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HSE MANUAL

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Page 1: SAFETY POLICY STATEMENT - Coastal LLC · safety consultants to identity operational and safety hazards. All planned inspections shall be documented and made part of the safety file

HSE MANUAL

Page 2: SAFETY POLICY STATEMENT - Coastal LLC · safety consultants to identity operational and safety hazards. All planned inspections shall be documented and made part of the safety file

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Contents SAFETY POLICY STATEMENT ......................................................................................................................... 7

SAFETY OVERVIEW ...................................................................................................................................... 8

ENVIRONMENTAL PROTECTION ACKNOWLEDGMENT .................................................................................. 9

HOUSEKEEPING ......................................................................................................................................... 10

EMPLOYEE ACCESS TO EXPOSURE AND MEDICAL RECORDS ........................................................................ 11

SUPERVISORS SAFETY & HEALTH TRAINING ............................................................................................... 12

FOREMAN/SUPERVISOR ORIENTATION ...................................................................................................... 13

COASTAL, LLC SAFETY & HEALTH TRAINING ................................................................................................ 14

NEW/TRANSFER EMPLOYEE ....................................................................................................................... 15

SAFETY ORIENTATION REVIEW SHEET ........................................................................................................ 15

Coastal, LLC Daily Equipment Inspection .................................................................................................... 16

On Site Work Employee PPE Checklist : ...................................................................................................... 17

Coastal LLC’s Disciplinary Action Form ....................................................................................................... 18

GENERAL SAFETY RULES............................................................................................................................. 19

HAZCOMM WRITTEN PROGRAM ................................................................................................................ 21

PREFACE ............................................................................................................................................................................ 21

RESPONSIBILITIES: ............................................................................................................................................................. 22

LISTS OF CHEMICALS: ........................................................................................................................................................ 22

LABELING SYSTEM: ............................................................................................................................................................ 23

TRAINING PROGRAM: ....................................................................................................................................................... 23

MATERIAL SAFETY DATA SHEET (MSDS): .......................................................................................................................... 25

CONTRACTOR EMPLOYEES: .............................................................................................................................................. 26

ADDITIONAL INFORMATION: ............................................................................................................................................ 26

HAZARDOUS COMMUNICATION ................................................................................................................ 27

HAZARDOUS MATERIALS HANDBOOK ........................................................................................................ 27

INFORMATION & SOLUTIONS .................................................................................................................... 27

INTRODUCTION ................................................................................................................................................................. 27

PURPOSE ........................................................................................................................................................................... 27

TERMS ............................................................................................................................................................................... 27

TYPES OF HAZARDS ........................................................................................................................................................... 29

CHEMICAL AGENTS ........................................................................................................................................................... 29

PHYSICAL AGENTS ............................................................................................................................................................. 30

INFECTIOUS AGENTS ......................................................................................................................................................... 30

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HAZARD CLASSES FOR CHEMICAL AGENTS ....................................................................................................................... 30

HEALTH HAZARDS ...................................................................................................................................... 31

MATERIAL SAFETY DATA SHEETS ...................................................................................................................................... 32

HOW TO READ AN MSDS .................................................................................................................................................. 33

METHODS OF CONTROL .................................................................................................................................................... 34

VENTILATION ................................................................................................................................................................. 34

PERSONAL PROTECTIVE DEVICES (PPD) ........................................................................................................................ 34

ADMINISTRATIVE CONTROLS ........................................................................................................................................ 34

LABELS AND WARNINGS ................................................................................................................................................... 35

Illustrations: .................................................................................................................................................................. 35

HEARING CONSERVATION PROGRAM ........................................................................................................ 36

PURPOSE ........................................................................................................................................................................... 36

PROCEDURE ...................................................................................................................................................................... 36

Who Should Wear Hearing Protectors? ........................................................................................................................ 39

How Can I Tell If a Noise Is Dangerous? ........................................................................................................................ 39

FORK LIFT SAFETY POLICY .......................................................................................................................... 41

OPERATING SAFETY RULES ................................................................................................................................................ 43

INSPECTION AND MAINTENANCE: .................................................................................................................................... 44

PALLETS: ............................................................................................................................................................................ 44

FORK LIFT SAFETY POLICY CERTIFICATION .................................................................................................................... 44

Hot Work................................................................................................................................................... 46

Responsibilities ................................................................................................................................................................. 46

Environment, Health and Safety (EHS) Department ..................................................................................................... 46

Supervisor ..................................................................................................................................................................... 46

Employee....................................................................................................................................................................... 46

Hazard Identification and Prevention ........................................................................................................................... 47

Fire Prevention and Protection for Welding and Cutting ............................................................................................. 47

Ventilation Requirements for Welding ......................................................................................................................... 47

Fire Hazard Prevention Tips: ......................................................................................................................................... 48

Hot Work Permit Requirements ................................................................................................................................... 48

Personal Protective Equipment for Welding and Cutting ............................................................................................. 50

Body Protection ............................................................................................................................................................ 50

Foot and Leg Protection ................................................................................................................................................ 50

Hand Protection ............................................................................................................................................................ 51

Hearing Protection ........................................................................................................................................................ 51

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Respiratory Protective Equipment ................................................................................................................................ 51

Eye and Face Protection ................................................................................................................................................ 51

RESPIRATORY ............................................................................................................................................ 52

PROTECTION PROGRAM ............................................................................................................................ 52

PURPOSE ........................................................................................................................................................................... 53

GENERAL ........................................................................................................................................................................... 53

SELECTION AND USE OF RESPIRATORS ............................................................................................................................. 55

A General Guide for Selection of Respirators ............................................................................................................... 57

MEDICAL EVALUATION ..................................................................................................................................................... 58

MAINTENANCE AND CARE OF RESPIRATORS .................................................................................................................... 59

TRAINING .......................................................................................................................................................................... 61

PROGRAM EVALUATION ................................................................................................................................................... 61

RECORD KEEPING AND ACCESS TO RECORDS ................................................................................................................... 61

APPENDIX B FIT TESTING OF RESPIRATORS ...................................................................................................................... 63

ISOAMYL ACETATE (BANANA ODOR) TEST. ................................................................................................ 64

TEST EXERCISES ................................................................................................................................................................. 64

RAINBOW PASSAGE ................................................................................................................................... 65

EXCAVATION AND TRENCHING .................................................................................................................. 66

FALL PROTECTION PROGRAM .................................................................................................................... 67

LADDER SAFETY ......................................................................................................................................... 70

Maintaining Ladders .................................................................................................................................. 70

AERIAL LIFTS .............................................................................................................................................. 71

HEAVY EQUIPMENT AND ELECTRICAL POWER LINES ....................................................................................................... 72

CRANES ..................................................................................................................................................... 72

EMERGENCY ACTION PLAN ........................................................................................................................ 74

SAFEGUARDS FOR MECHANICAL EQUIPMENT ............................................................................................ 75

QUALIFIED AND CERTIFIED PERSONS ......................................................................................................... 76

SCAFFOLDING ............................................................................................................................................ 76

SCAFFOLDS (TUBULAR WELDED FRAME) .......................................................................................................................... 77

WELDING AND BURNING OPERATIONS ...................................................................................................... 78

CRANES/LIFTING EQUIPMENT .................................................................................................................... 79

MEDICAL SERVICES/FIRST AID .................................................................................................................... 80

BLOODBORNE PATHOGENS EXPOSURE CONTROL PLAN .................................................................................................. 81

INTERACTION WITH HEALTH CARE PROFESSIONALS ........................................................................................................ 82

TRAINING .......................................................................................................................................................................... 82

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WORK AREA RESTRICTIONS .............................................................................................................................................. 83

CONTAMINATED EQUIPMENT .......................................................................................................................................... 84

PERSONAL PROTECTIVE EQUIPMENT ............................................................................................................................... 84

REGULATED WASTE DISPOSAL ...................................................................................................................................... 84

BIOHAZARD ............................................................................................................................................... 85

PERSONAL PROTECTIVE EQUIPMENT ......................................................................................................... 86

HEAD PROTECTION ........................................................................................................................................................... 86

FOOT PROTECTION ........................................................................................................................................................... 87

CLOTHING.......................................................................................................................................................................... 87

EYE AND FACE PROTECTION ............................................................................................................................................. 87

HAND PROTECTION ........................................................................................................................................................... 88

ADDITIONAL PPE ............................................................................................................................................................... 88

FIRE PREVENTION & PROTECTION .............................................................................................................. 89

GENERAL REQUIREMENTS: ............................................................................................................................................... 89

TRAINING: ......................................................................................................................................................................... 89

MAINTENANCE: ................................................................................................................................................................. 90

HAND, POWER TOOLS AND EQUIPMENT .......................................................................................................................... 90

MACHINE GUARDING ................................................................................................................................ 91

CONFINED SPACE ENTRY PROGRAM .......................................................................................................... 92

DEFINITIONS: ................................................................................................................................................................. 92

RESCUE AND EMERGENCY SERVICES: ............................................................................................................................... 98

HAZARDS FOR A CONFINED SPACE ................................................................................................................................. 100

TYPES OF CONSTRUCTION CONFINED SPACE FATALITIES .............................................................................................. 101

MATERIAL HANDLING & STORAGE ............................................................................................................102

ASSURED EQUIPMENT GROUNDING CONDUCTOR PROGRAM ...................................................................102

ELECTRICAL SAFETY ..................................................................................................................................104

LOCK/OUT – TAG/OUT ..............................................................................................................................108

PROCEDURES ............................................................................................................................................108

GENERAL ......................................................................................................................................................................... 108

LOCK/OUT-TAG/OUT INSTALLATION .............................................................................................................................. 108

LOCK OUT – TAG OUT REMOVAL .................................................................................................................................... 109

CONTROL ......................................................................................................................................................................... 109

TRAINING ........................................................................................................................................................................ 109

EMPLOYEE RETRAINING .................................................................................................................................................. 110

LOCKOUT/TAGOUT DEVICES ........................................................................................................................................... 110

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PERIODIC INSPECTION .................................................................................................................................................... 110

APPLICATION OF CONTROL ......................................................................................................................................... 111

ADDITIONAL REQUIREMENTS ..................................................................................................................................... 112

SHIFT OR PERSONNEL CHANGES ...............................................................................................................114

PERSONAL SAFETY EQUIPMENT ................................................................................................................114

COMPANY VEHICLE POLICY .......................................................................................................................116

ACCIDENT/ INJURY OR ILLNESS REPORTING ..............................................................................................117

SUPERVISOR ACCIDENT INVESTIGATION REPORT ......................................................................................118

EMPLOYEE INJURY AND ILLNESS REPORT FORM ........................................................................................120

ENVIRONMENTAL RESPONSIBILITIES .........................................................................................................121

WASTE MANAGEMENT ................................................................................................................................................... 121

SPILLS/RELEASES ............................................................................................................................................................. 121

HAZARDOUS NON-ROUTINE TASKS ...........................................................................................................124

CHEMICALS IN UNLABELED PIPES ..............................................................................................................124

LEAD CADMIUM AND OTHER METAL EXPOSURES .....................................................................................125

CRAFT SKILLS ASSESSMENT .......................................................................................................................125

ENVIRONMENTAL MANAGEMENT ............................................................................................................126

ALCOHOL AND DRUG ABUSE POLICY .........................................................................................................129

PROCESS SAFETY MANAGEMENT ..............................................................................................................134

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SAFETY POLICY STATEMENT

COASTAL, LLC is totally committed to safety and expects its employees to be committed to safety. Accident Prevention and efficient operations go hand-in- hand. Management must assume this responsibility can be met only by continuing efforts to promote safe work practices among all employees and to maintain property and equipment in the safest operating conditions. COASTAL, LLC strives to comply and be in accordance with all local, state, and federal standards and regulations. The safety, health and well being of our employees and the public are the ultimate concern of COASTAL, LLC No job or task is so important when performance results in injury. Therefore reasonable and prudent precautions should be undertaken to protect oneself, fellow employees, and members of the public. It is the policy of COASTAL, LLC to follow reasonable and prudent safety practices in the performance of every task. Your job and the success of our safety program depend on cooperation and compliance. Safety is an integral part of your job function.

Trey Williams Owner

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SAFETY OVERVIEW

COASTAL, LLC has developed a risk management program that applies the concept of hazard identification and control. As hazards are identified, procedures leading to their optimal control are developed and made part of this program. These procedures are designed to provide a place of employment that is free from uncontrolled hazards. Our employees are directed to follow these guidelines in order to assure that they are provided a place of employment that is free from uncontrolled hazards.

COASTAL, LLC has made a sincere, conscientious effort to provide state of the –art techniques and technology. Employee compliance and participation in the program is mandatory.

The employees’ job and the success of the program depend on their cooperation and compliance. This program is an integral part of each job functions. Suggestions to improve the practices and procedures set in the program are sincerely encouraged and solicited. These recommendations should be brought to the attention of the safety coordinator. Planned inspections will be conducted from time to time by the safety coordinator, supervisors and/or safety consultants to identity operational and safety hazards. All planned inspections shall be documented and made part of the safety file. Records of accidents and injuries are essential to efficient and successful safety programs, just as records ofproduction, cost, sales, and profits & losses are essential to efficient business operations. Records supply the information necessary to transform haphazard, costly ineffective safety work into a planned safety program that controls both the conditions and the acts that contribute to accidents. The safety coordinator will hold or conduct safety and health training seminars for employees at least quarterly. Employee training shall be documented and made part of the safety file and employee’s personnel file. This training may be in the form of films, videos, demonstrations, or presentations. Attendance at any such safety training exercise(s) relating to employees’ job responsibility and/or work environment is mandatory.

In addition to the safety training provided to all employees, supervisory personnel will be given additional safety training in order that the following general objectives of safety training for supervisory personnel may be accomplished.

1. To involve supervisors in the company’s accident prevention program. 2. To establish the supervisors as the key person in preventing accidents. 3. To cause supervisors to understand their safety responsibility.

4. To provide supervisors with information on causes of accidents and occupational health hazards and methods of prevention.

5. To give supervisors the opportunity to consider current problems of accident preventionand to develop solutions based on their own and others’ experiences.

6. To help supervisors gain skill in accident prevention activities. 7. To assist management in maintaining a safe work environment. The safety coordinator will perform the duties of Accident Investigation and identifying cause factors of

injuries and preventionof re-occurring accidents from the same causes. Additional duties and responsibilities of the safety coordinator included the review and revision (if needed) of the safety program and Operational Procedures. Company accidents and injury records will be analyzed periodically for trends, accident repeater, incident rates, etc.

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ENVIRONMENTAL PROTECTION ACKNOWLEDGMENT

COASTAL, LLC is aware of the importance of conducting operations in a manner such as to prevent damage or pollution to our environment. To accomplish this we must ensure that all of our equipment is maintained in sound operating condition to prevent leaks, discharges, or ruptures which could cause spillage of fuels, lubricants or other products into the environment, whether it be airborne, ground surface or waters of the U.S. In the event that a spill or discharge ever occurs, it is imperative that COASTAL, LLC personnel are prepared to handle the situation. This can be accomplished by securing the source of the leak, if it can be done without exposing anyone to danger or hazardous materials, containing the spill by building a dike around the spill with soil or using containment booms, commercial absorbent or any other suitable material that is capable of stopping the flow of the spilled product. After this is accomplished, COASTAL, LLC, employees must then report the spill or discharge to the appropriate personnel of the customer we are working for, or to their immediate supervisor if working on our premises. In any situation where an environmental mishap occurs, COASTAL, LLC and its employees must stand ready to assist, in any way possible, to bring the situation to a successful conclusion. This policy is to be communicated to all employees and supervisors so that a clear understanding of it is maintained at all times, any violations of this policy will be cause for disciplinary action.

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HOUSEKEEPING

Housekeeping is critical to ensure a safe working environment is maintained. It may seem like a trivial issue, but many times it is a contributing factor to occupational illnesses and injuries. Housekeeping is the responsibility of every employee. Please remember to put tools, materials, and equipment back in their proper place when not in use.

Keep work areas free from spills and leaks, (e.g., oils and chemicals, etc). Maintain access to emergency equipment, exits, and escape routes by keeping

areas clean and unobstructed at all times. Do not allow ice, snow, water, or mud to accumulate around decks, stairways, and walkways.

Always keep holes or openings in walking surfaces covered or place guards or barricades around them.

Dispose of waste materials in designated containers. Separate waste materials to allow for recycling. Never dispose of hazardous materials in a regular waste receptacle.

Report any housekeeping problems to your supervisor. Visually inspect the work area before you undertake a job. Make sure the work

area is prepared to ensure a safe, orderly condition when the job is being performed and also when the job is completed.

Secure and mark tripping hazards, such as hoses and electrical cords, whenever they are laid across walkways. Never lay hoses and cords across stairways.

Use caution on icy walkways and working surfaces. Keep hands free and out of pockets. Use railings when available.

The facility shall develop a site-specific fire prevention plan.

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EMPLOYEE ACCESS TO EXPOSURE AND MEDICAL RECORDS 1910.20( g ) ( 1) Requires employers, initially upon first employment and thereafter to inform employees exposed to toxic substances or harmful physical agent of the following;

1. The existence, location and availability of any medical or exposure record. 2. The person responsible for monitoring and providing access to records. 3. Each employee’s right to access these records. 4. Employer shall make readily available 1910.20 standard and its appendices.

At this establishment, the safety coordinator is responsible for maintaining these records. The records are kept in the administration office and are accessible any work day during regular office hours. A copy of 1910.20 and its appendices are kept in the safety office and are readily accessible to employees.

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SUPERVISORS SAFETY & HEALTH TRAINING All supervisors are required a new/transfer employee orientation. All supervisors are required to attend annual training to include but not limited to the following:

Safe work practices

Inspection techniques

Tool box safety meetings

Emergency procedures

First-procedures

Accident prevention

Fire protection & prevention

Pre-work orientation

Post construction clean-up & orientation

Hazard communication

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FOREMAN/SUPERVISOR ORIENTATION To ensure that or foreman and our subcontractors’ foreman are familiarized with their safety responsibilities, a one-time safety orientation shall be conducted by the project manager or superintendent upon hire or promotion to let him know what is expected of him. Upon completion of this information meeting, the foreman and the person holding the orientation shall attest to its completion by completing the Foreman’s Orientation Log (Exhibit 7.2). This sheet shall be kept on file at the jobsite as part of the permanent job file. This meeting shall cover the Safety Program, foreman’s responsibilities and specific duties. SAFE WORK AREAS Foreman shall be familiar with the crew’s work area and maintain a safe working environment. SAFE WORK PRACTICES When a foreman assigns a work task, he shall insure that employees are instructed as to safety practices, work methods and personal protective equipment. EMERGENCY PROCEDURES Each foreman shall be familiar with the emergency procedures for the project and be able to provide leadership in the case of an emergency such as fire, serious injury or evacuation. ACCIDENT INVESTIGATION Supervisors are required to help in the investigation of any accident and complete the required forms.

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COASTAL, LLC SAFETY & HEALTH TRAINING All employees are required to attend the NEW/TRANSFER EMPLOYEE SAFETY ORIENTATION. The orientation shall include but not limited to the following: (See new/transfer employee orientation review sheet on next page.) Initial and annual training is required (where applicable), in the following categories:

Lock-out/Tag-out (Energy Control)

Hot work

Confined space entry & attendant

Accident/Incident reporting

Unsafe condition reporting

Injury/Illness reporting

Bloodborne Pathogens

Fall Protection

P P E

Portable electric/ Power tools

Electrical safe work practices

Electrical equipment grounding assurance

Vehicle safety

Rigging & heavy equipment

Powered industrial vehicles (Cranes & Etc.)

Compressed gas cylinders

Housekeeping

Medical services/First-Aid

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NEW/TRANSFER EMPLOYEE

SAFETY ORIENTATION REVIEW SHEET

ITEMS TO BE REVIEWED WITH NEW/TRANSFER EMPLOYEE BY SUPERVISOR OR SAFETY COORDINATOR. CHECK OFF ITEMS AS INFORMATION IS EXPLAINED TO EMPLOYEE. NOTE: CERTAIN ITEMS MAY NOT BE APPLICABLE TO ALL POSITIONS.

EMPLOYEE NAME: _____________________________ JOB TITLE: ___________________ DEPARTMENT: _________________________________ DATE: ________________________

_____ 1. REVIEW HAZARDOUS ELEMENTS SPECIFIC TO THE JOB _____ 2. REVIEW ENGINEERING CONTROLS DESIGNED INTO OPERATION _____ 3. REVIEW ADMINISTRATIVE CONTROLS IN EFFECT _____ 4. REVIEW COMPANY “SAFETY POLICY STATEMENT “ _____ 5. REVIEW “GENERAL SAFETY “ _____ 6. REVIEW AND DISTRIBUTE PERSONAL PROTECTIVE EQUIPMENT _____ 7. READ SAFETY & HEALTH MANUAL AND SIGN ACKNOWLEDGEMENT SHEET _____ 8. REVIEW WRITTEN HAZARD COMMUNICATION PROGRAM AND MSDS OF CHEMICALS _____ 9. REVIEW LOCKOUT/TAGOUT _____ 10. REVIEW CONFINED SPACE ENTRY STANDARDS _____ 11. REVIEW “SOP’S FOR EQUIPMENT EMPLOYEE WILL BE EXPECTED TO USE _____ 12. REVIEW TOOLS-HAND & POWER _____ 13. REVIEW WELDING & CUTTING _____ 14. REVIEW LADDERS & SCAFFOLDING _____ 15. REVIEW CRANES, HOISTING EQUIPMENT, & MATERIAL HANDLING DEVICES _____ 16. REVIEW EXCAVATIONS, TRENCHING & SHORING _____ 17. REVIEW CONCRETE, CONCRETE FORMS & SHORING _____ 18. REVIEW TUNNELS, SHAFTS, AND COMPRESSED AIR _____ 19. REVIEW HEARING CONSERVATION PROGRAM _____ 20. REVIEW BLOODBORNE PATHOGENS PROGRAM _____ 21. REVIEW RESPIRATORY PROTECTION PROGRAM _____ 22. REVIEW ASSURED EQUIPMENT GROUNDING PROGRAM _____ 23. REVIEW CLOTHING & SHOE REQUIREMENTS _____ 24. REVIEW SAFETY/TRAINING MEETINGS (MANDATORY) _____ 25. REVIEW EMERGENCY EVACUATION PROCEDURES IN CASE OF FIRE OR DISASTER _____ 26. IDENDITY ALL FIRE EXTINGUISHER, TYPE OF FIRE TO BE USED ON, AND REVIEW FIRE EXTINGUISHER OPERATION _____ 27. REVIEW FIRE WATCH TRAINING AND PROCEDURES _____ 28. IDENTIFY ALL FIRE ALARM BOXES (IF AVAILABLE) _____ 29. IDENTIFY FIRST AID STATIONS AND SERVICES/EQUIPMENT AVAILABLE _____ 30. IDENTIFY EMERGENCY RESPONSE PERSONNEL _____ 31. REVIEW EMPLOYEE RIGHT-TO-ACCESS OF EXPOSURE & MEDICAL RECORDS _____ 32. REVIEW RIGHTS & INTERNAL ASSISTANCE AVAILABLE WITH REGARD TO WORKERS’ COMPENSATION _____ 33. REVIEW ACCIDENT/INCIDENT REPORTING PROCEDURES EMPLOYEE & SUPERVISOR AGREE THAT THIS INDOCTRINATION HAS BEEN CARRIED OUT COMPLETELY.

