrical workDCM-FO-SS-18-A (JHA 24) Heat tracing workDCM-FO-SS-18-A (JHA 25) Welding mi cableDCM-FO-SS-18-A (JHA 26) Cable tray installationDCM-FO-SS-18-A (JHA 27) Cable pullingDCM-FO-SS-18-A (JHA 28) Electrical testingDCM-FO-SS-18-A (JHA 29) Commissioning assistanceDCM-FO-SS-18-A (JHA 30) InstrumentationDCM-FO-SS-18-A (JHA 31) Working near energized components


APPENDIX D – SAFE WORK PRACTICES


List of all safe work practices

# Safe work practicesDCM-MT-SS-01-A PPEDCM-MT-SS-02-A Working at heightsDCM-MT-SS-03-A Ladders and stepladderDCM-MT-SS-04-A ScaffoldingDCM-MT-SS-05-A MobilizationDCM-MT-SS-06-A HygieneDCM-MT-SS-07-A Aerial platform devicesDCM-MT-SS-08-A Fork lift drivingDCM-MT-SS-09-A Operating vehiclesDCM-MT-SS-11-A Defective toolsDCM-MT-SS-12-A Drill press useDCM-MT-SS-13-A Hoisting and lifting apparatusDCM-MT-SS-14-A Working aloneDCM-MT-SS-15-A Trenching workDCM-MT-SS-16-A Emergency preparednessDCM-MT-SS-17-A Cable splicingDCM-MT-SS-18-A High voltage testingDCM-MT-SS-19-A Powdered actuated toolsDCM-MT-SS-20-A Band sawDCM-MT-SS-21-A Barricades, signage and flaggingDCM-MT-SS-22-A Extreme temperature exposureDCM-MT-SS-23-A Electrical toolsDCM-MT-SS-24-A Extension cordsDCM-MT-SS-25-A Fire extinguishersDCM-MT-SS-26-A HousekeepingDCM-MT-SS-27-A Material handlingDCM-MT-SS-28-A Office safety practicesDCM-MT-SS-29-A Portable grindersDCM-MT-SS-30-A Sabre saws and reciprocating sawsDCM-MT-SS-31-A Safe lifting practicesDCM-MT-SS-32-A WeldingDCM-MT-SS-33-A Use and storage of safety harnessDCM-MT-SS-34-A DemolitionDCM-MT-SS-35-A H2S awarenessDCM-MT-SS-36-A Radiation safetyDCM-MT-SS-37-A Workplace violenceDCM-MT-SS-40-A Combustible / Flammable handling and storage

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