____________________________ __________________________ ________________ (SUPERVISOR’S SIGNATURE) (EMPLOYEE’S SIGNATURE) (DATE)

THIS FORM TO BE COMPLETED AND SIGNED BEFORE EMPLOYEE IS ALLOWED TO START WORK. SUPERVISOR IS TO RETAIN A COPY AND RETURN ORIGINGAL TO THE SAFETY COORDINATOR.

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Coastal, LLC Daily Equipment Inspection

All equipment shall be examined before being placed in services and shall not be placed in service if the examination

shows any condition adversely affecting the safety of the equipment. These inspections shall be made DAILY.

BY:_____________________________________ DATE:______________________________________

EQUIPMENT:______________________________________

“X” If Satisfactory

Condition

Clean

Proper Tire Inflation

No Leaks, Drips or Seeps

Hose & Lines in Good Condition

Caps tight

All bolts in place

Ample Fuel and Oil Levels

Wiring in good condition

Brakes working properly

Steering in good condition

Startup normal

Gauges Working

No Hazardous sparks or flames present

Lights in proper working order

If removed from service, list reason: ______________________________________________________

Defects reported and/or corrected: _______________________________________________________

____________________________________________________________________________________

_____________________________________________________________________________________

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On Site Work Employee PPE Checklist :

Employee_____________________________________ Date: __________________

Job Site:______________________________________

Body Part Protection

Eyes □ Safety Glasses, Goggles

Face □ Face Shield

Head □ Hard Hat

Feet □ Safety Shoes

Hands/Arms □ Gloves

Bodies □ Vests

Hearing □ Ear Plugs, Earmuffs

Comments:________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

Witnessed by: _________________________________________

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Coastal LLC’s Disciplinary Action Form To: ____________________________________________ Date: ________________ Employee Name _________________________________ Disciplinary Action: ______ Initial Counseling ______ Oral Warning ______ Written Warning ______ Written Warning & Suspension ______ Final Written Warning ______ Discharge Your performance has been found unsatisfactory for the reason(s) set forth below. Your failure to improve or avoid recurrence will be cause for further disciplinary action in accordance with Coastal LLC’s Discipline Policies. Details: ______________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ Agreed-upon improvement plan: ____________________________________________________________________________________ ____________________________________________________________________________________ A copy of this warning was personally handed to the above employee by: ___________________________________________ Supervisor Date: _______________ I have received and read this warning notice. Refusal to sign warning is an automatic dismissalfrom Coastal LLC. Original signed form will be placed in employee’s folder and a copy will be given to her/him. _________________________________________ Employee Date: ________________

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GENERAL SAFETY RULES This booklet is intended to aid in prevention of accidents to you and your fellow employees. It contains many rules and safe practices which follow various safety standards. Yet we cannot cover all conditions which may arise on the job. Each employee is personally responsible for their own safety and for those around him on the job. Any employee regardless of position whose actions are considered unsafe or causes other to be placed in unsafe conditions will be subject to disciplinary action up to and including removal from jobsite.

1. Each individual must accept the responsibility to remain alert and use good judgment in the performance of their job.

2. Safety programs are initiated with the sole purpose of reducing accidents minimizing the severity of injuries to employees and protecting company property.

3. Each employee is encouraged to consider it their duty to family and fellow workers to participate in First-Aid and other training classes provided from time to time.

4. It is expected that all employees will cooperate in promoting and maintaining an effective safety program.

5. Learn your job, learn the hazards and safety precautions to eliminate or minimize the hazards involved. Wear safety apparel recommended, ask questions when in doubt, and report all injuries to your foreman no matter how slight.

6. Accidents don’t just happen- they are caused by either an unsafe act or an unsafe condition or both. With your help we will eliminate both.

7. Horseplay is not permitted. Do not distract or interfere in any way with a person performing their job. You will make many friends in the course of your employment; however, don’t let your friendship and familiarity be the basis for playing a practical joke or prank which may end in an injury.

8. Signs posted throughout your jobsite are messages to warn of danger or to give you instructions on what to do or what not to do. Read and comply with all warning signs.

9. If you are in doubt about the safe or proper way to perform a specific job or duty, get instructions from your supervisor before proceeding.

10. When your are relieved from a job that has unusual, partially concealed or concealed hazards, immediately inform the person relieving you that such hazards exist. Be specific!

11. A foreman may enforce disciplinary actions. CONTINUED NEXT PAGE

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12. You may notice conditions from time to time which appear hazardous. Notify your

foreman or supervisor of such conditions so that he may have them corrected. 13. If you observe and employee performing his job in an unsafe manner, bring it to their

attention. If this does not help, report it to your foreman or supervisor along with your suggestion for its corrective action. You need not mention any names. The mere fact that such practices get to the proper authority may prevent someone who perhaps does not realize their actions are dangerous from getting hurt.

14. Employees shall not attempt to work when ill or in any other unfit conditions which may jeopardize the safety of themselves or others. Employees must notify supervision if taken medication which may affect mental or physical alertness, or if they become ill while on company premises or while on duty.

15. Employees shall maintain a clean worksite. Daily/weekly inspections will be conducted to ensure employees are following safety rules and policies.

16. Tripping hazards, protruding nails, oil slicks, scrap materials and other hazardous conditions occurring during the course of the job shall be eliminated as work progresses.

17. Defective tools and equipment shall not be put into service and shall be reported to management. Unsafe tools and equipment shall be taken out of service and properly tagged. See lock-out & tag-out.

18. Employees shall examine their work area and equipment for unsafe conditions prior to proceeding with their work assignments.

19. Employees shall report all injuries or illnesses to their supervisors before the end of the shift or day on which they occur.

20. Employees are prohibited from riding on slings, cradles, skips, conveyors, suspended loads, headache balls, or any other conveyance except where such equipment is approved for this purpose.

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HAZCOMM WRITTEN PROGRAM PREFACE

COASTAL, LLC is firmly committed to provide each of its employees a safe and healthy work environment. It is a matter of our company policy as well as an important employee safety program. The company is also committed to protect the environment within the confines of the property and beyond. The hazard communication program outlined will provide all of us a better understanding of our workplace and ways to make it a safer place in the future. The purpose of this program is to advise all our employees of the chemical and hazardous materials to which they are exposed on the job. In addition, material is presented so that they will be able to recognize ways in which to protect themselves. The Hazard Communication Program includes:

1. Listing of all chemicals and hazardous materials that are used by COASTAL, LLC. 2. Labeling system used by COASTAL, LLC 3. Training programs for employees as outlined in the Hazard Communication Program 4. Material safety data sheets (MSDS) which are available 24 hours a day for your

review. 5. Copy of the Hazard Communication Standard 29 CFR 1910.1200, and a copy of the

Medical Exposure and Medical Records, 29 CFR 1910.20. All our employees are expected to assist in our efforts to control any exposure to hazardous chemicals as well as prevent accidents at the workplace.

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RESPONSIBILITIES:

The safety coordinator shall be responsible for the overall administration of the program. The safety coordinator will ensure all aspects of the program are utilized in such a manner as to comply with the standard 29 CFR 1910.1200. He will provide assistance to department heads in regard to implementation and compliance and will conduct inspection in each department. Each department head will be responsible for the day-to-day compliance with the standard. Each department head will be responsible to maintain an MSDS file in his department. The safety coordinator will be responsible for maintaining an updated master MSDS binder which is available to any employee upon request. Any new information on hazardous chemicals introduced in the work area will be posted on the employee bulletin board in the form of HAZCOMM update memos. When new chemicals are introduced, it is the responsibility of each department head to advise the safety coordinator so that the master MSDS binder and the chemicals list are both updated. The purchasing director or any department head should advise the safety coordinator that a new chemical has been introduced into the workplace. Department heads are responsible for compliance to the standard within their departments. They shall insure that hazardous chemicals are not used by any employee until he or she has been properly trained. Each department head is responsible for all MSDS for chemicals used in his or her department, personal protection equipment (gloves, masks, goggles, etc.) as required by the nature of the chemical being handled and that all appropriate labels are affixed to the material containers. Each department will be responsible for documentation of training, initiation of disciplinary action for non-compliance to the standard and communication of all information to the safety coordinator for master filing.

LISTS OF CHEMICALS: A list of all chemicals used at COATAL, LLC. is to be maintained by the safety coordinator and distributed to all departments. Each department should post its own list of chemicals used in that department. Each employee who completes the training program should be given a copy of the list for his or her department. Lists should be updated as required and properly posted for employees’ information. All lists should include the common name of each chemical, physical/health hazard severity ratings, personal protection equipment requirements, odors and physical appearances. A file of all materials listings shall be maintained by the safety coordinator to meet the exposure records requirement of 29 CFR 1910.20.

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LABELING SYSTEM: No hazardous chemical will be accepted for use within any work area unless properly labeled. Each department head is responsible for the labeling of all chemical used in that department. For containers of hazardous materials shipped from another location, the name, address and telephone number of the manufacturer, importer, or distributor shall be visible on the container,in addition, information on contents, hazards, treatment and all MSDS’s. Any substance that has an MSDS must be properly labeled. Containers received and shipped from your location must retain the label as you receive it. When containers are used to store or transport hazardous material, they should also be labeled unless the employee who transports the container is the user of the container is the user of the material during his work shift. If part of the material is to be stored after his work shift, then the container should be labeled.

The hazards of a material are identified by categories: (1) health; (2) flammability; and (3) reactivity and indicating the severity of the hazard by five numerical divisions (4-0), with 0 being the lowest level of hazard. The spatial arrangement uses color coding for quick recognition. Labels must be legible in English (plus other languages, if desired) and prominently displayed. All pipes and piping systems are not required to be labeled, but before any work is to be done on such systems your immediate supervisor will be present. Portable containers into which hazardous chemicals are transferred from labeled containers and that are intended for immediate use by the employee who makes the transfer do not need labels. If the same container is not emptied at the end of the shift and left on the shelf for future usage, it should be labeled.

TRAINING PROGRAM: All employees who use hazardous chemicals or who are regularly exposed to a hazardous chemical or who may be exposed to a hazardous chemical in case of emergency shall be trained initially and annually. It is the responsibility of each department head to ensure continued training of all his or her employees. Before taking on any new management positions, any manager will be trained by the safety coordinator. Should a new material be introduced or a change be made in the process which introduces a hazardous material, the employee shall immediately be trained in the hazard of the new position.

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The safety coordinator is responsible for the training of all department heads and supervisors and shall provide for proper documentation of the training performed. Each department head is responsible for the training of all his employees and shall provide for proper documentation of the training performed. The safety coordinator is responsible for maintaining and providing to any employee so requesting the result of their exposure to any harmful toxic material. Each employee has the right to the record which includes examining and copying it. A copy of the Hazard Communication Program is located at the main office (5131COUNTY ROAD 2047, ODEM TEXAS 78370), and supervisors vehicles for employees to review. A copy of each material safety data sheet (MSDS) is maintained in a master binder at the same location. All employees who work with hazardous material will follow a training program that will enable him or her to:

1. Understand the contents of the Hazard Communication Standard. 2. Interpret information on labels and MSDS. 3. Understand protective measures and usage of protective equipment.

4. Use methods of detection of presence or release of chemicals in the work areas, such as

monitoring, survey, visual appearance and odors. 5. Know where employee exposure records are located and whom to contact to obtain

access to such records or copy. (Standard Requirement 1910.20) 6. Know procedures regarding outside contractors working in exposure areas.

7. Know methods used to inform employees of the hazards associated with chemicals

contained in unlabeled pipes in their work areas. 8. Be informed of all hazardous chemicals in their work areas and the hazards that each

chemical posed (i.e., fire, skin irritation, cancer, lung damage, etc.)

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SAFETY DATA SHEET (SDS): An SDS is an information sheet which describes all the properties of a chemical/material and any other information required by law. SDS’S are required by law to be accessible to any employee during all work shifts, without obtaining the supervisor’s permission. It is the responsibility of each department head to ensure that each hazardous material is delivered with the appropriate SDS. No hazardous material will be accepted without the SDS. No chemical may be used unless an SDS or statement has been received. The safety coordinator will continue to survey the property, determine what existing chemicals might be hazardous, and compile a complete list. After the list is compiled, the suppliers of all the listed chemicals will be asked to provide an SDS. If no SDS is required because the chemical is non-hazardous or exempt, the supplier should issue a statement to that effect. Each department head is responsible to provide information regarding existing chemicals to the safety coordinator when this initial survey in conducted. It is the responsibility of the Purchasing Director or any other purchaser to request an SDS for any hazardous material being ordered. If any SDS confirms that the material does not contain any hazardous chemicals, there is no need to affix labels on the containers. Steps should be taken to ensure that an SDS is available for each chemical you have. A department-by-department review for any hidden hazardous material will be conducted by the department heads. Before a chemical is used, the SDS should already be on file, both in that department and in the master binder. An SDS need not be received with every shipment of chemical; it must be received only with the first shipment of a new chemical after the SDS has been changed. The master binder will be maintained by the safety coordinator and will be available for review at the main office. The safety coordinator will receive, review and file each SDS with copies to the respective department for its individual SDS file. The master binder will be available during all shifts. The SDS will be filed in the master binder by department and by category, such as acid or alkali. The identity of the chemical on the SDS will be the same as the identity on the label and the chemical list. The safety coordinator will be the only person authorized to file or remove any SDS from the master binder. If any employee requests a copy of an SDS, only that person will be allowed to make a copy.

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Any SDS received by any department will be immediately forwarded to the safety coordinator. Upon receipt of the SDS, he will review it for completeness of all pertinent information. If any SDS is incomplete, it should be filed in the incomplete section until completed. No chemical will be used until authorized by the safety coordinator. If the SDS is complete, the label information for the chemical is determined, the chemical added to the master list and copies of both are sent to the department head so that they are properly filed or affixed before usage.

CONTRACTOR EMPLOYEES: The field supervisor up on notification, will advise outside contractors in person of any hazardous material that may be present in the vicinity of their work areas, the labeling system used at the property, the protective measures to be taken and the safe handling procedures to be used. They will also be notified of the location of the master SDS file. Any outside contractor who brings hazardous materials into the property must provide the MSDS with the appropriate hazard information on these materials, including labels used and precautionary measures taken in working with those materials. The outside contractor who does not comply will not be allowed to work at this property.

ADDITIONAL INFORMATION:

All employees or their designated representatives can obtain additional information on this program, the Hazard Communication Standard, SDS and chemicals list at the Main Office or by

contacting your department head. Copies or part of this program is also available at the Main Office for review by an employee. THE MASTER MSDS FILE IS AVAILABLE AT THE FOLLOWING LOCATION(S) FOR REVIEW BY AN EMPLOYEE, 24- HOURS A DAY:

MAIN OFFICE: 5131 COUNTY ROAD 2047

ODEM, TX 78370

(361) 877-7650

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HAZARDOUS COMMUNICATION

HAZARDOUS MATERIALS HANDBOOK

INFORMATION & SOLUTIONS

INTRODUCTION Hazard awareness is a basic part of a safety and health program. Your employer must provide a reasonably safe place in which to work, and instruct you in safe work practices. You, as an employee, have a responsibility to learn and follow sensible established procedures. In other words, you and your employer must work together to achieve the intent of the OSHA standard.

PURPOSE COASTAL, LLC cares about your health and safety. Using the OSHA Hazard Communication and other Right-To-Know standards as a guide, this report has been designed to give you the information you need to work safely with chemical/hazardous materials to reduce the possibility of over exposure to their physical hazards. Chemical information will be provided to employees on multiple worksites or multiple employer worksites. Safety Data Sheets (SDS) are obtained for all hazardous chemicals and are available to employees.

TERMS Below are listed terms used in this program and in the preparation of the SDS. Although we have not included every term found in these sources, the most important ones are defined. If you do not understand a word or one of the definitions, please feel free to ask for help. ABSORPTION: The movement of a hazardous chemical through the skin and into the blood stream. ACUTE: Short-term effect, usually of a temporary high-level exposure. BOILING POINT: The temperature at which a liquid boils at atmospheric pressure.

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CATALYST: A chemical which, without changing itself, caused a chemical reaction to proceed faster. CEILING VALUE (C): A maximum level. No exposure should ever exceed this level. CHRONIC: A long-term effect. Low-level exposure over a long period gives rise to symptoms that develop over time. COMBUSTIBLE: A liquid that becomes flammable when heated above 100 degrees Fahrenheit. CONCENTRATION: PPM and Mg/M3: PPM-Parts per million is the volume-per-volume relation of concentration. Mg/M3-Milligrams per meter cubed is a weight-per-volume measure usually applied to dust mists, and fume. A cubic meter is a cube, 39.4 inches on a side, for chemical vapor, PPM and Mg/M3 are interchangeable. EVAPORATION RATE: The time it takes a given amount of material to completely dry up, compared with an equal amount of referenced material (Acetone) FLAMMABLE (EXPLOSIVE) LIMITS-LEL AND UEL: A flammable material will burn in air when ignited. These materials are referred to as flammable, combustible, or explosive. The range of concentration in air which these materials will burn is limited by the Lower Explosive Limit (LEL). When the gas or vapor is below this concentration, the mixture is to lean to burn. The Upper Explosive Limit (UEL) means above this concentration, the mixture is too rich to burn. FLASH POINT: The temperature at which a flammable liquid produces sufficient vapors for combustion to occur. INGESTION: Taking a material by mouth: eating it. INHALATION: Breathing in a material. INHIBITOR: A chemical which, when added to another reduces the likelihood of a chemical reaction. ORAL DOSE: (LD50) The amount, usually expressed in milligrams per kilograms, which when fed to a group of animals will cause 50 percent of them to die. OXIDIZING AGENT: A material which gives off oxygen in a chemical reaction.

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POLYMERIZATION: A chemical reaction in which two or more smaller molecules form a larger molecule. (Drums swell up and may rupture.) REACTIVITY: The ability of a material to undergo a reaction with release of energy or heat. REDUCING AGENT: A material which accepts oxygen in a reaction. SOLUBILITY: The tendency of a material becomes soluble in water or other solvent. SPECIFIC GRAVITY: The weight per volume of a liquid compared to water. SPONTANEOUS HEATING: The tendency of a material to heat up without external heating. (Example; epoxies and their catalyst heat up while hardening) STABILITY: The tendency of a material to resist undesirable chemical changes during storage or transportation. (Freeze-thaw cycles) THERMAL DECOMPOSITION: The breakdown of a material when heated. THRESHOLD LIMIT VALUE-TLV AND PERMISSIBLE EXPOSURE LIMIT: Is a safe exposure level set by the American Conference of Governmental Industrial Hygienists (ACGIH). A PEL is a similar level set by OSHA. Both signify a level at which you can be exposed day after day with no adverse effects. (8 hour day) TOXICITY: The degree of injury or illness caused by a poisonous material. VOLATILE: The fraction by weight or volume of solvent, of evaporable content in a mixture.

TYPES OF HAZARDS You encounter hazards every day, both at work and at home. When discussing hazardous materials, generally we talk about chemical, physical or infectious agents. Here is an explanation of each:

CHEMICAL AGENTS Most chemicals you use at work are potentially hazardous. Some are hazardous because of physical reactions which can occur. Examples of such physical hazards include flammable materials which can cause burns if ignited and reactive materials which can injure you under the wrong conditions. Corrosive materials, when splashed on the skin and eyes, cause injury to

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them. Some corrosive materials come as dust, mist, or fumes. Most corrosives are very irritating; consequently, their worst effect is the injury they may cause to the skin and eyes. Only when workers are trapped or unable to leave the contaminated are do corrosives usually become threatening as an inhalation hazard. Some chemical agents are toxic. Unlike corrosives, toxic materials in contact with the skin usually cause no injury at the site of a splash. They can cause injury or illness by entering the body and acting as a poison to one or more of the body systems. Usually, these materials are found in the workplace as vapors or gases. They are carried by the air to the breathing zone (that area around the head from which the breathing air is drawn in and enters the body by way of the lungs). There, they are absorbed by the blood stream and carried to one area of the body, or may possibly poison the entire system; some toxic materials can be absorbed through the skin and carried to other parts of the body. Toxic materials may also be accidentally swallowed with food however; only a small number of industrial accidents are caused by toxins entering the body in this matter.

PHYSICAL AGENTS Physical agents are usually produced by machine, or when two or more chemical agents are mixed. Some of these hazards, like noise, heat, and welding arcs are easy to sense. Other, agents, like x-rays, microwaves, and ultrasound noise, may be hazardous but do not register on our senses. Physical agents can present an immediate hazard (like high voltage wires) or they can cause damage over a long period of time (like exposure to too much noise).

INFECTIOUS AGENTS Infectious agents are living microbial materials which can cause disease or create toxic wastes/by-products. They can cause illness in people or animals. Infectious hazards can be borne in the air in moisture droplets or spores, thus inhaled. They can also be contracted by touching a contaminated surface or enter the body through cuts or abrasions. For example, anthrax spores can enter the skin through cuts in the hide handler’s hands. Other infectious agents can also be ingested with food.

HAZARD CLASSES FOR CHEMICAL AGENTS Some materials are hazardous because they can react with the environment in ways that hurt people. Examples of these are flammable, reactive, radioactive materials. Injuries can occur when you are to close to these materials under the wrong circumstances. Other materials are hazardous because they cause illness or disease when they are taken into the body. Examples of these are toxic, carcinogenic, or corrosive materials.

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These materials are directly responsible for the harmful health effects you may experience after acute or prolonged exposure. HEALTH HAZARDS

TOXIC AND HIGHLY TOXIC: Almost all materials can be hazardous when used under the wrong conditions. Usually, the degree of hazard depends on the exposure dose. Even a substance as necessary to life as water can be hazardous when too much is taken in (i.e.; kidney overload can result in death). Small amounts of most materials may cause mild symptoms which disappear once the person is removed from the exposure. Large doses can cause more severe illnesses, with some permanent injury or even death. Each person responds differently to hazardous materials. OSHA standards check limit doses of industrial materials to levels which should not cause permanent harm to the average person over a working lifetime. OSHA’s definition of “toxic” and “highly toxic” applies to materials which in most cases are much more hazardous than the average industrial chemical. In this program, we will use the more common, broader definition of toxic: any material which can cause illness or injury. SENSITIZER: Sensitizers can change is the body’s defense system that may cause harm when an individual is exposed to even trace amounts of the material at periodic intervals. (Example, some amine type inhibitors may create a rash in workers) CORROSIVE OR IRRITANT: These materials cause injury or irritation when they come in contract with the eyes, skin, or mucous membranes. Acid eats away skin. Mild concentrations of acids may cause a slight burning reaction to the skin which often goes without treatment. TARGET ORGAN TOXINS: These materials damage one or more particular organ or body systems after exposure. Repeated exposures over time at low concentration can cause cumulative damage. CARCINOGENS, TERATOGENS, MUTAGENS AND REPRODUCTIVE HAZARDS: These materials cause changes in the body’s genetic material. Carcinogens cause changes leading to cancer. Teratogens cause birth defects and miscarriages. Mutagens can cause a variety of reproductive effects ranging from infertility to miscarriage.

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SAFETY DATA SHEETS(SDS) Manufacturers and supplies of chemical products are required by law to provide an SDS for each material or mixture they supply. The information in the SDS is gathered from scientific reports and the testing of the materials. The SDS is intended to give employers enough information to use the material safely in their operations. This SDS information is supplied to help you work more safely and be aware of the hazards of the materials you use in the course of your job. By knowing the chemical and physical characteristics of the materials you use, you can better protect yourself from their hazards. When you clearly understand control methods and emergency actions, you can protect yourself accordingly. A SDS is a technical bulletin detailing information about a specific chemical. Every chemical manufacturer or importer must develop or obtain and SDS for each hazardous chemical which it supplies. An SDS must accompany each sample or order shipped to a location for the first time, and must accompany the first shipment after each update of the SDS. Every employer must have available for their employees an SDS which meets the criteria of the standard for each chemical/hazardous material in the workplace. If a chemical manufacturer becomes newly aware of any data or if a report is published suggesting a hazard not indicated on a provided SDS, the chemical manufacturer is required to prepare a new SDS as a replacement within three months. The federal standard is designed so that the SDS is the most comprehensive source of written information for the employee. No standard format for the SDS information is specified as long as all required information is included. The SDS must be written in English, and at a minimum must contain the following:

The identity of the chemical that is indicated on the container label.

The chemical and common name of all ingredients having known health hazards present in concentrations greater than 1% and for carcinogens, if present at 0.1% or more.

The physical and chemical characteristics of the hazardous components.

The physical and health hazards including signs and symptoms of exposure.

The primary routes of entry. (skin, ears, nose, mouth, eyes)

Any known exposure limits (OSHA, PELS or ACGIH TLVS)

Whether the hazardous chemical is listed in the NIP as potential carcinogens.

The precautions for safe handling and use, and procedures for spill/leak clean up.

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Control measures

The emergency first aid procedures

The date of preparation

The name, address, and telephone number of the company distributing the SDS.

HOW TO READ AN “SDS” When reading an SDS one should take into consideration the following concerns:

1. The MSDS often outlines only the minimum precautions for safe handling of the chemical in the section on fire and explosion hazards, spills or leak procedures, special protection information, and special protection information, and special precautions.

Thus, if employer’s policy or the reader’s judgment suggests more stringent procedures, they should be used. 2. In many cases the emergency first aid procedures and handling precautions are written

to deal with the worst case or scenario, such as extensive exposure. Knowing this fact, one might conclude, for a seemingly minor incident, that immediate medical attention is not required. The SDS, however; might call for immediate medical attention. One should keep in mind that in the absence of an informed opinion by a designated health professional, a response to seek aid is the best policy. 3. When no mention of a particular health effect is made in the SDS, one should not

assume the substance is hazard free. Test results may not have been available when the SDS was prepared.

4. One should expect a complete SDS with no blank spaces. When receiving an SDS with

blank spaces, the supplier should be questioned. If data is not available, the SDS should so state in the space provided.

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METHODS OF CONTROL Various approaches can be taken to prevent or reduce your exposure to the hazards of chemical materials. Isolation from the exposure is the preferred OSHA method. Engineering controls which contain the hazard, ventilate it, or otherwise prevent it from reaching you, are to be used whenever possible. If the hazard cannot be adequately reduced through engineering controls, personal protective equipment shall be used. If protective equipment is inadequate, administrative controls can be used to ensure that no one is overexposed. VENTILATION

Ventilation is the method of control most often used to reduce worker exposure to hazardous materials. This includes dilution ventilation (provided by the room fan system), which may be used for relatively harmless materials in low concentration. Local exhaust ventilation designed to capture vapors and gases as they are released is the most common form of industrial ventilation. Specially designed systems are sometimes used to capture some highly toxic dusts; total containment glove boxes are used to maintain control over all detectable amounts of some materials. PERSONAL PROTECTIVE DEVICES (PPD)

Where engineering controls are not feasible, or do no fully protect the worker, personal protective devices, such as gloves, safety glasses, and respirators are used. Respirators must be carefully chosen. Special fit testing procedures are needed to assure full protection. There is a specific OSHA standard which addresses a complete Respirator Protection Program. In order to provide protection, gloves must resist penetration of the specific hazardous material to be handled. Some gloves are good for one class of hazard but not effective against others. Gloves and other protective clothing must not have worn spots, tears or cuts that may actually trap the hazardous material next to the skin. You’re the best judge of whether or not the protective equipment assigned is doing the job. ADMINISTRATIVE CONTROLS

Administrative controls are ways of scheduling workers so that no one person is overexposed to hazardous materials. By reducing the length of exposure and individual gets only a small dose of a hazardous material. In some cases only a small dose of a hazardous material. In some cases (nuclear reactors, for example), administrative controls are the only way to schedule work in areas where it is impossible to reduce the hazard of overexposure.

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LABELS AND WARNINGS There are many different methods use by manufacturers to warn you of the potential dangers of a material. In most cases, each label will tell you the name of the chemical and manufacturer as well as an emergency telephone number. Also, shipping container labels will provide similar information as that contained in the SDS: special precautions, controls, storage requirements and emergency procedures. OSHA’s stated purpose is to have labels serve only as an immediate warning and as a reminder that more detailed information is available elsewhere. Employees should be aware of the hazards of the chemicals they work with through in-house training programs and reading Safety Data Sheets. When a chemical has several potential hazards, not all of the hazards are necessarily listed so long as the label gives an immediate visual warning of the most imminent hazards. Labels may use symbols, pictures, and/or words to present their message. Existing labels complying with the standard need not be replaced. Employers, including research laboratories, must not remove or deface labels on incoming containers unless the original labels are replaced with other appropriate ones. Illustrations:

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HEARING CONSERVATION PROGRAM

PURPOSE COASTAL, LLC has implemented a hearing conservation program pursuant to meeting criteria of OSHA industry standard 1910.95.

PROCEDURE

A. Responsibilities for establishing and administering the program. 1. A competent person will be designated to oversee and maintain the program. 2. The program will be evaluated periodically by Trey Williams. 3. Changes will be made as necessary to maintain program effectiveness.

B. Monitoring and establishing high noise levels.

1. The initial noise survey is performed with the use of a sound level meter, currently a Quest, Model 208. 2. Areas and operations which fall into a noise area range of 85 decibels (dBa) or above will be identified and documented. 3. COASTAL, LLC job site management will set policy or mandatory use of hearing protection in these areas, and while performing certain operations. 4. COASTAL, LLC employees will be notified in writing of high noise areas and operation by the safety director. 5. COASTAL, LLC will post or otherwise identify shop areas or operations which exceed 85 dBa or greater. 6. Employees will wear hearing protection in areas designated to by 85 dBa or greater. 7. If significant changes in noise levels occur, noise levels will be re-evaluated to determine the level of protection that is required.

C. EMPLOYEE NOTIFICATION

1. Eight-hour time-weighted average noise monitoring results requiring employee notification will be posted in a conspicuous location.

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D. AUDIOMETRIC TESTING PROGRAM

1. Audiometric testing will be available to all employees while exposure to noise equals or exceeds and eight-hour TWA of 85 dBa on a regular basis.

at least 14 hours without exposure to workplace noise is required prior to establishing a baseline audiogram.

2. COASTAL, LLC safety director will determine which have and 8- hour TWA

exposure of 85 dBa or greater. Such employees will be notified and placed in the audiometric testing program. Employees are notified in "writing" of a standard threshold shift within 21 days of determination. Hearing protection is re-evaluated in the event of a standard threshold shift. Hearing protection is evaluated for the specific noise environments in which the protector will be used.

3. Arrangements will be made by COASTAL, LLC safety director to perform the following:

audiometric testing test interpretation by an audiologist or other qualified person computerized data analysis and retention management education programs initial fitting of employees for ear plugs, if required facilitate training for job site supervision fit testing new

employees 4. COASTAL, LLC will establish a baseline audiogram against which subsequent

audiograms can be compared (for all employees exposed to 85 dBa TWA or above).

a baseline audiogram shall be conducted within 6 months after an employee has been found to be exposed to 85dBa or above

testing to establish a baseline audiogram without exposure to work place noise. The use of hearing protection in lieu of non-exposure to work place noise is acceptable.

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E. ANNUAL ADDIOGRAMS

1. At least annually, after obtaining the baseline audiograms COASTAL, LLC shall

obtain a new audiogram for each employee exposed 85 dBa or above.

2. Each employee’s annual audiogram shall be compared to that employee’s baseline audiogram to determine if the audiogram is valid and if a significant threshold shift (STS) has occurred.

A. An employee will be notified within 21 days of a determination of an

STS. B. Hearing protection will be worn by employees experiencing an STS.

1. A subsequent audiogram shows not STS 2. The employee is not exposed to noise greater than 90 dBa TWA.

3. The facility retained to conduct the audiometric testing will meet or exceed the OSHA 1910.95 (h) requirements related to this section.

F. HEARING PROTECTION

1. All employees working in areas with noise levels at or above 85(dBa) will wear proper hearing protection.

2. Hearing protectors will be replaced as necessary.

3. Site supervision will monitor the enforcement and correct usage of hearing

protectors.

G. TRAINING PROGRAM 1. COASTAL, LLC job site management will institute and maintain an initial

training program for new employees and provide an annual training program thereafter for employees with 85 (dBa) or greater noise exposure.

2. The safety director will ensure that employees participate in the program.

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3. Training programs will be kept updated and will be documented. 4. The training program shall include:

A. The effects of noise on hearing B. The purposes of hearing protectors; the advantage, disadvantages and

attenuations of various types. Instructions shall be given in issue points, selection, fitting, use and care of hearing protectors.

C. Purpose of audiometric testing and explanation of test procedures.

5. A copy of 1910.20 and applicable informational training material will be kept at COASTAL, LLC office. Employees will be informed of the availability of the documents for review.

H. RECORD KEEPING

1. Exposure measurements, audiometric tests, and related records will be kept on file for review pursuant 1910.20 access to medical records.

2. Record retention will be done in accordance with the time periods stated in

the standard. Who Should Wear Hearing Protectors? If you must work in an excessively noisy environment, you should wear protectors. You should also wear them when using power tools, noisy yard equipment, firearms, or riding a motorcycle or snowmobile. How Can I Tell If a Noise Is Dangerous? People differ in their sensitivity to noise. As a general rule, noise may damage your hearing if you have to shout over background noise to make yourself heard, the noise hurts your ears, it makes your ears ring, or you have difficulty hearing for several hours after exposure to the noise. Sound can be measured scientifically in two ways. Intensity, or loudness of sound, is measured in decibels. Pitch is measured in frequency of sound vibrations per second. A low pitch, such as a deep voice or a tuba, makes fewer vibrations per second than a high voice or violin.

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FORK LIFT

SAFETYPOLICY

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FORK LIFT SAFETY POLICY Fork lift traffic accidents can be prevented by using the same safe practices that apply to highway traffic. For example, excessive speed can lead to accidents both in the plant and on the road. Safe speed is the rate of travel, which will permit the truck to stop well within the clear distance ahead, or make a turn without overturning. Wet or slippery floors require a slower-than-ordinary speed. Certified personnel are the only persons who may operate a forklift. All employees are required to be trained and certified prior to operating each specific type of equipment. Forklift training is provided by a qualified instructor which will train in formal instruction, practical training and a workplace-specific operator evaluation. Forklift operators are re-evaluated every three years, at minimum.

Collisions between forklifts and stationary objects often occur while forklifts are backing, usually when they are tuning and maneuvering. In such cases, the operator may be so intent on handling the load that where the rear of the fork lift is going is forgotten. Because backing accidents usually result from a failure to look, operators are required to look in the direction of travel, maintaining a clear view. The operator should stop at blind corners and before passing through doorways, and go ahead only when it can be seen that the way is clear. Operators should keep forklifts a safe distance apart during operation. Operators must not pass other forklifts traveling in the same direction at intersections, blind spots, or other dangerous locations. They must keep to the right, if aisle width permits it without passing dangerously close to machine operators or others. Where aisles are not wide enough for continuous two-way traffic, vehicles should run in the middle of the aisle except when in a passing situation where the vehicle moves to the side and passes with caution. Operators should avoid making quick starts, jerky stops, or quick turns at excessive speed. They should use extreme caution when operating on turns, ramps, grades, or inclines. On descending grades, forklifts should be kept under control, so that they can be brought to an emergency stop in the clear space in front of them. The reverse control should never be used for braking.

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No fork lift should be used for any purpose other than the one for which it is designed. Common dangerous materials misuses include bumping skid, pushing piles of material out of the way, using the forks as a hoist, and moving other forklifts. Highway trucks and trailers should have their brakes set and their wheels securely blocked while they are being loaded or unloaded by forklifts. Before entering a trailer, forklift drivers should determine that wheel shocks are squarely placed in front of the rearmost tires on dual axle trailers. Feet and legs should be kept inside the guard or the operating station of the truck. Driving with a foot or leg outside is unsafe, as is placing a hank, arm or leg on or between the uprights of a truck. When in close quarters, operators should keep their hands where they cannot be pinched between the steering or control levers and projecting stationary objects. The operator should leave a fork lift unattended only after the controls have been put in neutral, the power shut off, the brake set, the key removed, or the connector plug pulled, and the load engaged means placed in a lowered and inoperative position. An “unattended truck” is defined by OSHA as one where the operator is more than 25 feet from it or cannot see it. It is the operator’s responsibility never to park a fork lift in an aisle or doorway nor to obstruct material or equipment to which another worker may need to access. Looking out for pedestrians is also the fork lift operator’s responsibility, and the horn should be sounded when approaching pedestrians. Excessive horn blowing; however is discouraged. Having sounded the warning, the operator should proceed with caution, passing only when the pedestrians are aware of the fork’s presence and are in clear. The operator should not use the horn to “blast” a way through. Forks should never be driven directly toward anyone who is standing in front of a bench or other fixed object. Pedestrians also have a responsibility to watch out for trucks and to get out of the way with reasonable promptness. Consideration by both sides is needed. Passengers must never be permitted to ride on a forklift. It is the operator’s responsibility to keep riders off. Loads, whether on trucks, trailers, skids, or pallets, should be stable. Objects should be neatly piled or cross tied, if the shape permits. Irregularly shaped objects should be loaded sot had they cannot roll or fall off. Heavy, odd-shaped objects should be placed with the weight as low as possible.

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OPERATING SAFETY RULES:

1. All starts and stops should be easy and gradual to prevent the load from shifting. Turns should be made smoothly and gradually at a safe speed. 2. The operator should be particularly careful, while either traveling or

maneuvering, to avoid striking overhead structures and nearby objects, such as sprinkler piping, electrical conduit, or fixed structures.

3. Loads should not be raised or lowered en route. Loaded or empty, the forks should not be carried as low as possible, but high enough not to strike any raised or uneven surfaces. Tilting back then upright keeps the load steady and secure.

4. If any bulky load is to be carried that cannot be lowered enough to prevent its obstructing

the view, the fork should be driven backward so the operator can see where the fork is going.

5. Trucks should ascend or descend grades slowly. On all grades, the load and load-engaging

means should be tilted back, if applicable. Low gear or the slowest speed should be used when the truck is descending a grade. The operator should keep clear of the edge of loading docks and ramps and never make a turn on a ramp.

6. Before driving over them, it is important that the operator check bridge plates, to make

sure they are properly secured, and the floors of trucks, to be sure they are in good condition and will bear the weight of the truck and load. Also, check the truck or trailer to see that it is properly chocked.

7. Operatorsshouldnever, under any circumstances, attempt to operate a fork with an

overload. Such a load is dangerous because it removed weight from the steering wheels, which affect the steering. Standing on a truck or adding counter weights to compensate for an overload isnotpermitted.

8. Side stability is a critical factor in making turns at speed or on a slope or ramp. Back tilt or

uprights reduces side stability on high lifts, and allowances should be made for this factor.

9. In attempting to pick up a palletized load, the forks should be fully and squarely seated in the pallet, and equal distance from the center stringer and well out toward the sides. Forks to be inserted in a pallet should be level, not tilted forward or back.

10. When raising or lowering loads while standing still, the operator should not leave the fork in

gear; the shift should be returned to neutral and the clutch disengaged.

11. When a fork lift is parked, the forks should be placed flat on the floor. No one is allowed to stand or walk under elevated forks.

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INSPECTION AND MAINTENANCE: Operators should make daily inspections of controls, brakes, tires and other moving parts. Defective brakes, controls, tires, lights, power supply, load-engaging mechanism, lift system, steering mechanism and signal equipment must be repaired before the fork is allowed into service. Operators are prohibited from making repairs without permission.

PALLETS: Pallets should be in safe condition. Top deckboards should be sound and securely fastened to runners. Splintered, broken or loose parts should be repaired or replaced. Loose nails or chunks of wood can cause injury to workers and damage fork lifts. Pallets should be neatly stacked and limited in height so that they are stable and secure against sliding and collapse. Also, they should not be left standing on edge or in a leaning position from which they might topple onto people or other objects.

FORK LIFT SAFETY POLICY CERTIFICATION

“ALL EMPLOYEES MUST BE CERTIFIED BEFORE OPERATING ANY EQUIPMENT” “I certify that I have received, and read this Fork Lift Safety Policy, and I have discussed the operation and any item for which I am unfamiliar with my supervisor (or other authorized person). I understand how to operate this equipment and will follow procedure to prevent accidents and perform my work in the safest possible manner.” ______________________________ ________________________ Employee Signature Date ______________________________ Employee Printed Name

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HOT WORK

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Hot Work Hot Work is defined as “work involving burning, welding, or similar operation that is capable of initiating fires or explosions.”

Responsibilities Environment, Health and Safety (EHS) Department

EHS is responsible for reviewing hazards and incidents associated with Hot Work conducted on campus along with developing training programs for Hot Work operations, performing health hazard evaluations, and performing safety inspections of welding work areas and equipment. Any defective hot work equipment must be removed from service.

Supervisor Supervisors are responsible in making sure employees who will be performing Hot Work operations are properly train on the UNC procedures before performing work on campus. A hot work permit is completed before performing hot work. A JSA should be developed that provides specifies written rules and instructions covering when Hot Work Permit is required, the safe operation of equipment, incorporating information from Material Safety Data Sheets (MSDS) welding materials used, appropriate PPE, evaluation of combustible materials and hazardous areas present or likely to be present in the work location. Whenever a Hot Work Permit is required, the Supervisor is responsible for designating the following:

Hot Work Operator: Employee who is qualified and authorized by management to perform hot work such as welding, brazing, soldering, and other associated work tasks.

Permit Authorizing Individual: Employee who trained and is authorized to issue a hot work permit by management.

Fire Watch: Employee who is trained in hot work safety and monitors the hot work area for changing conditions and watches for fires and extinguishes them if possible.

Employee

Employee performing hot work SHALL: Before use of welding equipment, read and understand all safety practices outlined in

the manufacture instruction manual for the specific type(s) of welding equipment used for the work process. Read and understand Material Safety Data Sheets (MSDSs), and Work Unit Specific Safety Practices (e.g. SOPs, JSA) and safety requirements of this Policy.

Employees performing hot work, Departmental Hot Work Permit Authorizing Individual(s) (PAI), Fire Watches, and Supervisors of hot work operations, must complete annual Fire Safety Training (“hands-on”) and complete the Hot Work Safety Training Module located on the EHS website Self Study page.

Inspect all welding equipment daily prior to use. Shall perform a hazard assessment before work or during any unusual welding

operations are planned. Shall follow all the safety requirements outlined in the issued Hot Work Permit.

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Use all required welder personal protective equipment for the specific job. Report any unsafe condition immediately to the Supervisor.

Hazard Identification and Prevention

Fire Prevention and Protection for Welding and Cutting

Welding, cutting, and allied processes produce molten metal, sparks, slag, and hot work surfaces can cause fire or explosion if precautionary measures are not followed. Flying sparks are the main cause of fires and explosions in welding and cutting. Sparks can travel up to 35 feet from the work area. Sparks and molten metal can travel greater distances when falling. Sparks can pass through or become lodged in cracks, clothing, pipe holes, and other small openings in floors, walls, or partitions. Typical combustible materials found inside buildings include: wood, paper, rags, clothing, chemicals, flammable liquids and gases, and dusts. Parts of buildings such as floors, partitions, and roofs may also be combustible. Welding and cutting can cause explosions in spaces containing flammable gases, vapors, liquids, or dusts. Ventilation Requirements for Welding

Adequate ventilation shall be provided for all welding and cutting and related operations. Adequate ventilation shall be enough ventilation such that personnel exposures to hazardous concentrations of airborne contaminants are maintained below the allowable limits. Ventilation is used to control overexposures to the fumes and gases during welding and cutting. Adequate ventilation will keep the fumes and gases from the welder’s breathing zone. The heat of the arc or flame creates fumes and gases (fume plume). Fumes contain respirable particles. Gases include the shielding gas, and combustion products. The heat from the arc or flame causes the fume plume to rise. Overexposure to welding fumes and gases can cause dizziness, illness, and even unconsciousness and death. The following measures and precautions are to be instituted to protect employee health:

General Welder Safety Precautions: Keep your head out of the fume plume. Reposition the work, your head, or both to keep from breathing smoke and fumes. Do not breathe the fumes. Use ventilation to control the fumes and gases produced from cutting and welding.

Adequate ventilation: All welding, cutting, and heating operations shall be ventilated (natural or mechanical) such that personnel exposures to hazardous concentrations of airborne contaminants are within acceptable limits. Adequate ventilation can be obtained through natural or mechanical means or both.

1. Natural ventilation is the movement of air through a workplace by natural forces. Roof vents, open doors and windows provide natural ventilation. The size and layout of the area/building can affect the amount of airflow in the welding area. Natural ventilation can be acceptable for welding operations if the contaminants are kept below the allowable limits.

2. Mechanical ventilation is the movement of air through a workplace by a mechanical device such as a fan. Mechanical ventilation is reliable. It can be more

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effective than natural ventilation. An example is a local exhaust ventilation system. These systems include a capture device, ducting, hood, and a fan. The capture devices remove fumes and gases at their source. Some systems filter the airflow before exhausting it. Fixed or moveable capture devices are placed near or around the work. They can keep contaminants below allowable limits. When using mechanical ventilation remember to:

1. Locate the hood as close as possible to the work. 2. Position the hood to draw the plume away from the breathing zone. 3. Curtains may be used to direct airflow.

Cutting of Stainless Steel: Oxygen cutting, using either a chemical flux or iron powder or gas-shielded arc cutting of stainless steel, shall be done using mechanical ventilation adequate to remove the fumes generated.

Fire Hazard Prevention Tips:

Whenever possible, relocate the work from the work site to the welding/maintenance shop area. Welding and cutting operations shall ideally be conducted in a separate, well ventilated room with a fire-retardant floor. Fire watch shall be maintained for at least 30 minutes after hot work activities were completed.

When not possible to relocate work to the welding shop: remove combustible materials for a minimum radius of 35 feet (10.7 meters) around the work area or move the work to a location well away from combustible materials.

Protect combustibles with covers made of fire-resistant materials (see below for a description of approved fire-resistant materials for hot work).

If possible, enclose the work area with portable, fire-resistant screens. Cover or block all openings, such as doorways, windows, cracks, or other openings with

fire resistant material. When needed, have a qualified firewatcher in the work area during and for at least 30

minutes after hot work is finished. Do not dispose of hot slag in containers holding combustible material. Fire extinguishers shall be maintained in a state of readiness for instant use. Welding or cutting is not permitted in or near rooms containing flammable or

combustible liquids, vapors, or combustible dusts. Do not weld or cut in atmospheres containing reactive, toxic, or flammable gases, vapors, liquids, or dust.

Do not apply heat to a work piece covered by an unknown substance or coating that can produce flammable, toxic, or reactive vapors when heated.

Provide safety supervision for outside contractors conducting hot work. Inform contractors about site-specific hazards including the presence of flammable materials.

Hot Work Permit Requirements

Employees that perform hot work outside of designated Welding Shop and Maintenance Shop areas must complete a UNC Hot Work Permit (see Appendix A) prior to conducting hot work

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operations and post original at job site and provide EHS with a copy of the initial (before work) and the final sign-off (after work is completed). The Supervisor, Departmental Permit Authorizing Individual, and Hot Work Operator are responsible for ensuring compliance with the permit requirements. The information contained on the UNC Hot Work Permit is based from NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work. The PAI must document the following on the Hot Work Permit:

1. Date the Permit is being issued. A Permit is only valid for one day of work. 2. Building/Location/Floor Level where hot work will be taking place. 3. Document type of work to be performed (i.e. Overhead MIG Welding) 4. The PAI then shall inspect the work area and confirm that precautions have been taken

to prevent a fire. The PAI must complete the checklist outlined on the Hot Work Permit which includes observing special precautions needed during work such as posting a fire watch, and ensuring the hot work location is free from hazards within 35 feet of the work area where hot work is planned.

5. Document any special precautions for the work to be performed such as the use of supplemental fire extinguishers, welding blankets, welding curtains, and ensuring combustible materials are not present and guarding materials that cannot be relocated as a last line of defense where hot work is planned.

6. The PAI must inspect if hot work is planned near or on walls, ceilings, and roofs. These areas must be inspected for fire hazards.

7. Hot work is prohibited on enclosed equipment, such as in, on, near tanks, vessels, or containers that contain or have contained flammable substances.

8. Hot work is prohibited in areas with the accumulation of dusts. 9. The PAI must ensure that the Fire Watch is provided during hot work and for 30 minutes

after the completion of hot work. 10. The PAI must ensure the Fire Watch is supplied with appropriate fire extinguishers

and/or fire suppression equipment (e.g. water hose). 11. The Fire Watch must be able to activate the fire alarm and be able to contact the Fire

Department in the event of an emergency. 12. The PAI must determine if more than one fire watch is required in adjoining areas,

above level and below areas. 13. The Fire Watch must perform a final check of the work area and adjacent areas to which

sparks and heat might spread (including floors above and below, and on opposite side of wall(s). 30 minutes after the hot work was completed and verify with the PAI that the area was found safe.

14. Hot Work Locations 15. Hot work is never permitted in certain types of locations where safe conditions do not

exist and cannot be created. Hot work is allowed in two types of locations: 16. Designated Area

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17. A permanent location approved for routine hot work operations made safe by removal of all possible sources of ignition that could be ignited by the hot work tool. An example is the Welding Shop or Maintenance Shop where all combustibles have been removed. A Hot Work Permit is not required in a Designated Hot Work Area.

18. Controlled Area 19. One in which safe conditions for hot work exist or where safe conditions can be created

by moving or protecting combustibles. An example of a controlled area is in a campus building construction area where welding must take place and the work area has been made safe by removing all combustibles and implementing the requirements of the hot work permit in order to make it safe.

Personal Protective Equipment for Welding and Cutting

Employees exposed to the hazards created by welding, cutting, or brazing operations shall be protected by personal protective equipment (PPE) in accordance with the requirements of OSHA standard 1910.132. Appropriate protective clothing required for any welding operation will vary with the size, nature and location of the work to be performed. PPE must protect against hazards such as burns, sparks, spatter, electric shock, and optical radiation. Body Protection

Clothing shall provide sufficient coverage, and be made of suitable materials, to minimize skin burns caused by sparks, spatter, or radiation. Wear oil-free protective clothing made of wool or heavy cotton. Heavier materials work best. Choose clothing that allows freedom of movement and covers all areas of exposed skin. Wear long sleeved shirts (no t-shirts), and button the cuffs, pockets, and collar. They will protect your arms and neck from exposure and skin burns. Wear leather aprons (leather or other material that protects against radiated heat and sparks), leggings, capes, and sleeves as needed for the application. Keep clothing dry. Change it when needed (this reduces the possibility of electric shock). Keep clothing clean (free of oil, grease, or solvents which may catch fire and burn easily). Keep it in good repair (no holes, tears, or frayed edges). Always follow the manufacturer’s direction for their use, care, and maintenance. Remove all flammables and matches and cigarette lighters from your pockets. Do not wear synthetic (man-made) fabrics because they may burn easily, melt, stick to your skin, and cause serious burns. The following is an illustration of a welding jacket that is used by a Campus Shop – Courtesy UNC-CH Physics Shop. Foot and Leg Protection

Wear leather, steel-toed, high-topped boots in good condition. They will help protect your feet and ankles from injury. In heavy spark and slag areas, use fire-resistant boot protectors or leather spats strapped round your pant legs and boot tops to prevent injury and burns. Do not wear pants with cuffs. Wear the bottoms of your pants over the tops of your boots to keep out sparks and flying metal. Do not tuck pant legs into your boots.

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Hand Protection

Wear flame-resistant gloves, such as leather welder’s gloves. Always wear dry, hole-free, insulated welding gloves in good condition. They will help protect your hands from burns, sparks, heat, cuts, scratches, and electric shock. Hearing Protection

If loud noise is present, wear approved ear plugs or ear muffs to protect your hearing and prevent hearing loss. When working out of position, such as overhead, wear approved earplugs or muffs. They prevent sparks, spatter, and hot metal from entering your ears and causing burns. Respiratory Protective Equipment

When controls such as ventilation fail to control airborne contaminants to allowable levels or when the implementation of such controls is not feasible, respiratory protective equipment shall be used to protect employees from hazardous concentrations of air contaminants. Only approved respiratory protection (NIOSH approved respirators) shall be used and employee use of respirators must meet the University Respiratory Protection Program Requirements. Eye and Face Protection

Welding, cutting, and allied hot work processes presents various hazards to the welder’s eyes and face: the intense heat from arc rays and welding sparks can cause burns to the skin and eyes, during electric welding and welding processes. Personal Protective Equipment for the eyes and face is very important for both the welder and other personnel working near welding operations. Filter lens shall be in accordance with ANSI Z87.1. For Electric Arc Welding and Arc Cutting: Helmets with filter lenses and cover lenses shall be used by operators and nearby personnel when viewing the arc. For electric welding, the minimum lens shade should be at least #10. If the electrodes are larger than 5/32″ a darker lens compensates for the additional amperage required for the electrode. If the process uses a shielding gas, the lens shade should increase to at least #11 or #12. A darker shade is necessary because the presence of the gas increases the reflective intensity of the arc. Welding helmets with a filter lens of #5 is the minimum protection for gas welding and cutting; however the protection required may increase to shade #8 dependent on the operation. Goggles or other approved eye protection shall be worn by persons in the work area during oxy fuel gas welding and cutting operations. See the below OSHA welding and cutting lens selector guide for the selection of welding lens for this process. This welding helmet(s) are used for head, face, and eye protection which welders use adjustable (auto lens and Auto Darkening Helmet):

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RESPIRATORY

PROTECTION PROGRAM

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PURPOSE

A. This respiratory program is designed to prevent on the job health injuries to employees from contaminated breathing air. This program is limited to the respirators required for the protection of employees performing the sandblasting and painting operations of this company.

B. Respiratory protective equipment may be used to supplement but is not to be used in lieu of engineering control measures where practical.

C. A respirator’s purpose is to prevent the inhalation of harmful airborne substances Respirators remove contaminants from the air before they are inhaled or they supply respirable air from a contaminant free source.

GENERAL

A. Respirators work on one of two basic principles: Air- Purifying or Air Supplied

1. Air- Purifying respirators remove contaminants from the surrounding air before they can be inhaled. These respirators are grounded into three general types: particulate removing, vapor and gas removing and combination.

Elements which remove particulates are called filters. Vapor and gas removing elements are called chemical cartridges filters and cartridges. Filter and cartridges are the functional portion of air-purifying respirators, and they can generally be removed and replace dafter their effective life, except for single use disposable respirators.

A. Particulate removing respirators have filters to remove nuisance dusts, mists, fumes, or mixtures of these substances. B. Vapor and gas removing respirators have sorbent elements called chemical

cartridges that absorb the vapors and gases. C. Combination respirators have filters and cartridges to remove particulates plus

vapors and gases.

Advantages of using air-purifying respirators are that they are relatively inexpensive, small, easily maintained and are at least restrictive to the wearers’ movement. Many combinations of face pieces, filters and cartridges permit the user to adapt a properly fitted and effective respirator to a special exposure situation.

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Disadvantages of using air-purifying respirator are that they cannot be used in atmospheres which oxygen deficient or otherwise immediately dangerous to life and health (IDLH), or when the chemical contaminant gas or vapor has inadequate warning properties such as odorless, colorless, or tasteless, or when the odor threshold is so high that if the odor is detected you are above the threshold limit value. The maximum use concentrations may restrict due to face sealing problems or because of small sorbent or filter capacity. They require fit testing. 2. Air-Supplied respirators provide clean air from a source independent of the surrounding atmosphere. These respirators are classified by the method by which air is supplied. These are:

A. self-contained breathing apparatus (SCBA) where breathing air is carried in a tank on the person.

B. Air-Line respirators where compresses air from a stationary source through a High pressure hose is connected to a mask or hood.

C. Combination of air-line and self-contained respirators. ADVANTAGES of this kind of respiratory protection are that certain types of air supplied respirators, A and C above, can be used in environments which are immediately dangerous to life and health. They can be used for protection from contaminants that have poor warning properties. DISADVANTAGES are that these respirators are cumbersome, limit movement and impede mobility and productivity of the person. B. Respirators are of two general “fit” types.

1. Tight-fitting: a. Half-mask, which fits over the nose and under the chin such as a painter’s combination type filters/cartridge respirator or an air supplied respirator. b. Full-nose piece, which covers from above the eye to below the chin such as air- supplied respirators used in hazardous environments where eye and face protection is required. 2. Loose-fitting hoods and helmets such as sandblaster’s hood.

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SELECTION AND USE OF RESPIRATORS

A. Only respirators approved by the National Institute of Occupational Safety and Health (NIOSH) shall be used.

B. Respirators shall be selected on the basis of an evaluation of the following information for each work situation.

1. The nature of the hazard. 2. The airborne concentrations of the hazardous material 3. The nature of the work operation 4. The period of time respiratory protection must be worn during work shift. 5. The work activity of the employees and the potential stress of the work conditions on the employees wearing respirators. 6. Fit test results. 7. Warning properties of the hazardous materials. 8. The physical characteristics, functional capabilities, and limitations of

the various types of respirators. 9. Material safety data sheet information.

C. The nature of the hazard must be determined before an appropriate respirator can

be selected. The physical form of the hazard must be identified as being a particulate, a vapor or gas, or a combination of these. Assessment must be made as to whether or not the hazard causes and oxygen deficiency (less than 19.5% oxygen in the air) as an asphyxaint can cause combustion or is an immediate danger to life or health at the concentration level’s encountered.

D. After the hazard has been identified, quantities must be considered by checking the concentrations of the contaminant. If the amounts exceed the allowable Ceiling Valves, the 8-hour time weighted averages, or acceptable Ceiling Concentrations found in Tables Z-1, Z-2 and Z-3 of OSHA Standard CFR 1910.1000, Air contaminants, a dangerous exposure condition exists and respirators shall be used.

E. Respirators are normally issued for the exclusive use of one worker. A qualitative individual fit test (Appendix B) must be performed to insure the user does not breathe the contaminant when air-purifying respirators are used. Half-mask or full-face piece cartridge respirators successfully fit tested on an employee by the qualitative test procedure may be used in contaminated atmospheres up to ten times the established exposure limits. A qualitative fit test shall be conducted annually for each employee using air-purifying respirators. Results shall be recorded.

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F. A full-face piece respirator shall be used if the contaminant caused eye irritation and

protective clothing must be used if skin irritations are caused. G. Immediately Dangerous to Life or Health (IDLH) atmospheres required that the

employee wear positive pressure self contained breathing apparatus (SCBA) or a combinations full-face piece pressure demand supplied air respirator with auxiliary self-contained air supply cylinder. Persons using air line respirators in IDLH atmosphere shall be equipped with safety harnesses and safety lines for lifting or removing persons form hazardous atmospheres or other and equivalent provisions for rescue shall be used. Another employee positioned out of the contaminated atmosphere must be in communication with the employee in the IDLH atmosphere and able to provide effective emergency assistance. Rescue personnel shall be equipped with positive pressure self contained breathing apparatus, or the equivalent.

H. Breathing Air Quality :

1. Compressed air used as breathing air shall be of high purity. Breathing air shall

meet the requirements of the specification for grade D breathing air as described in Compressed Gas Association Commodity Specification G-7.1-1996.

2. Breathing air may be supplied to respirators from approved cylinders on air compressors.

3. Plant air shall not be used for breathing air. 4. Company policy is to use only company owned air compressors for breathing

air. If other than a company air compressor is in use the air quality shall be tested prior to breathing the air.

5. Compressors shall be positioned to avoid entry of contaminated air into the system and suitable installed inline purifying sorbent elements and filters installed to ensure breathing air quality.

6. Compressors shall have a receiver of sufficient capacity to permit a respirator wearer to escape from a contaminated area if the compressor fails.

7. Oil-lubricated compressors shall have a high-temperature or carbon monoxide alarm, or both. If only a high-temperature alarm is used, the air from the compressor shall be frequently tested for carbon monoxide to ensure its purity as breathing air.

8. Breathing air line couplings shall be incompatible with line couplings for other gas systems to prevent connecting air lines respirators with non-respirable gases or oxygen.

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A General Guide for Selection of Respirators

IMMEDIATELY DANGEROUS TO LIFE OR HEALTH (IDLH)

HAZARD RESPIRATOR

OXYGEN DEFICIENCY IDLH SELF CONTAINED BREATHING APPARATUS, (SCBA) OR COMBINATION AIR-LINE RESPIRATOR WITH AUXILIARY SELF-CONTAINED AIR SUPPLY

CYLINDER

GAS AND VAPOR CONTAMINANTS IDLH SCBA ORCOMBINATION AIRLINE RESPIRATOR WITH AUXILIARY SELF-CONTAINED AIR SUPPLY

CYLINDER. PARTICULATE CONTAMINANTS IDLH SCBA OR COMBINATION AIR-LINE RESPIRATOR

WITH AUXILIARY SELF-CONTAINED AIR SUPPLY CYLINDER.

COMBINATION GAS, VAPOR, AND PARTICULATE CONTAMINANTS IDLH

SCBA OR COMBINATION AIR-LINE RESPIRATOR WITH AUXILIARY SELF-CONTAINED AIR SUPPLY

CYLINDER.

NOT IMMEDIATELY DANGEROUS TO LIFE OR HEALTH

HAZARD RESPIRATOR

GAS AND VAPOR CONTAMINANTS AIR-LINE RESPIRATOR OR AIR-PURIFYING HALF MASK OR FULL FACE PIECE RESPIRATOR.

PARTICULATE CONTAMINANTS AIR-LINE RESPIRATOR OR AIR-PURIFYING HALF MASK OR FULL FACE PIECE RESPIRATOR. AIR-LINE ABRASIVE BLASTING RESPIRATOR.

COMBINATION GAS, VAPOR, AND PARTICULATE CONTAMINANTS

AIR-LINE RESPIRATOR OR PARTICULATE CONTAMINANTS AIR-PURIFYING HALF MASK OR FULL FACE PIECE RESPIRATOR.

I. Approved Respirator Usage. The following NIOSH approved respirators, or the equivalent, shall be used by employees of this company for respiratory protection from the hazard indicated while performing the work tasks listed.

IMMEDIATELY DANGEROUS TO LIFE OR HEALTH/ATMOSPHERE (IDLH)

HAZARD/WORK TASK RESPIRATOR

OXYGEN DEFICIENCY OR COMBINATION GAS, VAPOR AND PARTICULATE CONTAMINANTS IDLH

COMBINATION AIR-LINE RESPIRATOR WITH AUXILIARY SELF-CONTAINED AIR SUPPLY

SPRAY PAINTING IN ENCLOSED SPACED WHERE VENTILATION DOES NOT REDUCE THE

CONTAMINANTS BELOW ACCEPTABLE LIMITS. RESCUE FROM IDLH AREAS.

SCOTT COMBINATION PRESSURE DEMAND BREATHING APPARATUS

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NOT IMMEDIATELY DANGEROUS TO LIFE OR HEALTH

HAZARD/WORK TASK RESPIRATOR

DUST, MIST, FUMES, PARTICULATE CONTAMINANTS, CHIPPING, CLEAING, HAND

SANDING, WIRE BRUSHING, ATTENDING SAND POT, WORKING IN DUSTY AREA, OR CLEAN-UP

3M EASY-AIR DUAL CARTRIDGE WITH 7255, 7256, OR 7258 FILTERS, OR WILSON 1200 SERIES WITH R-12, OR R-16 FILTERS, OR DISPOSABLE 3M 8710

OR MOLDEX 2200

ORGANIC VAPORS, PAINT, LAQUER, ENAMEL MISTS AND DUST, COMBINATION GAS VAPOR AND PARTICULATE CONTAMINANTS. SPRAY

PAINT OPERATIONS WHERE THE CONTAMINANTS DO NOT CAUSE IDLH ATMOSPHERE.

AIR PURIFYING HALF-MASK, 3M EASY-AIR WITH 7251 ORGANIC VAPOR CARTRIDGES AND 7255

OR 7256 FILTERS, OR WILSON 1200 SERIES WITH R-21 OR R-31 ORGANIC VAPOR CARTRIDGES AND

R-12, R-15 OR R-16 FILTERS.

DUST, PARTICULATE CONTAMINANTS FROM SANDBLASTING OPERATIONS

AIR-LINE ABRAISIVE BLASTING RESPIRATOR ABRAISIVLE PRODUCTS AND EQUIPMENT

SUPPLIED AIR RESPIRATOR MODEL SANDBLAST HOOD

MEDICAL EVALUATION

A. An employee shall not be assigned to work situations where respirator protection is required until it has been determined that the employee is medically and physically able to perform the work while using the required respirator.

B. Each employee required to wear respiratory protection shall complete Appendix A, questionnaire to Determine if Employees are Medically Fit For Use of Respiratory Protection Equipment.

C. A complete physical by a physician to include pulmonary function testing may be required after a review of Appendix A and it fit testing difficulties are experienced by an employee.

D. Each employee is responsible for reporting, to his job supervisor who shall report to the Company Safety Coordinator, any changes in his medical or physical status or if any difficulty in breathing is experienced. Employee reports of changes in his medical or physical status and reports of breathing difficulties shall require a review of the employee’s fitness to wear a respirator and perform his work assignments safely.

E. Periodic check shall be made by the Company Safety Coordinator to determine if an employee is still medically fit to wear a respirator.

F. An annual medical review of employees required to wear respirators shall be conducted by the Company Safety Coordinator.

G. Records shall be maintained of all employee medical evaluations, and each employee shall have access to these records as provided in 29 CFR 1910.20.

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MAINTENANCE AND CARE OF RESPIRATORS

A. Respiratory Protective Equipment must be properly maintained. A poorly maintained respirator may be completely incapable of protecting a wearer who is depending on the respirator to protect his health. Respirators must be kept clean and sanitary. The filters and cartridges must be replaced frequently depending on the concentration of contaminants and the length of time used.

The maintenance and care program shall be adjusted to the work location, working conditions and the hazards encountered, and shall include: Inspection and repair, cleaning and disinfecting, and storage.

1. INSPECTION AND REPAIR A. Frequent inspections of respirators shall be conducted by the job site

supervisor and/or the safety coordinator to ensure that the respirator is correct for the hazard condition, clean, properly fitted and maintained, and functions properly.

B. Each employee shall inspect his respirator prior to each use and shall not

attempt to use a defective respirator. Inspection shall include:

1. Face pieces-pliable, not dried, cracked or distorted. Massage rubber parts to keep them pliable.

2. Valves-soft, pliable, not cracked or distorted. Check valve seats to be clean and not cracked.

3. Headbands and straps- intact and good elasticity. 4. Filters/cartridges/gaskets- conditions and properly positioned. 5. Air supply cylinders charged to the manufacturer’s specifications. 6. All connections tight.

C. Respirator repairs and parts replacement shall be made under the direction of

the job supervisor. Replacement parts shall be identical with those furnished by the manufacturer under the NIOSH approval. Repairs, replacements or adjustments beyond the manufacturer’s recommendations shall not be made.

D. Reassembly of the respirator shall be in accordance with the manufacturer’s instructions for the model respirator in use.

E. Combination air-line respirators with auxiliary self-contained air supply cylinders not routinely used by kept ready for emergency use shall be inspected before and after each use and at least monthly to ensure that it is in

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satisfactory working condition. Air cylinders shall be charged to the manufacturer’s specifications. These respirators shall be cleaned and disinfected after each use. Emergency use respirator inspections shall be recorded on a tag on the respirator. Massage the rubber parts to keep them pliable and prevent them from taking a set during storage. The carrying case contains the proper storage instructions.

2. CLEANING AND DISENFECTING A. Cleaning of a respirator is recommended after each day’s use. If a respirator is

used for only a short time each day it may be sprayed with a respirator disinfectant after each use and thoroughly cleaned after several uses.

B. Remove filters and cartridges first. Do no wash these items. C. Disassemble the respirator parts and wash, using a soft hand brush, in a warm

solution of detergent-germicide and clean water. Rinse in clean, warm water and air dry in a non contaminated atmosphere.

D. Inspect parts and reassemble part per the manufacturer’s instructions. E. Replace cartridges and filters as needed depending on the exposure, odor and

resistance to breathing.

3. STORAGE A. Respirators shall be stored in tightly closed plastic bags protected from the sun

and high temperatures and humidity as much as is practical. B. Respirators not used regularly shall be removed from storage, inspected,

massaged and repaired and cleaned as needed at least monthly.

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TRAINING

A. Employees required to wear respirators to perform assigned job tasks shall be thoroughly trained in the contents of this respirator program.

B. Every respirator wearer shall receive individual attention in the process of respirator selection, fitting, familiarization, and fit testing in a test atmosphere.

C. Respirators shall no be worn when conditions such as facial hair, or eye glasses prevent a good piece seal. Contact lenses shall not be worn with respirators in a contaminated-atmosphere. The absences of one or both dentures may prevent a good face piece seal.

D. Employees who wear corrective eyeglasses may require a specially fitted full face piece respirator.

E. Periodic training sessions shall be conducted on the job during respirator inspections.

PROGRAM EVALUATION

A. Management shall review this program annually and conduct frequent visits to the work sites to ensure that the provisions of the program are being properly and effectively implemented.

B. Management shall consult employees wearing respirators to assess wearer acceptance and initiate corrective actions to eliminate any problems that are revealed.

RECORD KEEPING AND ACCESS TO RECORDS

A. The employer shall record, maintain, and provide access to records of exposure monitoring and medical surveillance in accordance with 29 CFR 1910.20, access to employee exposure and medical records

B. A record shall be kept of inspection dates and findings for respirators maintained for emergency use.

C. A record of employee fit tests in a test atmosphere shall be maintained.

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ACRONYMS ACGIH – American Conference of Governmental Industrial Hygeinists MSDS – Material Safety Data Sheet TWA – Time Weighted Average IDLH – Immediately Dangerous to Life or Health SCBA – Self Contained Breathing Apparatus NIOSH – National Institute of Occupational Safety and Health OSHA – Occupational Safety and Health Administration (or act) LEL – Lower Explosive Limit UEL – Upper Explosive Limit PEL - Permissible Exposure Limit (established by OSHA) TLV – Threshold Limit Value (established by ACGIH)

The letters ST used with PEL or TLV indicate Short Term exposure limit. Short Term is defined as a period not exceeding 15 minutes and no more than (4) times on an 8 hour workday.

The letter “C “following PEL or TLV denotes a CEILING Limit that may not be exceeded at any time.

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APPENDIX B FIT TESTING OF RESPIRATORS

A. A respirator must be comfortable and properly fitted to the person to provide adequate protection. An employee to be fitted with a respirator shall be permitted to select the most comfortable respirator from a selection of sizes from different manufacturers. He shall be shown how to put on a selected respirator using the manufacturer’s instructions. Respirator position and tension and comfort shall be covered. A mirror should be provided.

B. The selected respirator shall be put on by the user, have it properly adjusted and test its face-piece to face seal by the positive and negative pressure face-fit methods. Then wear the respirator in normal air for at least five minutes for familiarization and to test its comfort before it is worn in a test atmosphere.

C. Positive Pressure Face-Fit Test. Place the palm of the hand or the thumb over the exhalation valve cover and exhale gently. If the face piece bulges slightly and no air leaks between the face and face piece are detected, a proper fit has been obtained. If air leakage is detected, reposition the respirator on the face and readjust the tension of the straps. Repeat this procedure until a tight seal is obtained.

D. Negative pressure Face-fit Test. Place the palm of the hands over the open area of the cartridge caps, inhale gently and hold your breath for five to ten seconds. If the face piece collapses slightly, a proper fit has been obtained. If air leakage is detected, reposition the respirator on the face and readjust the straps and repeat the procedure until a tight seal is obtained.

E. Qualitative Fit Test Procedures for half-mask cartridge respirators.

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ISOAMYL ACETATE (BANANA ODOR) TEST.

A. The test subject shall put on his respirator and perform the positive and negative pressure face fit tests.

B. The respirator shall be equipped with organic vapor cartridges. C. The test subject shall be given a copy of the following test exercises and the

rainbow passage or other equally effective passage which will adequately test the effects of talking on the fit test.

TEST EXERCISES

1. Breathe normally 2. Breathe deeply 3. Turn head all the way from one side to the other. Inhale on each side. Do not bump the respirator against the shoulders. 4. Nod head up and down. Inhale when head is in the fully up position looking at the ceiling. Do not bump the respirator on the chest. 5. Read the Rainbow Passage aloud slowly. 6. Job in place. 7. Breathe normally.

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RAINBOW PASSAGE When the sunlight strikes raindrops in the air, they act like a prism and form a rainbow. The rainbow is a division of white light into many beautiful colors. These take the shape of a long round arch, with its path high above, and its two ends apparently beyond the horizon. There is, according to legend, a boiling pot of gold at one end. People look, but no one ever finds it. When a man looks for something beyond reach, his friends’ say he is looking for the pot of gold at the end of the rainbow.

D. A fit check ampoule of Isoamyl Acetate (IAA) shall be broken and the ampoule passed around the test subject’s face and respirator while he performs the test exercises and reads the Rainbow Passage. Each exercise shall be performed for at least one minute.

E. If the test subject detects the banana-like odor at any time during the test, procedure, the test has failed the subject shall leave the test area, return to the selection area free of the IAA odor, select and put on another respirator and repeat the IAA test procedure.

F. When the respirator is found that passes the IAA test, the test subject breaks the face seal and takes a breath in the test area. This is to assure that the reason the test subject does not smell the IAA is the good fit of the respirator and not sense of smell fatigue.

I certify that I have read or have had it read to me and understand the attached company safety policy and that I shall comply with the rules and safe work practices contained herein. I also understand that willfully or negligently failing to comply with this company’s Safety Policy, as contained herein, shall or could be ample reason for immediate termination. Date:__________________________ Employee________________________________ (Print) Supervisor:______________________ Employee Signature: _______________________

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EXCAVATION AND TRENCHING

Competent Person

OSHA standards require that trenches be inspected daily and as conditions change by a competent person prior to worker entry

to ensure elimination of excavation hazards. A competent person is an individual who is capable of identifying existing and predictable hazards or working conditions that are hazardous, unsanitary, or dangerous to employees and who is authorized to

take prompt corrective measures to eliminate or control these hazards and conditions. All underground installations / buried utilities are located and/or marked before digging.

Before Excavating and Trenching Guidelines Duties /Responsibilities of the Competent Person:

Follow the guidelines below before beginning excavation and trenching operations:

1. Ensure general public safety. 2. Evaluate soil conditions or other material to be dug.

3. Evaluate the water table level and percolation conditions. 4. Evaluate proximity to underground utility, cable, and pipelines.

5. Mark all underground utilities, cables, and pipelines.

6. Evaluate proximity to buildings, roads, railroad tracks, and public right-of-way. 7. Contact owners of utilities, right-of-ways, transmission piping, etc.

8. Ensure all employees receive proper training, including first aid and CPR, and are competent in excavation and trenching operations. Employees shall not work under suspended loads.

9. Ensure there is adequate equipment, including personal protective equipment, shoring materials, signs, fire extinguishers,

barricades, guardrails are installed for crossings and walkways to protect against falls and machinery, before starting the job.

10. Check the location of heavy equipment, power shovels, backhoes, trenchers, trucks, and spoil pile to ensure they are at least two feet from the opening edge.

11. Ensure shoring equipment or trench boxes/shields are adequate for the job at hand. After evaluating and completing the above tasks, additional precautionary measures may need to be taken before starting any

excavation or trenching operations.

Access and Egress

OSHA requires safe access and egress to all excavations, including ladders, steps, ramps, or other safe means of exit for

employees working in trench excavations 4 feet (1.22 meters) or deeper. These devices must be located within 25 feet (7.6 meters) of all workers. The excavation/trench shall be inspected by a competent person on a daily basis.

General Trenching and Excavation Rules

Keep heavy equipment away from trench edges.

Atmospheric testing shall be performed, classifying and stabilizing soil. Keep surcharge loads at least 2 feet (0.6 meters) from trench edges.

Know where underground utilities are located. Test for low oxygen, hazardous fumes and toxic gases.

Inspect trenches at the start of each shift. Inspect trenches following a rainstorm for accumulation of water in an excavation/trench.

Do not work under raised loads.

Additional Information

Visit OSHA’s Safety and Health Topics web page on trenching and excavation at http://www.osha.gov/SLTC/trenchingexcavation/ index.html

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FALL PROTECTION PROGRAM Fall protection training is required of all employees who might be exposed to fall hazards. This training shall enable each employee to recognize hazards of falling and shall train each employee in the procedures to follow to minimize these hazards. Written certification records shall be maintained by the Safety Coordinator. These records shall show the following:

1. Who was trained, when & dates of training 2. Signature of who provided the training & date it was determined

that training was deemed adequate. Retraining shall be provided when the following are noted:

1. Deficiencies in training 2. Work place changes 3. Fall protection systems or equipment changes that render

previous training obsolete.

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Fall protection is required whenever employees are potentially exposed to falls from

heights of 6 feet or greater to lower levels. This includes work near and around excavations. Use of guardrails, safety net, or personal fall arrest systems should be used. When the standard methods of protection are not feasible or a greater hazard would be created, the exposure determination shall be made without regards to the use of PPE. The company shall discus the extent to which scaffolds, ladders or a vehicle mounted work platforms can be used. The option of a fall protection plan is an available option only to employees engaged in leading edge work, precast concrete construction work, or residential construction work who can demonstrate that it is infeasible or it creates a greater hazard to use conventional fall protection equipment. Prompt rescue of employee in the event of a fall. Coastal LLC will provide for prompt rescue of employees in the event of a fall or shall assure the employees are able to rescue themselves. The fall protection plan shall conform to the following provisions:

1. The fall protection plan shall be prepared by a qualified person and developed specifically for site where the leading edge work, precast concrete work, or residential work is being performed and the plan must be maintained up to date.

2. Any changes to the fall protection plan must be made by a qualified person. 3. A copy of the fall protection plan with all approved changes shall be maintained at

the jobsite. 4. The implementation of the fall protection plan shall be under the supervision of a

competent person.

5. The fall protection plan shall document the reasons why the uses of conventional fall protection systems (guardrails systems, personal fall arrest systems, or safety net systems) are infeasible or why their use would create a greater hazard.

6. The fall protection plan shall include a written discussion or other measures that will be taken to reduce or eliminate the fall hazard for workers who cannot be provided with protection from the conventional fall protection systems. For example, discuss the extent to which scaffolds, ladders, vehicle mounted work platforms can be used to provide a safer working surface and thereby reduce the hazard of falling.

7. The fall protection plan shall identify each location where conventional fall protection systems cannot be used. These locations shall then be classified as controlled access zones and the company must comply with 29CFR1926.502(g).

8. Where no other alternative measure has been implemented, the company shall implement a safety monitoring system in conformance with 29CFR1926.502(h).

9. The fall protection plan must include a statement which provides the name or other method of identification for each employee who is designated to work in controlled access zones.

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10. In the event an employee falls, or some other related, serious incident occurs, (e.g., a near miss) the company shall investigate the circumstances of the fall or other incident to determine if the fall protection plan needs to be changed(e.g., new practices, procedures, or training) and shall implement those changes to prevent similar types of falls or incidents.

Safety monitor systems shall comply with the following provisions. The company shall

designate a competent person to monitor the safety or other employees and the company shall ensure that the safety monitor complies with the following requirements.

1. The safety monitor shall be competent to recognize fall hazards. 2. The safety monitor shall warn the employee when it appears that the employee is

unaware of a fall hazard or is acting in an unsafe manner. 3. The safety monitor shall be on the same walking/working surface and within visual

sighting distance of the employee being monitored. 4. The safety monitor shall be close enough to communicate orally with the employee

being monitored. 5. The safety monitor shall not have other responsibilities which could take the

monitors attention from the monitors function.

Mechanical equipment shall not be used or stored in areas where safety monitoring systems are being used to monitor other employees engaged in roofing operations on low sloped roofs.

No employee, other than an employee engaged in roofing work (on low sloped roofs), or an employee covered by a fall protection plan, shall be allowed in an area where an employee is being protected by a safety monitoring system. Each employee working in a controlled access zone shall be directed to comply promptly with Fall Hazard warning from safety monitors. When purchasing equipment and raw materials for use in fall protection systems, all applicable ANSI & ASTM requirements shall be met.

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LADDER SAFETY Falls from portable ladders (step, straight, combination and extension) are one of the leading causes of occupational fatalities

and injuries.

Read and follow all labels/markings on the ladder. Avoid electrical hazards! – Look for overhead power lines before handling a ladder. Avoid using a metal ladder near

power lines or exposed energized electrical equipment.

Always inspect the ladder prior to using it. If the ladder is damaged, it must be removed from service and tagged until repaired or discarded.

Always maintain a 3-point (two hands and a foot, or two feet and a hand) contact on the ladder when

climbing. Keep your body near the middle of the step and always face the ladder while climbing (see diagram).

Only use ladders and appropriate accessories (ladder levelers, jacks or hooks) for their designed purposes.

Ladders must be free of any slippery material on the rungs, steps or feet. Do not use a self-supporting ladder (e.g., step ladder) as a single ladder or in a partially closed

position.

Do not use the top step/rung of a ladder as a step/rung unless it was designed for that purpose. Use a ladder only on a stable and level surface, unless it has been secured (top or bottom) to prevent

displacement. Do not place a ladder on boxes, barrels or other unstable bases to obtain additional height.

Do not move or shift a ladder while a person or equipment is on the ladder. An extension or straight ladder used to access an elevated surface must extend at least 3

feet above the point of support (see diagram). Do not stand on the three top rungs of a straight, single or extension ladder.

The proper angle for setting up a ladder is to place its base a quarter of the working length

of the ladder from the wall or other vertical surface (see diagram). A ladder placed in any location where it can be displaced by other work activities must be

secured to prevent displacement or a barricade must be erected to keep traffic away from the ladder.

Be sure that all locks on an extension ladder are properly engaged. Do not exceed the maximum load rating of a ladder. Be aware of the ladder’s load rating and

of the weight it is supporting, including the weight of any tools or equipment.

Maintaining Ladders

Inspect ladders regularly. Ladders used by Coastal LLC employees shall meet OSHA/ANSI specifications. Stepladders and extension ladders should be inspected for broken or frozen joints or latches. Aluminum ladders should be inspected for cracks and broken welds. Ladder rungs, cleats, and steps shall be parallel, level, and uniformly spaced, when the ladder is in position for use.

Aluminum ladders should also be inspected for rough spots and burrs before first use.

Wood ladders should be inspected for cracked wood, splinters, and rot. Look for broken or loose hardware. Protect wood ladders with linseed oil or clear sealant. Never paint a wooden ladder - the paint may hide imperfections such as rot or cracks.

Fiberglass ladders are protected with a clear sealant. If the fiberglass is damaged through the sealant, sand lightly before applying another coat of lacquer.

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AERIAL LIFTS AERIAL LIFTS. -1926.453

Aerial lifts acquired for use which were manufactured on or after January 22, 1973 will have a placard or label affixed which indicates that the lift is designed and constructed in accordance with ANSI standard A92.2-1969. Aerial lifts acquired for use prior to January 22, 1973 may not be used unless modified to meet this standard. 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 equivalent entity that the aerial lifts conform with ANSI standard A92.2-1969 and are as safe as before modifications. Aerial lifts include the following types of vehicle-mounted aerial devices to elevate personnel to job-sites above the ground:

A. extensible boom platforms. B. aerial ladders. C. articulating boom platforms. D. vertical towers. E. a combination of any of the above.

Only authorized persons may operate an aerial lift.

Lift controls and equipment must be inspected and tested each day prior to use to determine they are in a safe working condition.

When working from an aerial lift, you must stand firmly on the floor of the basket or cage and use (wear) and an approved fall restraint system.

The fall restraint system must be attached to the boom or basket – it may not be attached to any adjacent pole, structure, or other equipment.

You may not sit or climb on the edge of the basket; use planks, ladders, or other devices for a work position.

Load limits set by the manufacturer must never be exceeded.

The brakes must be set and when outriggers are used, they shall be positioned on pads or a solid surface.

Aerial lifts must not be moved with personnel in the basket unless it is designed for this type of operation. Aerial lifts designed as personnel movers must have controls that are clearly marked as to their use and the lower controls must be able to override the upper controls. Except in an emergency, the lower controls shall not be used unless permission has been granted by the persons in the lift. It is required that the vehicle have a “reverse signal alarm” audible above the surrounding noise level or a ground-guide (spotter), using standard hand signals, when backing up. The vehicle will be backed up only when the spotter signals that it is safe to do so. Using a ground-guide provides a substantially higher level of safety than a “reverse signal alarm” because the vehicle can be guided to an exact location with assurance that there is sufficient clearance from objects, and, most importantly, no person is in harm’s way. Special attention will be given to electrical lines. Extreme care must be exercised to avoid contact with electrical energy.

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HEAVY EQUIPMENT AND ELECTRICAL POWER LINES Except where electrical distribution and transmissions lines have been deenergized and visibly grounded at point of work or where insulating barriers (not attached to the vehicle) have been erected to prevent physical contact with the lines, the following clearance -- between any part of the equipment, load line, or load and the power line -- will be observed:

A ground guide will be designated to observe clearance of the equipment and give warning to the equipment operator in situations where it is difficult for the equipment operator to maintain the desired clearances by visual means. An overhead wire will be considered energized unless the owner of the line or the electrical utility authorities indicate that it is not energized and it has been visibly grounded.

CRANES What is a crane? A crane is a mechanized piece of equipment used to hoist loads for various reasons. A crane uses cable and pulley or hydraulic systems to lift, lower and swing the load into position. A crane may be stationary or mobile. Some common hazards associated with cranes include the following: Power line contact – crane structure contacts overhead lines Overloading – exceeding the rated capacity or tipping load Outrigger Failure – outriggers not extended, crane on soft ground, structural defects Two-blocking – contact of the hoist block or hook assembly with boom tip causing parting of hoist line and loss of load

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Signal person- is used when the operator's view is obstructed. Pinch point – accessible areas within swing radius of rotating superstructure where employees become crushed or squeezed Unguarded moving parts – all parts within cab, engine compartment or service area that employees must enter or reach into Unsafe hooks – (when required) hooks without latches or damaged/defective latches Obstruction of vision – operator, rigger or signaler vision blocked by load or work environment Improper assembly/disassembly – failure to follow manufacturer’s procedures Employee/Operators operating cranes will be trained on: • Proper pre-shift inspection techniques and items to be inspected. • Proper use of the equipment. • Contents of manufacturers’ operations manual. • Lock out/Tag out procedure. • How to document the inspections. • Who to contact in the event that a product requires service or repair. Employees operating, rigging and working on the ground around a crane all have responsibilities to ensure its safe operation. Always follow your employer’s safety program for cranes and never operate, rig or work with a crane if you are not properly trained. Remember to always mark /barricading the area within the crane's swing radius. And get written approval from the manufacturer (or a Professional Engineer) must be obtained before modifying equipment if the changes may impact safe operation. Rules to follow when operating a crane: Cranes must be placed on stable ground. Equipment must not be assembled or used unless ground conditions are firm, drained, and graded to a sufficient extent so that, in conjunction (if necessary) with the use of supporting materials, the equipment manufacturer’s specifications for adequate support and degree of level of the equipment are met. All manufacturer's specifications/instructions are followed during assembly and/or disassembly. A competent / qualified person must direct the assembly and/or disassembly of equipment. A pre-operation hazard assessment is performed to identify the work zone. control measures taken if it is determined that any part of the equipment may come within 20 feet of a power line. Equipment is inspected before use. All safety devices must be in proper working order before operation. Manufacturer instructions/procedures (operator's manual) must be followed. Crane operation procedures (operator's manual) must be readily available in the cab at all times. If there is a safety concern the operator may refuse to lift a load.

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EMERGENCY ACTION PLAN

This emergency action plan is written to ensure employees safety in the event of a fire

or any other reasonably foreseeable emergency. This plan shall be reviewed with each employee initially when the plan is developed, new employee orientation, employee’s responsibilities or designated actions under the plan change and whenever the plan is changed. All employees shall be trained in an educational program to familiarize themselves with the general principles of fire extinguisher use and the hazards involved with the incipient employment and at least annually thereafter.

To report an emergency use the telephone paging system. The Corpus Christi Fire Department shall be contacted at 911 in case of life threatening emergencies of fire, EMT, and/rescue. Emergency escape and exit routes shall be the safest means of egress to the front of the shop and office. All plant operations shall be shut down and all employees shall report to the front of the shop or office for accountability by the shop foreman and the office manager, who are to be contacted for information or clarification. The above mentioned training shall include but not limited to proper use of portable fire extinguishers. Escape procedures, exit routes, and employee accounting following an emergency evacuation, rescue and medical duties, persons to be contacted for information or clarification.

This training shall be conducted upon initial assignment, new employee orientation, and annual refresher training. The student population shall be no more than fifty employees in a training class. The instructors shall be the safety coordinator, shop foreman, and/or the office manager. There will be new training whenever the emergency plan changes.

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SAFEGUARDS FOR MECHANICAL EQUIPMENT

1. Except when removed for the purpose of testing or repairing the machinery, all guards and other safety devices shall be securely in place while machinery is being operated.

2. No hand-held power tools shall be operated unless they are equipped with controls requiring constant hand or finger pressure or shall be equipped with friction or other equivalent safety devices.

3. Mobile and stationary equipment shall be maintained in safe operating condition and machinery or equipment in unsafe condition shall be removed from service immediately.

4. Machinery and equipment shall be operated only by persons trained in the use of and authorized to operate such machinery or equipment.

5. Repairs or maintenance shall not be performed on machinery until the power is off and the machinery is blocked against motion, except where machinery motion is necessary to make adjustments.

6. Machinery shall not be lubricated while in motion where a hazard exists. Unless equipped with extended fittings or cups.

7. Drive belts shall not be shifted while in motion unless the machines are provided with mechanical shifters. Belt dressing shall not be applied while belts are in motion except where it can be applied without endangering a person.

8. Belts, chains, and ropes shall not be guided onto power driven moving pulleys, sprockets, or drums with the hands except on slow moving equipment especially designed for hand feeding. Pulleys of conveyors shall not be cleaned manually while conveyor is in motion.

9. Do not operate mobile equipment, such as fork lifts, trucks, tractors, front end loaders, and graders, unless the automatic warning device which gives an audible alarm when such equipment is put into reverse gear is functioning.

10. Shovels, draglines, and tractors shall not be operated in the presence of any person exposed to a hazard from its operation. Al operators of such equipment shall give adequate warning prior to starting operation.

11. When booms and masts of equipment are required to pass under or by any energized high voltage power line and the clearance between such equipment and the power line is less than that specified in the Mandatory Safety Standards stated under the Health and Safety Act. Such power lines shall be de-energized and/or other safety precautions taken

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QUALIFIED AND CERTIFIED PERSONS

No one shall perform any work which requires the performance of certification under the provisions of applicable Health and Safety Laws unless they possess the required certification or qualification, or it is under the direct supervision of one who does.

SCAFFOLDING

Scaffolding is very important in our industry, however, scarcely a day goes by that we don’t hear about someone injured or killed in a scaffold fall. Inadequate design is sometimes to blame, but in most cases, scaffold falls are caused by careless maintenance and improper use. Specific requirements on scaffolding are detailed in ANSI A10.8 and OSHA 1926.451. Listed here are some of the basic requirements and use of scaffolding.

1. Footings shall be sound and rigid, capable of withstanding the maximum intended

weight. Unstable objects such as bricks, boxes, etc., shall not be used.

2. Only competent persons shall erect, move, or dismantle a scaffold.

3. Guardrails and toe-boards shall be installed on all open sides and ends 4 feet above the

floor. Guardrails shall be 42 inches high. Toe-boards shall be a minimum of 4 inches

high.

4. Screen shall be installed between the toe-board and a mid-rail when people are

required to pass underneath.

5. Any component of a scaffold weakened or damaged must be repaired or replaced

immediately.

6. Scaffold and their components shall be able to support at least times the intended load.

7. The maximum span for 2” x 12” planking shall be 8’. Minimum plank size shall not be

less than 2” x 10”. All planking shall be of scaffold grade material.

8. A ladder or other safe access must be provided.

9. A scaffold plank to extend over their end supports at least 6” but not more than 12”.

10. Overhead protection must be provided on a scaffold when subject to overhead hazards.

11. Slippery conditions on a scaffold shall be eliminated as soon as they occur.

12. Wire or wire rope used to suspend a scaffold shall be able to support at least six times

the intended load. No welding, cutting, burning, etc., shall be allowed on any scaffold

suspended by synthetic fiber or rope.

13. The legs or uprights of a scaffold shall be plumb and rigidly braced to prevent swaying.

Lean-to or shore type scaffolds shall not be used.

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SCAFFOLDS (TUBULAR WELDED FRAME)

1. The scaffold and its components shall be designed to support four times the intended load.

2. The scaffold shall be braced and the braces shall be of the proper length in order for the scaffold to remain plumb and rigid.

3. The entire scaffold shall be tied to and securely braced against the building or structure at intervals not to exceed 30’ horizontally and 26’ vertically.

4. Rolling scaffolds shall not be used on sloped surfaces. 5. The foundation of the scaffold shall be such that it will adequately support the

maximum intended load. FOR ADDITIONAL REQUIREMENTS ON A PARTICULAR TYPE OF SCAFFOLD REFER TO “OSHA SAFETY AND HEALTH STANDARDS (29CFR 1926/1910)”.

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WELDING AND BURNING OPERATIONS

1. Compressed gas cylinders shall be secured in an upright position. Valves on compressed gas cylinders shall be protected by valve covers when the cylinders are not in use. Gauges shall be protected from falling objects when in use. Valves shall be shut off when cylinders are not in use.

2. Employees shall wear appropriate welding protective apparel, including proper density lens protection.

3. When arc-welding near other workers, non-combustible screens must be used to prevent welder’s flash.

4. Oil and grease shall be kept away from oxygen and acetylene gauges and valves. 5. No cutting, welding or burning shall be conducted where there is oil, grease, flammable

liquids or gases, or combustible materials without first removing them from the area. Should it be impossible to remove them, they shall be protected by a metal barrier or some fire retardant material and a fire extinguisher shall be on hand.

6. Cutting, welding or burning shall not be conducted on tanks or drums which have contained flammable liquids or grease until they have been thoroughly cleaned or other precautions taken to prevent fire or explosion.

7. Employees shall ensure there is adequate ventilation when welding, cutting or burning in confined spaces or with exotic metals.

2,000 cubic feet per welder

5 welders = 10,000 cfm. Needed for ventilation

8. Do not use matches to light torches. Spark igniters must be used. Torches must not be

used to light smoking materials. 9. When a special wrench is required to operate the acetylene cylinder valve, the wrench

must be kept in position on the valve.

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CRANES/LIFTING EQUIPMENT

Only designated personnel shall be allowed to operate this equipment. The operator shall be trained in the safe work standards including the use of fire extinguishers. All operators shall successfully complete a written test and a hands-on operating test prior to beginning work or transferring to an operator position. This testing shall be conducted by COASTAL, LLCSafety Coordinator or his authorized representative. Annual and monthly crane inspection records shall be kept on file in the COASTAL, LLC Safety office. Rated load test, records confirming the adequacy of any repairs or alterations, and wire rope inspection reports shall be maintained. These reports shall certify the date and the person performing the inspections. All wire rope which has been idle for a period of a month or more due to shut down or storage of a crane on which it is installed shall be given a thorough inspection before it is used. This inspection shall be for all types of deterioration and shall be performed by an appointed or authorized person whose approval shall be required for further use of the rope. A certification record which included the date of the inspection, the signature of the person who performed the inspection, and an identifier of the rope which was inspected shall be prepared and kept on file. A carbon dioxide, dry chemical or equivalent fire extinguisher shall be kept in the cab or the vicinity of the crane. If work is to be performed near overhead lines, the lines shall be de-energized and grounded, or other protective measures shall be provided before work is started. If the lines are to be de-energized, arrangements shall be made with the person or organization that operates or controls the electric circuits involved to de-energize and ground them. If protective measures such as guarding, isolating, or insulating are provided, the precautions shall prevent employees from contacting such lines directly with any part of their body or indirectly through conductive materials, tools or equipment. All provisions of 29CFR1910.180 shall be followed in wheel mounted crane operations.

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MEDICAL SERVICES/FIRST AID COASTAL, LLC shall insure the availability of medical personnel for advice and consultation on matters of occupational health. Provisions shall be made prior to commencement of each project to provide prompt medical attention in case of serious injury. In the absence of an infirmary, clinic, hospital, or physician, that reasonably accessible in terms of time and distance to the work site, which is available for treatment of injured employees, a person who has a valid certificate in First-Aid training from the U.S. Bureau of Mines, The American Red Cross, or the equivalent training that can be verified by documentary evidence, shall be available at the worksite. All First-Aid items shall be approved by the consulting physician and easily accessible when required. The approved First-Aid items shall be stored in a weatherproof container with individual sealed packages for each type of item. The contents of the First-Aid shall be checked by the Safety Coordinator or his representative, before being sent out on the job, and at least weekly on each job to ensure that the expended items are replaced. In case of a minor injury requiring more than First-Aid, the employees shall be transported in a company vehicle, by his supervisor or his representative, for prompt medical attention. In a case of more than a minor injury, the injured employee shall be transported by way of ambulance. On each project there shall be a communication system (telephone, cellular telephone, or radio), for contacting necessary ambulance services. The project manager or supervisor shall be responsible for posting telephone numbers of physicians, hospitals, and ambulances. This posting shall be in a conspicuous space. Where the eyes or body of any employee may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and/or body shall be provided within the work area for immediate emergency use. Whenever First-Aid services are rendered the First-Aid log shall be completed by the person administering the First-Aid.

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BLOODBORNE PATHOGENS EXPOSURE CONTROL PLAN In accordance with OSHA Bloodborne Pathogens standard, 29CFR 1910:1030, the following Exposure control plan has been developed. 1. Exposure Determination

In accordance with OSHAs exposure determination policy the following job classification may incur occupational exposure to blood or other potentially infectious materials.

A. On site CPR & First Aid personnel Trey Williams

B. General Foreman

All injuries are reported to the immediate supervisor

C. Foreman All injuries are reported to the immediate supervisor

D. Lead Man

All injuries are reported to the immediate supervisor 2. Implementation schedule and methodology Compliance methods Universal precautions will be observed throughout COASTAL, LLC’s company structure. All blood or other potentially infections secretions will be considered infections regardless of the perceived status of the source individual.

The employee will be offered post exposure prophylaxis in accordance with the current recommendations of the U.S. Public Health Service. The employee will be given appropriate counseling concerning precautions to take during the period after the exposure incident. The employee will also be given information of what potential illnesses to be alert for and report any related experiences to appropriate personnel. All COASTAL, LLC’s policies are carried out effectively as well as to maintain all records related to this policy an all others as well.

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INTERACTION WITH HEALTH CARE PROFESSIONALS A written opinion shall be obtained from the health care professional who evaluated employees of this facility. Written options will be obtained in the following instances:

1. When the employee is sent to obtain the Hepatitis B vaccine. 2. Whenever the employee is sent to a health care professional following an exposure incident.

3. The Hepatitis B Vaccine is made available to all employees with occupational exposure at no cost. Health care professionals shall be instructed to limit their opinions to Trey Williams.

1. Whether the Hepatitis B vaccine is indicated and if the employee has received the vaccine, or for evaluation following the incident.

2. That the employee has been informed of the results of the evaluation 3. That the employee has been told about any medical conditions resulting from exposure to blood or

other potentially infectious materials. (Note that the written opinion to the employer is not to reference any personal medical information).

4. Accurate medical records for each employee with occupational exposure must be maintained for at least the duration of employment plus 30 years.

TRAINING Training for all employees will be conducted prior to initial assignment to tasks where occupational exposure may occur. Training records will be kept for 3 years or more. Training records shall be maintained for 3 years from the date of training. Training will be conducted in the following manner: Training for employees will include the following an explanation of:

The OSHA standard for Bloodborne Pathogens.

Epidemiology and symptomatology of Bloodborne diseases.

Modes of transmission of bloodborne pathogens.

This Exposure Control Plan, i.e. points of the plan, lines of responsibility, how the plan

will be implemented, etc.

Procedures which might cause exposure to blood or other potentially infectious

materials at this facility.

Control methods which will be used at the facility to control exposure to blood or

other potentially infectious materials.

Personal protective equipment available at this facility and who should be contacted

Post exposure evaluation and follow-up

Signs and labels used at the facility

Hepatitis B vaccine program at the facility The training course is conducted with video tapes, written materials, and a lecture given by our Safety Coordinator. -All employees will receive annual refresher training (NOTE that this training is to be conducted within one year of the employee’s previous training). -The outline for the training materials is located at COASTAL, LLC administration office on file

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RECORD KEEPING All records required by the OSHA standard will be maintained by the Safety Department.

The following is a list of work practice and engineering controls, aimed at the elimination or minimization of exposure to employees.

1. Sharp metal, Scrap container 2. All employees must wear gloves to handle sheet metal and glass. This protective

equipment must also be worn to do any type of clean up; in our fab shop or out on the job site.

3. Disposable paper cups at all water dispenser. 4. No glass containers are allowed in the shop, work area or on the job site. 5. No sharing of personal protective equipment: gloves, hard hat, respirators, or rubber

boots. 6. All First Aid cases shall be handled while wearing rubber gloves.

The six controls listed will be monitored for compliance by the COASTAL, LLC safety officer. Per job site each General Foreman shall be responsible for implementing these controls. A weekly inspection of the work area will be implemented to check the adherence and effectiveness of these controls. In the shop fabrication areas, hand washing facilities are provided for employees, who incur exposure to potentially infectious materials. The location of this facility is in the South East corner of the fabrication shop. Site conditions here hand washing facilities may not be present, antiseptic cleanser and clean towels or paper towels will be provided. After antiseptic cleansing the exposure areas must be washed with soap and running water as soon as possible. Where these site conditions occur, the on site office trailer shall be the location of the antiseptic cleanser as well as the First Aid Facility. Employees exposed without regard to the use of personal protective equipment shall wash hands and any other potentially contaminated skin area immediately or as soon as feasible with soap and water. Bio hazards due to sharps such as needles scalpels etc. are not potential hazards found within the companies structure.

WORK AREA RESTRICTIONS Under no circumstances, will the omission of personal protective equipment be allowed while handling First Aid cases.

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CONTAMINATED EQUIPMENT Tools or equipment contaminated with potentially infectious materials should be reported to and decontaminated by, CPR and First Aid personnel only.

PERSONAL PROTECTIVE EQUIPMENT Rubber gloves for handling of CPR and First Aid cases will be provided to personnel at no cost to the employee. These rubber gloves are found in office First Aid Case. After use these rubber gloves shall be disposed of and not reused. Safety glasses with a full aide shield shall be worn while handling First Aid cases and during decontamination procedures. Work areas contaminated by blood or potentially infectious materials shall be decontaminated by CPR and First Aid personnel only.Decontamination will be accomplished utilizing the following materials:

1. 2 to 1 Bleach Solution 2. Veridical Disinfectant

REGULATED WASTE DISPOSAL

In the event Bio-Hazardous Waste is generated Allied Waste Services will be contacted to transport and properly dispose of such material. POST EXPOSURE EVALUATION AND FOLLOW-UP When the employee incurs an exposure incident, it should be reported to the safety coordinator. All employees who incur and exposure incident will be offered post-exposure evaluation and follow-up in accordance with the OSHA standard. 29 CFR 1910.1030.

This follow-up will include the following:

Documentation of the route of exposure and the circumstances related to the incident.

If possible, the identification of the source individual and, if possible, the status of the source individual. The blood of the individual will be tested (after consent is obtained) for HIV/HBV infectivity.

Results of testing of the source individual will be made available to the exposed employee with the exposed employee informed about the applicable laws and regulations concerning disclosure of the intity and infectivity of the source individual.

The employee will be offered the option of having their blood collected for testing of the employees HIV/HBV serological status. The blood sample will be preserved for at least 90

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days to allow the employee to decide if the blood should be tested for HIV serological status. However, if the employee decides prior to that time that testing will be conducted then that appropriate action can be taken and the blood sample discarded.

BIOHAZARD

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PERSONAL PROTECTIVE EQUIPMENT It is our policy to provide employees with PPE that will offer protection from hazards encountered in the workplace. Approved PPE will be provided and replaced at no cost to the employee, with adequate selections available to ensure proper fit for a wide range of employees. Employees are trained on the selection, use and care of PPE. Employees will be given PPE and assure Coastal LLC verbally they are the proper fit and/or size. Employees are responsible for proper inspection, maintenance, and care of their PPE. Contractors are responsible for providing themselves with approved PPE. We will not provide contractors with approved PPE except in mutually agreed upon circumstances. PPE training is documented and retraining is performed as necessary. Coastal LLC employees will adequately and properly maintain PPE. Any defective PPE must be discarded or removed from service.

HEAD PROTECTION All employees, contract personnel, and visitors must wear approved head protection in designated areas at field and facility locations. Head protection will also be worn anytime there is a danger of falling objects or a possibility head injury may occur while performing duties.

Head protection must meet American National Standards Institute (ANSI) Z89.1, or equivalent, requirements.

Do not paint, drill holes in, or modify the head protection in any manner except as approved by management.

Hairstyles that make it impossible for a person to wear head protection properly are not permitted.

Do not wear head protection backward or with items stored in it, otherwise you will not be adequately protected.

Inspect head protection on a regular basis, or according to manufacturer’s requirements, for cracks, signs of wear, and worn or damaged suspension.

Clean head protection with mild soap and water. Do not use solvents.

Do not wear head protection without the suspension.

Do not wear metal hard hats as they conduct electricity.

Replace hardhat every 5 years.

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FOOT PROTECTION Safety shoes or boots must be worn in all customer service locations and in designated work areas.

Safety shoes must meet ANSI Z41.1, or equivalent, requirements.

Wear appropriate chemical protective boots when handling liquids or hazardous chemicals.

Wear safety footwear with well-defined heels to help prevent slipping when climbing stairs and ladders.

CLOTHING

Do not modify uniforms by cutting sleeves or legs. Loose or baggy clothing, shirttails, unbuttoned sleeves, or ripped uniforms create unacceptable hazards when working around equipment. Wear only approved uniforms, in good condition. In addition to the safety of personnel, your appearance projects professionalism and TPFI’s image to the public.

Hazard analysis may indicate that certain processes involve potential exposure to a flammable or combustible environment requiring the use of flame resistant clothing. Likewise, some customers may require fire-retardant clothing. In these cases, exterior clothing must be flame resistant. Do not alter fire-retardant or flame resistant uniforms in any way.

Processes with potential exposure to corrosives, acid, or other harmful chemical materials require the use of long-sleeved clothing. A risk assessment must be conducted prior to doing the work to determine if long sleeves are required.

EYE AND FACE PROTECTION All employees, contract personnel, and visitors to TPFI’s premises must wear ANSI Z87.1, or equivalent, eye protection as required for the work location.

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Prescription eyewear must have permanently affixed side shields and meet ANSI Z87.1.

Wear approved eye and face protection, including face shields and goggles, during inspection, grinding, chipping, buffing pneumatic tool operation, chemical handling, cutting, or any other operations where particles may cause an eye injury.

Welders must wear an approved welding hood during welding operations.

Appropriate filter lenses are required for oxygen cutting, arc and gas welding, torch brazing, and torch soldering.

Replace worn, scratched, cracked, deeply pitted, or broken eyewear immediately.

HAND PROTECTION Wear appropriate gloves to help prevent injuries resulting from rough materials, sharp edges, irritating substances, etc… While wearing gloves; however be careful not to create a safety hazard (e.g.., getting a glove caught in rotating equipment).

Wear leather gloves when handling wire rope.

Wear cloth gloves when handling pipe, oilfield tools, etc.

Depending on the chemical being handled, you must wear the specific type of hand protection necessary. Refer to the MSDS to determine what type must be worn.

Gloves are required at all times when performing duties that may injure your hand or fingers. If an employee is injured while not wearing gloves he or she will be required to provide an explanation of why they were not wearing proper PPE.

ADDITIONAL PPE You may be required to use additional PPE in certain areas or for specific tasks. Individual risk assessments must be conducted to determine this need. A hazard assessment must be completed. Contact your supervisor or HSE representative if you have any questions.

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FIRE PREVENTION & PROTECTION

GENERAL REQUIREMENTS: Smoking is prohibited while using, dispensing, or being around flammable or combustible liquids, or as otherwise posted. Flammable and combustible liquids shall be dispensed from approved safety cans and stored in approved safety cans. Gasoline powered equipment shall not be fueled while running. Unobstructed access to fire extinguishers and other firefighting equipment shall be maintained. Employees shall know the location of the fire protection equipment in their work area. Fire protection equipment once used shall be turned into the tool room and reported to the safety coordinator for servicing. Only approved solvents shall be used to clean parts and equipment. Solvents shall not be left in open containers when not in use. They shall be stored in approved, closed containers. Oily rags, trash and other combustible scrap materials shall be placed in their proper containers. All portable fire extinguishers shall be maintained in a fully charges and operable condition and kept in their designated places at all times except during use.

TRAINING: Mandatory training, for portable fire extinguishers, is required of all employees. This educational program is to familiarize employees with the general principals of fire extinguisher use and the hazards involved with the incipient stage of firefighting. This mandatory training is required upon initial assignment and at least annually thereafter.

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MAINTENANCE: All portable fire extinguishers shall be subjected to monthly vision checks and an annual maintenance check. The company shall record the annual maintenance date and retain this record for 1 year after the least entry or the life of the shell, whichever is less.

HAND, POWER TOOLS AND EQUIPMENT

1. Protection for rotating/moving parts. All tools must guard rotating/moving shafts and parts to prevent employee’s body parts and clothing from getting caught in them.

2. Power tools shall be hoisted or lowered by a hand line, never by the cord or hose.

3. Cord and hoses must be kept out of walk-ways and off stairs and ladders. They must be so as not to create a tripping hazard for employees or to be subject to damage from equipment or materials.

5. Hand tools shall be used for their intended purpose only. The design capacity of hand

tools shall not be exceeded by unauthorized attachments. 6. Powder- actuated tools may be used only by assigned employees who have been

instructed and trained in their safe use.

7. The use of powder-actuated tools is prohibited in explosive or flammable atmospheres.

8. Safe operating procedures provided by the manufactures of powder-actuated tools

shall be followed explicitly.

9. Employees shall maintain all hand and power tools in safe condition. All tools in need or repair shall be taken out of service, be red tagged, and turned into the tool room for repair.

10. Grinding and buffing wheels are rated for a certain speed and using a faster speed

may cause the wheel to explode.

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11. Employees shall always wear the proper personal protective equipment when working with hand and power tools.

MACHINE GUARDING

1. Gears, sprockets, chains, drives, coupling, flywheels, shafts, saw blades, fan blades and similar exposed moving machine parts which may cause injury, shall be adequately guarded. Employees shall immediately report any guard which is missing or damaged to the extent it is ineffective. 2. Guards shall be kept in place on tools and equipment. Machine guards and safety appliances shall not be removed or made inoperative, except for the purpose of making repairs. 3. All mobile equipment under repair shall be adequately choked and blocked against movement. 4. No work shall be performed under equipment or machinery in a raised position until it is securely blocked in place. 5. Repairs or maintenance shall not be performed on machinery until the source of power is off and the machinery is securely blocked against motion, except where motion is necessary to make adjustments. Lockout procedure shall be followed when maintenance or repairs are made.

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CONFINED SPACE ENTRY PROGRAM DEFINITIONS:

1910.146(b) Confined space means – 1.) Is large enough and so configured that and employee can bodily enter and perform assigned work; and 2.) Has limited or restricted means of entry or exit (for example, tanks, silos, storage bins, hoppers vaults, and pits are spaces that may have limited means of entry.); and 3.) Is not designed for continuous employee occupancy. 1926.21(b) (6) (ii) “Confined space or enclosed space” means – any space having a limited means of egress, which is subject to the accumulation of toxic or flammable contaminants or has an oxygen deficient atmosphere. Confined spaces include, but are not limited to, storage tanks, process vessels, bins, boilers, ventilation or exhaust ducts, sewers, underground utility vaults, tunnels, pipelines, and open top spaces more than 4 feet in depth such as pits, tubs, vaults, and vessels. ANSI z117.1-1989 A confined space is an enclosed area that: It’s primary function is something other than human occupancy, and has restricted entry and exit, and may contain potential or known hazards. Permit required confined space: A confined space which after evaluation has actual or potential hazards which have been determined to require written authorization for entry. Non-permit confined space: A space which, by configuration, meets the definition of a confined space but which after evaluation is found to have little potential for generation of hazards or has the hazards abated by engineering controls. Qualified person: Is a person who by training or experience should be familiar with: 1.) The tasks to be performed. 2.) The potential hazards that may be encountered in confined spaces. 3.) Safety and health requirements for work in confined spaces. 4.) Entry permit program and emergency plans.

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CONDITIONS NECESSARY FOR SAFE WORK IN AND ABOUT A CONFINED SPACE WILL VARY GREATLY DEPENDING ON ITS LOCATION, CONFIRGURATION, AND SERVICE. AFTER A QUALIFIED PERSON HAS ASSESSD THE POTENTIAL HAZARDS, THIS PERSON SHOULD, AS A MINUMUM, INCORPORATE THE FOLLOWING SAFEGUARDS. Entry permit for PRCS shall include:

Date of entry

Location of entry

Type of work to be performed in the confined space

Hazards to be controlled or eliminate prior to entry

Safety equipment required

Safety precautions required to the job.

Type of atmospheric test and the results of those test

Type of rescue equipment that will be needed

Duration for the permit

Space for approval authority Atmospheres must be tested in confined space before entry. Recommended sequence is oxygen, flammability, and toxic. Further test shall be conducted with the ventilation system on. (To ensure ventilation does not introduce engine exhaust and other toxic gases). If the confined space is vacated for any significant time period, retesting of the atmosphere shall be conducted. Acceptable limits:

oxygen 19.5% to 23.5%

Flammability less than 10% of the LEL

Toxic less than recognized exposure limits (OSHA, ACGIH, MSDS, etc…) Attendants shall be stationed outside any PRCS Attendants and occupants shall remain in constant two way communication. All energy sources which are potentially hazardous shall be locked/out, disconnected, relieved, and/or restrained before any entry into confined spaces.

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Methods and means shall be selected and used to prevent flammable, toxic, irritating, or oxygen displacing gases and vapors from entering the space. All hazardous material, high pressure, high temperature and other piping that could introduce a hazard shall be isolated by blinding, disconnecting, removal, or double block and bleed as needed to prevent material(s) and hazardous contaminants. Pipelines and other similar conveyances between the confined spaces an point(s) of isolation shall be drained, cleaned, or flushed of hazardous materials as known contaminants necessary. When ventilation is used to remove atmospheric contaminants from confined spaces, the space shall be ventilate until the atmosphere is within acceptable ranges. Ventilation shall be made during occupancy if there is the potential for the atmospheric conditions of the confined space moving out of the acceptable range. When ventilation is not possible or feasible, alternate protective measure or methods to remove air contaminates and protect the occupants shall be determined by the qualified person prior to authorizing entry. Confined spaces shall be cleaned/decontaminated of hazardous materials to the extent feasible before entry. Appropriate retrieval device shall be available to retrieve personnel from vertical type Permit Required Confined Spaces greater than five feet in depth. Confined spaces with could inadvertently be entered shall have a sign identifying it is a confined space. Signs for Permit Required Confined Spaces shall have a warning that a permit is required before entry. A plan of action (Emergency Response Plan) shall be written with provisions to conduct a timely rescue for individuals in a confined space should an emergency arise. It shall include:

Method of rescue Designation of rescue personnel Type and availability of rescue equipment Method to summon rescuers

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Training and drill of attendant and rescue personnel in preplanning, rescue, and emergency procedures

Personnel responsible for supervising, planning, entering, or participating in confined space entry and rescue shall adequately be trained in their function prior to any confined space entry. Training shall include;

Hazards associated with confined spaces

Reason for, proper use, and limitations of PPE

Explanation of the permit system

How to respond to emergencies

Duties/responsibilities as a member of a confined space entry team.

A description of how to recognize probable air contaminant over-exposure systems to themselves and co-worker, and method(s) of altering attendants.

Personnel using atmospheric monitoring equipment shall be trained in its use, calibration, the anticipated hazardous contaminant, and any factors which could significantly alter the conditions inside or outside of the confined space. Rescue personnel shall be trained in first-aid and CPR. Work in confined spaces may present special problems resulting from the existence of extraordinary circumstances. Special precautions and procedures that are beyond the scope of this program should be established. Deviation from the guidelines in this written program may be necessary. However, the objective of working safely in a confined space must be achieved. Each affected employee must be trained prior to initial assignment, prior to a change in assigned duties, if a new hazard has been created or special deviations have occurred. All training shall be documented. This certification shall include the employee name, trainer signature/initials, and dates of training. Certification must be made to employees & their authorized representative. At least one attendant shall be provided outside the permit space into which entry is authorized for the duration of the operation. If multiple spaces are to be monitored by a single attendant, it shall be included in the permit program the means and procedures to enable the attendant to respond to an emergency affecting one or more of the permit spaces being monitored without distraction from the attendant’s responsibilities.

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Designated persons who are to have active roles in the permit required confined space are the authorized entrants, attendants, entry supervisors, and persons who test or monitor the atmosphere in the permit space. Duties of the authorized entrants are as follows:

1. Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure. 2. Proper use of equipment as required in 29CFR1910.146(d) (4). 3. Communicate with the attendant as necessary to enable the attendant to monitor entrant status and to enable the attendant to alert entrants of the need to evacuate the space immediately under any of any of the following circumstances: A. If the attendant detects a prohibited condition. B. If the attendant detects the behavioral effects of hazard exposure in an

authorized attendant. C. If the attendant detects a situation outside the space that could endanger the authorized entrants: or D. If the attendant cannot effectively or safely perform all the duties required of them. 4. Alert the attendant whenever: A. The entrant recognizes any warning sign or symptom of exposure to a dangerous situation, or B. The entrant detect a prohibited condition; and 5. Exist the space as quickly as possible whenever: A. An order is given to evacuate by the attendant or entry supervisor, B. The entrant recognizes any warning sign or symptom of exposure to a dangerous situation, C. The entrant detects a prohibited condition, or D. An evacuation alarm is activated

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Duties of attendants are as follows:

Know the hazards that may be faced during entry, including information on the mode, signs and symptoms, and consequences of the exposure;

Is aware of possible behavioral effects of hazard exposure in authorized entrants;

Continuously maintains an accurate count of authorized entrants in the permit space and ensure that the means to identify authorized entrants by name or by such other means as will enable the attendant to determine quickly and accurately, for the duration of the permit, which authorized entrants are inside the permit space. (forexample, through the use of rosters or tracking systems)

Remains outside the permit space during entry operations until relieved by another attendant.

Communicates with authorized entrants as necessary to monitor entrant status and to Alert entrants of the need to evacuate the space under paragraph (6) of this section.

Monitors activities inside and outside of the space to determine if its is safe for entrants to remain in the space and orders the to evacuate the permit space immediately under any of the following circumstances;

If the attendant detects a prohibited condition; A. If the attendant detects the behavioral effects of hazard exposure in the

authorized entrant; B. If the attendant detects a situation outside the space that could endanger the

authorized entrants, or C. If the attendant can no effectively perform all the duties required of them.

Summon rescue and other emergency services as soon as the attendant determines that authorized entrants may need assistance to escape from permit space hazards.

Takes the following actions when unauthorized persons approach or enter a permit space while entry is underway:

A. Warn the unauthorized persons that they must stay away from the permit space;

B. Advise the unauthorized persons that they must exit immediately if the they have entered the permit space.

C. Inform the unauthorized entrants and entry supervisor if unauthorized persons have entered the permit space;

Performs non-entry rescues as specified by COASTAL, LLC. rescue procedures, and

Performs no duties that might interfere with the attendant’s primary duty to monitor and protect the authorized entrants.

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Duties of entry supervisor are as follows:

Knows the hazards that might be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure;

Verifies, by checking that the appropriate entries have been made on the permit, that all test specified by the permit have been conducted and all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry to begin;

o Terminates the entry and cancels the permit when: The entry operations covered by the permit have been completed or; A condition that is not allowed under the entry permit arises in or near the

permit space.

Verifies that rescue services are available and that the means for summoning them are operable;

Removes unauthorized individuals who enter or attempt to enter the permit space during entry operations; and

Determines whenever responsibility for a permit space entry operation is transferred and at intervals indicated by the hazards and operations performed within the space, that entry operations remain consistent with terms of the entry permit and that acceptable entry conditions are maintained.

RESCUE AND EMERGENCY SERVICES:

1. Each member of the rescue team shall be provided with, and is trained to use properly, the personal protective equipment and rescue equipment necessary for making rescues from the permit spaces.

A. Each member of the rescue team shall be trained to perform the assigned rescue duties. Each member of the rescue team shall also receive the training required of authorized entrants.

B. Each member of the rescue team shall practice making permit space rescues at

least once every 12 months, by means of simulated rescue operations in which they remove dummies, manikins, or actual persons from the actual permit spaces or from representative permit spaces. Representative permit spaces shall, with respect to opening size, configuration, and accessibility, simulate the types of rescue is to be performed.

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C. Each member of the rescue team shall be trained in first-aid and in cardiopulmonary resuscitation (CPR). At least one member of the rescue team holding current certification in first-aid and in CPR shall be available.

2. When COASTAL, LLC arranges to have persons other than their own employees perform permit space rescue, the company shall:

A. Inform the rescue service of the hazards they may confront when called on to perform rescue at the host employer’s facility, and

B. Provide the rescue service with access to all permit spaces from which rescue may be necessary so that the rescue service can develop appropriate rescue plans and practice rescue operations.

3. To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant. Retrieval systems shall meet the following requirements;

A. Each authorized entrant shall use a chest or full body harness, with a retrieval line attached at the center of the entrant’s back near shoulder level, or above the entrants head. Wristlets may be used in lieu of the chest or full body harness if the company can demonstrate that the use of a chest or full body harness is infeasible or creates a greater hazard and that the use of wristlets is the safest and most effective alternative.

B. The other end of the retrieval line shall be attached to a mechanical device or a fixed point outside the permit space in such a manner that rescue can begin as soon as the rescuer becomes aware that rescue is necessary. A mechanical device shall be available to retrieve personnel form vertical type permit spaces more than 5 feet deep.

4. If an injured entrant is exposed to a substance for which a Material Safety Data Sheet (MSDS) or other similar written information is required to be kept at the worksite, that MSDS or written information shall be made available to the medical facility treating the exposed entrant. A written or printed entry permit shall be completed before any entry into a permit required confined space. This permit becomes void at expiration time, work not started within 1 hour, or work has stopped for 1 hour, plant alarm sounds or any other emergency situation causes the job to shut down.

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In the event of multi employers, the entry supervisor shall coordinate between employers so that employees of one employer do not endanger the authorized entrants. At the conclusion of entry operations that permit shall be cancelled and removed from the entry site. The closing off of the permit space shall be initiated to prevent entry of unauthorized entrants. All cancelled permits shall be turned into the safety office. Cancelled permits shall be kept on file for at least 1 year. A review of the permit space program, using cancelled permits, within 1 year of each entry and to revise the program as necessary, to ensure that employees participating in permit operations are protected from permit space hazards. The program review shall include the entry operations that may nor provide enough protection for employees and for revising the program prior to subsequent entries are authorized. The written program shall be reviewed annually (unless no entries were made during the prior 12 month period) and revised as necessary as to protect employees from confined space hazards.

HAZARDS FOR A CONFINED SPACE Confined spaces are often hard to define. The following factors should be considered when evaluating a trench, manhole, or excavation for the hazard of confined spaces. 1. Soil has high organic content (use USDA soil survey criteria of the more than 4% organic content by volume) 2. Soil has methane pockets (Hydrogen Sulfide in certain locales) 3. If the area is in a high traffic area, Carbon Dioxide is heavier than air and could settle in the low areas. Carbon Monoxide, although not heavier than air is toxic by product of combustion engines. 4. The use of diesel/gasoline equipment in the space. Same rationale as described in # 3. 5. The use of chemicals in the space. Solvents from waterproofing compounds/pipe sealers have been past caused of fatalities. 6. Worksites adjacent to a gas main or landfill. Gases from both are hazardous.

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7. Connecting or next to a live sewer main. Gases can travel down or upstream of the confine space. 8. Space that had been left alone for a long period of time. Anything from underground gases chemical off gassing, oxygen depletion through oxidation, and many others can occur in the confine space.

TYPES OF CONSTRUCTION CONFINED SPACE FATALITIES 1. Excavations- Approximately 16 feet wide, 20 feet deep. Carbon Dioxide displaced the oxygen in the excavation. The CO2 was from the decomposition of the highly organic soil. Rescuer also died. 2. Manhole- 12-13 feet deep, not connected to live line, 4% 02, 20% LEL. (Probable methane) 3. Foundation – 13 feet deep, 3 feet wide, applying waterproofing. Vapors off gassed the solvents, methyl chloroform and 1,4 dioxane. 4. Underground Vault – CO2 in vault, employees were looking or problem in a telephone line. Rescuer died also. 5. Sewer Pipe – Applying waterproof coating in sewer pipe using an airline from a compressor. The compressor generated CO and the employee died from CO poisoning. The compressor had neither CO alarm nor a high temperature alarm. Rescuer died also. 6. Above Ground Pipe – Employee entered a 24 inch pipe to grind a bad weld. Air quality was a concern so they provided 100% 02 for ventilation. His clothes were oxygen enriched and the grinder’s sparks ignited his clothing. He died from the burns. 7. Air Conditioning Unit – Air conditioning tech was purging lines with Freon 22 . Freon built up and the employee died of “Freon Intoxication”. 8. Grain Dryer – Employee went to level out dessicant used to dry out the dryer and was asphyxiated. Vessel was purged with nitrogen two days earlier and not completely ventilated. Resucer also died. Per OSHA’s proposed rule on confined space, 60% of the fatalities in confined spaces were the rescuer.

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MATERIAL HANDLING & STORAGE

1. Heavy or awkward materials shall be moved with mechanical aid or with additional help to prevent lifting hazards.

2. Materials and supplies shall be neatly and securely stacked, blocked and limited in height so as to be stable and in no danger of collapsing, sliding or falling over. 3. Heavy items shall be stored on lower shelves and blocked against falling or rolling. 4. Materials shall not be permitted to protrude from shelves in such a manner as to create a hazard.

ASSURED EQUIPMENT GROUNDING CONDUCTOR PROGRAM COASTAL, LLC has elected to use assured equipment grounding conductor program in lieu of ground- fault circuit interrupters in temporary electrical circuits on construction sites. The Safety Coordinator or representative (a competent person), are designated and trained to implement the program. Each cord set, attachment cap, plug and receptacle or cord sets, and any equipment connected by cord or plug. Except cord sets and receptacles which are fixed and not exposed to damage, shall be visually inspected before each days use for external defects, such as deformed or missing pins or insulation damage, and for the indication of possible damage. Equipment found damaged or defective may not be used until repaired. The following test 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. All equipment grounding connectors shall be tested for continuity and shall be electrically continuous. Each receptacle and attachment cap or plug shall be tested for correct attachments of the equipment grounding conductor. The equipment grounding conductor shall be connected to its proper terminal.

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All required test shall be performed and recorded.

1. Before each use. 2. Before equipment is returned to service following any repairs. 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).

4. At intervals not exceeding 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.

5. The company will not make available or permit use by employees of any equipment which has not met the requirements above.

6. A written description of the program, including the specific procedures adopted by the company, and the record of tests, shall be available at the safety office or inspection.

Color coding shall be used to denote the time period the equipment was tested. Quarterly color codes are: 1st Qtr. - Blue, 2nd Qtr. - Green, 3rd Qtr. - Red, 4th Qtr.-Yellow. Inspections shall be performed at the tool room or at the jobsite by a competent person approved by the safety coordinator. All documentation shall be turned in to the safety office for record keeping.

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ELECTRICAL SAFETY Only authorized employees shall perform maintenance or repairs on electrical wiring or equipment. The electrical lock-out procedure shall be followed. No maintenance or repairs shall be attempted until the lock-out is in place to prevent start up, movement, or electrical shock. No one will remove lock-out tags, locks, or multiple locking bars other than those who attach them. Locks shall not be cut off any lock-out. Electrical tools or equipment shall not be used unless they have been inspected. Damaged or defective electrical must be properly tagged and returned immediately to the tool room for repair. Treating exposed de-energized parts as live when working on or around the equipment. Conductors and parts of electrical equipment that have been de-energized but not been locked or tagged out shall be treated as live parts. Temporary electrical cords must be covered or elevated. They must be kept clear or walkways and other locations where they might be exposed to damage or create tripping hazards. Booms and mass of equipment shall not be operated within 10 feet of an energized overhead high voltage line. TRAINING: The training requirements contained in the section apply to employees who face a risk of electrical shock that is not reduced to a safe level.

1. Employees shall be trained in safety related work practices that pertain to their respective job assignments. 2. Qualified persons(i.e., those permitted to work on or near exposed energized parts) shall at a minimum be trained at a minimum, to be familiar with the following:

A. The skills and techniques necessary to distinguish exposed live parts from other parts of electrical equipment. B. The skills and techniques necessary to determine the normal voltage of exposed live parts and clearance distances.

Employees who face a risk of electrical shock but who are not qualified persons shall be trained and familiar with electrical related safety practices. Safe work practices shall be employed to prevent electric shock or other injuries resulting in either direct or indirect electrical contacts when work is performed near or on equipment or circuits which are or may be energized.

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Working on or near energized parts, applies to work performed on exposed live parts (involving either direct or indirect contact or by means of tools or materials) or near enough to them for employees to be exposed to any hazard they present.

1. Only qualified persons may work on electrical circuit parts (involving either direct contact or contact by means of tools or materials) or near enough to them for employees to be exposed to any hazard they present. 2. Only qualified persons may work on electrical circuit parts or equipment that they have not been de-energized. Such persons shall be made familiar with the use of special precautionary techniques, PPE, insulating and shielding materials and insulated tools.

If work is to be performed near overhead lines, the lines shall be de-energized and grounded, or other protective measures shall be provided before work is started. When an unqualified person is working in an elevated position near overhead lines, the location shall be such that the person and the longest conductive object he or she may contact cannot come closer to unguarded, energized overhead line that the following distances:

1. For voltages t ground 50kV or below- 10 feet 2. For voltages to ground over 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 cannot bring any conductive object closer to unguarded, energized overhead lines so that a clearance of 10- feet is maintained. If the voltage is higher than 40kV, the clearance shall be increased 4 inches for every 10kV over that voltage. When a qualified person is working in the vicinity of overhead lines, whether in an elevated position or on the ground, the persons may not approach or take any conductive object without an approved insulating handle closer to exposed energized parts than shown in table s-5 unless:

1. The person is insulated from the energized part (gloves with sleeves necessary, rated for the voltage involved are considered to be insulation of the person from the energized part on which work is performed), or

2. The energized part is insulated both from all other conductive objects at a different potential and from the person, or

3. The person is insulated from all conductive objects at a potential different from that of the energized part.

TABLE S-5 Approach distances for qualified employees-alternating current

VOLTAGE RANGE (PHASE TO PHASE) MINIMUM APPROACH DISTANCE

300v and less AVOID CONTACT

Over 300V, not over 700V 1 ft. 0 in.

Over 750V, not over 2kV 1ft. 6 in.

Over 2kV, not over 15kV 2ft. 0 in.

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Over 15kV, not over 37kV 3ft. 0 in.

Over 37kV, not over 87.5 kV 3 ft. 6 in.

Over 87.5kV, not over 121kV 4 ft. 0 in.

Over 121kV, not over 1450kV 4 ft. 6 in.

Any vehicle or mechanical equipment capable of having parts of its structure elevated near energized overhead lines shall be operated that such a clearance of 10 ft. is maintained. If the voltage is higher than 50kV, the clearance shall be increased 4 in. for every 10kV over that voltage. However, under any of the following conditions, the clearance may be reduced:

1. If the vehicle is in transit with its structure lowered, the clearance may be reduced to 4 ft.. If the voltage is higher than 50kV, the clearance shall be increased 4 in. for every 10kV over that voltage. 2. If insulating barriers are installed to prevent contact with the lines, and the barriers are rated for the voltage of the line being guarded and are not part of or and attachment to the vehicle or its raised structure, the clearance may be reduced to a distance within the design working dimensions of the insulating barrier.

3. If the equipment is aerial lift insulated for the voltage involved, and if the work is performed by a qualified person, the clearance (between the un-insulated portion of the aerial lift and the power line) may be reduced to the distance given in Table S-5

Employees standing on the ground may not contact the vehicle or mechanical equipment or any of its attachments, unless: 1. The employee is using protective equipment rated for the voltage; or

2. The equipment is located so that no un-insulated part of its structure (that portion of the structure that provides a conductive path to employees on the ground) can come closer to the line than permitted in the previous paragraph of this section.

If any vehicle or mechanical equipment capable of having parts of its structure elevated near energized overhead lines in intentionally grounded, then 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. Additional precautions, such as the use of barricades or insulation, shall be taken to protect employees from hazardous ground potentials, depending on earth resistively and fault currents, which can develop within the first few feet or more outward for the grounding point.

Employees may not enter spaces containing exposed energized parts, unless illumination is provided, that enables the employees to perform the work safely. Where the lack of

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illumination or an obstruction precludes observation of the work to be performed, employees may not perform tasks near exposed energized parts; employees may not reach blindly into areas which may contain energized parts.

When an employee works in a confined or an enclosed space (such as manhole or a vault) that contain exposed energized parts, the company shall provide, and the employee shall use, protective shields, protective barriers, or insulating materials as necessary to avoid inadvertent contact with these parts, doors, hinged panels, and the like shall be secured to prevent their swinging into an employee and causing the employee to contact exposed energized parts.

Conductive materials and equipment that are in contact with any part of an employee’s body shall be handled in a matter that will prevent them from contacting exposed energized conductors or circuit parts. If an employee must handle long dimensional conductive objects (such as ducts and pipes) in areas with exposed live parts, the company shall institute work practices (such as the use of insulation, guarding, and material handling techniques) which will minimize the hazard.

Portable ladders shall have nonconductive side rails if they are used where the employee or ladder cold contact exposed energized parts.

Conductive articles of jewelry and clothing (such as watchbands, bracelets, rings, key chains, necklace, metalized apron, cloth with conductive thread, or metal headgear) may 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.

Where live parts present an electrical contact hazard, employees may not perform housekeeping duties at such close distances to the parts that there is a possibility of contact, unless adequate safeguards (such as insulating equipment or barriers) are provided. Electrically conductive cleaning materials (including conductive solids such as steel wool, metalized cloth, and silicon carbide, as well as conductive liquid solution) may not be used in proximity to energized parts unless procedures are followed which will prevent electrical contact.

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LOCK/OUT – TAG/OUT

PROCEDURES One of the most important functions to be performed prior to equipment maintenance and/or vessel entry to prevent possible injury is the proper isolation of associated equipment. This procedure establishes a program to effectively secure machinery, equipment, and/or energy sources for the operations and maintenance functions. This procedure applies to all COASTAL, LLC facilities, locations, and operations. Each operating facility shall establish a lock/out – tag/out to prevent the premature and/or inadvertent operations of equipment which could expose employees to potential hazards associated with such operations.

PROCEDURE

GENERAL

1. To insure the success of a lock/out – tag/out program it is essential that personnel be trained in all applicable procedures.

2. Individually keyed safety locks and danger tags shall be furnished or made available to every employee required to isolate or work on machinery, power systems, and other mechanical equipment and shall be used only for that purpose. Duplicate keys should be prohibited to eliminate the chance for unauthorized lock removal.

3. The safety locks and danger tags should be used to secure equipment controls when making repairs, cleaning, or doing work where there is a potential for injury should the equipment be energized or be put into operation while such work is being done.

LOCK/OUT-TAG/OUT INSTALLATION

1. Following equipment shutdown and system isolation, operations personnel shall install their locks and tags to main disconnect switch, valve, and other related equipment.

2. The electrical start switch, if available for the piece of equipment being worked on, must be activated to insure proper isolation following main disconnect switch isolation. Following the activation of each start switch the reset and stop switches must be activated to prevent premature starting of equipment following lock/out removal.

3. For power drives other than electric it will be necessary to immobilize equipment thru valve lock/out, blinding, removal of hydraulic or pneumatic pressure, or other effective means. If possible on large pieces of equipment such as compressors where the crankcase is to be entered by the hands or body, the flywheel or crankshaft must be secured to prevent rolling. When hands must go past cylinder valves on the compressor end, a position means must be used to prevent piston travel.

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LOCK OUT – TAG OUT REMOVAL

1. Upon completion of the operations lock and tag will remain in place until all others have been removed at which time commissioning can begin.

2. If it is necessary to remove a lock another employee has placed, proper documentation in the appropriate operating log must be completed by the supervisor removing the lock. The removal of a lock under these circumstances must be restricted to the authority of the involved supervision with concurrence of the craft supervisor. Prior to the removal the respective supervisor must conduct a thorough inspection.

CONTROL

1. To assist in control of this program it is imperative to maintain documentation to verify proper installation and removal of all locks and tags.

2. Supervision holds the key to maintaining an effective locking and tagging program. They must insure that employees know, understand, and follow Lock/Out – Tag/Out procedures to prevent personal injury.

TRAINING The company shall provide training to ensure the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application to the following:

1. 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 method and means necessary for energy isolation and control

2. Each affected employee shall be instructed in the purpose and use of the energy control procedure.

3. 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.

4. When tag out systems are used, employees shall be trained in the following limitations: a. Tags are essentially warning devices attached to energy isolating devices, and do

not provide the physical restraint on those devices that is provided by a lock. b. 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.

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c. Tags must be legible and understandable by all employees, affected employees, and all other employees whose work operations are or may be in the area, in order to be

d. Tags and their means of attachment must be made of materials which will withstand the environment conditions encountered in the workplace.

e. Tags may evoke a false sense of security, and their meaning needs to be understood as part of the overall energy control program.

f. Tags must be securely attached to energy isolating devices so that they cannot be removed.

EMPLOYEE RETRAINING

1. 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

2. Additional retraining shall also be conducted whenever the company has reason to believe, that there are deviations from or inadequacies in the employee’s knowledge or use of the energy control procedures.

3. The retraining shall reestablish employee proficiency and introduce new or revised control methods and procedures, as necessary.

4. The company shall certify that employee training has been accomplished and is being kept up to date. The certification shall contain each employees name and dates of training.

LOCKOUT/TAGOUT DEVICES If an energy source can be locked out this method shall be utilized. Lockout Device: A devise that utilizes a lock, either key or combination to hold an energy isolating devise in a safe position. If an energy source cannot be locked out, a tag out system shall be utilized. Tag-Out: Warning of hazardous energy (Do Not Start) (Do Not Open) (Do Not Close) (Do Not Energize) Devices shall indicate the identity for the employee applying the device.

PERIODIC INSPECTION The company shall conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this program are being followed.

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1. The periodic inspection shall be performed by an authorized employee other

than the one(s) utilizing the energy control procedure being inspected. 2. Documentation of the inspection shall include the date, equipment,

employees, and the person performing the inspection. APPLICATION OF CONTROL

The established procedures for the application of energy control (the lockout/tagout procedures) shall cover the following elements and actions and shall be done in the following sequence:

1. Preparation for shutdown. Before an authorized or affected employee turns off a machine or equipment, the authorized employee shall have knowledge of the type and magnitude of the energy, the hazards of the energy to be controlled, and the method or means to control the energy.

2. Machine or the equipment shutdown. The machine or equipment shall be turned off or shutdown using the procedures established for the machine or equipment. And orderly shutdown must be utilized to avoid any additional or increased hazard(s) to employees as a result of the equipment stoppage.

3. Machine or equipment isolation. All energy isolating devices that are need 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).

4. Lockout or tagout device application.

a. Lockout or tagout devices shall be affixed to each energy isolating device by authorized employees.

b. Lockout devices, where used, shall be affixed in a manner so that it will hold the energy isolating devices in a “safe” or “off” position.

c. 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.

d. 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.

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e. Where a tag cannot be affixed directly to the energy isolating device, the tag shall be located as close as safely possible to the devise, in a position that will be immediately obvious to anyone attempting to operate the devise

5. Stored Energy. Following the application of lockout or tagout devices to energy isolating devices, all potentially hazardous stored or residual energy shall be relieved, disconnected, restrained, and otherwise rendered safe.

a. If there is the possibility of re-accumulation of stored energy to hazardous level, verification of isolation shall be continued until the servicing or maintenance is completed, or until the possibility of such accumulation no longer exist.

6. Verification of Isolation. 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

ADDITIONAL REQUIREMENTS

Testing or positioning of machines, equipment, or components thereof. In situations where 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.

1. Clear the machine or equipment of tools. 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.

2. Remove employees from the machine or equipment area, the work shall be

checked to ensure that all employees have been safely positioned or removed. 3. Each lockout or tagout device shall be removed from each energy isolating

device by the employee who applied the device. EXCEPTION: When the authorized employee who applied the lockout or tagout device is not available to remove it, that device may provide equivalent safety to the removal of the device by the authorized employee who applied it. This specific procedure shall include, but not limited to, the following:

a. Verification by the superintendent that the authorized employee who applied the device is not at the facility

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b. Making all reasonable efforts to contact the authorized employee to inform him/her that his/her lockout or tagout device has been removed

c. Ensuring that the authorized employee has this knowledge before he/she returns to work at the facility.

4. Energize and proceed with the testing or positioning. 5. De-energize all systems and reapply energy control measures in accordance with section ( 1 ) of this section to continue the servicing and/or maintenance.

GROUP LOCKOUT OR TAGOUT

1. When servicing and/or maintenance is performed by a crew, craft, department, or other group, they shall utilize the procedure which affords the employees a level of protection equivalent to that provided by the implementation of a personal lockout or tagout device.

2. Group lockout or tagout devices shall be used in accordance with 29CFR1910.147(c) (4)

a. 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);

b. Provisions for the authorized employee to ascertain the exposure statue of individual group members with regard to the lockout or tagout of the machine or equipment

c. 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

d. Each authorized employee shall affix a personal 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.

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SHIFT OR PERSONNEL CHANGES Specific procedures shall be utilized during shift or personnel changes to ensure the continuity of lockout or tag out protection, including provision for the orderly transfer of lockout or tag out 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.

PERSONAL SAFETY EQUIPMENT REMEMBER: SAFETY EQUIPMENT WILL NOT ELIMINATE ACCIDENTS! THAT IS UP TO YOU. IT WILL HOWEVER, PROTECT AND REDUCE THE EFFORT OF AN ACCIDENT.

1. Approved hard hats and foot protection are required to be worn at all field construction areas except parking lots and general offices.

a. Under certain circumstances (an employee such as a welder when welding, must wear a welding hood) this requirement may be waived, but only the absolute amount of time the employee and supervisor sees that it is not practical to use a hard hat.

2. Approved eye protection including face shields and goggles shall be worn when welding,

cutting or working with molten metal or when other hazards to the eye exist such as grinding, chipping, using jack hammers, air chisels, steam cleaning, compressed air for cleaning, while handling hazardous chemicals, or as otherwise directed by management.

3. Approved safety harnesses or lifelines properly secured shall be worn from elevated

work positions six ( 6 ) feet or greater in height where no railing or other perimeter protection exists, employees shall inspect the equipment to insure it is in proper condition before each use.

4. Shall employees shall wear protective clothing and equipment required by

management.

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5. Ragged, torn or loose clothing will not be permitted on the job where it may cause an accident.

6. Long hair (hair extending to the shoulder and longer) and facial hair shall be contained

when necessary to guard against fire hazards and rotating machinery.

7. Gloves or other hand protection shall be worn where noise warning signs are posted.

8. Approved hearing protection shall be worn where noise warning signs are posted.

9. Some work assignments may require the use of special safety equipment such as face shield, ear plugs, rubber boots, respiratory devices, etc. where such equipment is required and provided, employees are expected to use this equipment for their own safety.

10. When selecting personal protective equipment the following requirements must be met:

a. Manufactured in accordance with accepted standards for performance and materials. (ANSI) American National Standards Institute. (NIOSH) National Institute for Occupational Health are designed to meet such standards

b. Durability and if possible the ability to maintain the equipment on the jobsite. c. Provide desired protection to workers against hazard exposure. d. Maximum comfort with minimal weight. e. Minimum restriction of essential body movement, vision, etc.

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COMPANY VEHICLE POLICY

1. Company vehicles are only to be driven on company business and to and from home. Any exceptions to the above will have to be approved by the company President, Trey Williams.

2. No unauthorized drivers or riders allowed. 3. Fuel receipts and odometer readings are to be turned in weekly to the office. 4. Use of alcoholic beverages, drugs, or narcotics which will affectoperator’s capabilities is

prohibited. 5. Seat belts must be worn at all times. 6. Drivers must obey all laws, maintain a satisfactory driving record and have a valid

driver’s license. 7. Follow the proper accident reporting procedures. 8. Drives are responsible for load safety and properly securing any loads. 9. Required use of safety devices and procedures such as: road flares or safety markers,

trailer safety chains, turn signals, flagman for backing, and fire extinguishers. It is the responsibility of the vehicle operator to assure all trailer lights are working properly with each use. NOTE: TRAILER LIGHTS DO NOT UNPLUG THEMSELVES

10. A monthly report of vehicle conditions and comments shall be turned in monthly to the office.

11. Drives assigned to a vehicle are responsible for operation of that vehicle by authorized company officials; drivers are responsible for safety inspections and proper maintenance to keep the vehicle in a safe operational condition.

12. Each employee that operates a company vehicle will be furnished a copy of this policy to sign and return for our files. A copy of this policy will also be included in our Safety Manual.

_________________________________ _______________________ Employee Signature Date _________________________________ ________________________ Supervisor Signature Date NOTE: Employees are subject to dismissal for violating the above rules.

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ACCIDENT/ INJURY OR ILLNESS REPORTING In the event that an accident/injury or illness occurs on or off the company’s premises during working hours the employee must notify their supervisors before the end of the day or shift on which they occur. The supervisor in charge at the time will then proceed in filling out one of the two report forms listed below based on which is relevant to the incident at hand.

1. SUPERVISOR ACCIDENT INVESTIGATION REPORT FORM 2. EMPLOYEE INJURY AND ILLNESS REPORT FORM

All of Coastal LLC’s Accident/Injury or Illness reports are kept on file with the company’s HSE Coordinator @ COASTAL, LLC’s main office.

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SUPERVISOR ACCIDENT INVESTIGATION REPORT Employed by (Company Name ) ______________________________________________________________ Name (First, Middle Initial, Last) _____________________________________________________________ Job Classification (Welder, Pipefitter, etc.) _______________________________________________________ Date of Injury (Mo. Day, Yr.) ____/____/____ Time of Injury ___________ ___ AM ___ PM Location of Incident _________________________________________________________________________ Accident and Injury Category – Check those that apply: ___ Medical Treatment ___ Lost Time ___ Restricted Work ___First Aid ___ Fatality ___ Motor Vehicle ___ Property Damage Detailed narrative description: How did accident occur, why? (Objects; equipment; tools used; circumstances; assigned duties) (Be specific) __________________________________________________________________________________________ ____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ (Use additional sheets if required) Witnesses to accident _____________________________________________________________________________ YES NO ___ ___ 1.0 Was equipment or a hazardous condition(s) a contributing factor? If yes, answer the

following. If no, skip to Item # 2. ___ ___ 1.1 Did location/position of equipment/materials contribute to a hazardous condition? ___ ___ 1.2 Did any defect(s) in equipment/tools contribute to the hazardous condition(s)? ___ ___ 1.3 Was the defective equipment recognized? ___ ___ 1.4 Was the defective equipment reported? ___ ___ 1.5 Was the correct equipment/tools/material used? ___ ___ 1.6 Did employee know where to obtain equipment/tools and material required for the job? ___ ___ 1.7 Is there an adequate equipment inspection procedure(s) to detect the hazardous condition(s)? ___ ___ 1.8 Were adverse environment factors such as noise, temperature, solvent, gases, dusts,

insects, etc. a factor? ___ ___ 1.9 Was the workspace sufficient? Explain each yes or no answer as needed ________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

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______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ YES NO ___ ___ 2.0 Was job procedure(s) used a contributing factor? If yes, answer the following. If no, proceed to Item # 3. ___ ___ 2.1 Is there a written or known procedure ( rules ) for this job? ___ ___ 2.2 Did procedure(s) cover factors that contributed to the accident? ___ ___ 2.3 Did employee(s) know the job procedures? ___ ___ 2.4 Did employee(s) deviate from known job procedure? ___ ___ 2.5 Was employee capable of performing the job? Explain each yes or no answer as needed ________________________________________________________ __________________________________________________________________________________________ __________________________________________________________________________________________ __________________________________________________________________________________________ YES NO ___ ___ 3.0 Was lack of personal protective equipment a contributing factor? If yes, answer below.

If no, proceed to Item # 4 . ___ ___ 3.1 Was proper protective equipment available? ___ ___ 3.2 Was proper protective equipment available? ___ ___ 3.3 Was employee aware that protective equipment was required? ___ ___ 3.4 Did employee(s) know how to use and maintain protective equipment? ___ ___ 3.5 Was protective equipment adequate? ___ ___ 3.6 Was emergency equipment available for this job? Explain each yes or no answer as needed ______________________________________________________ _________________________________________________________________________________________ _________________________________________________________________________________________ _________________________________________________________________________________________ 4. What was the primary cause for incident? ____________________________________________________ _________________________________________________________________________________________ 5. What immediate action was taken to prevent recurrence? _______________________________________ _________________________________________________________________________________________ 6. What other action is required to assure future compliance? _______________________________________ __________________________________________________________________________________________ Date Prepared ___/___/___ Signature of Supervisor/Mgr. ______________________________

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EMPLOYEE INJURY AND ILLNESS REPORT FORM

TODAYS DATE:__________________________________

EMPLOYEES NAME: _______________________________________________________________

DATE OF ACCIDENT/ILLNESS: ____________________ TIME: ________________________

LOCATION: _________________________________________________________________________

REPORTED TO: _____________________________________________________________________

TYPE OF INJURY/ILLNESS: _________________________________________________________

PART OF BODY INJURED:___________________________________________________________

DESCRIPTION OF HOW AND WHY ACCIDENT/ILLNESS OCCURRED: _____________

_______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________

WITNESS: ____________________________________________________________________________

TREATMENT:

___ FIRST AID ___ SENT HOME ___ EMERGENCY ROOM

___ SENT TO PHYSICIAN

PHYSICIAN’S NAME: ______________________________________________________________

PHYSICIAN’S ADDRESS, CITY, STATE, ZIP CODE:________________________________

_____________________________________________________________________________________

EMPLOYEE’S SIGNATURE: _____________________________________

TPFI REP SIGNATURE:__________________________________________

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ENVIRONMENTAL RESPONSIBILITIES

WASTE MANAGEMENT

1. All waste generated and handled at facilities or project sites that COASTAL, LLC generates, and is responsible for, must be disposed of correctly at a Company-approved facility. Your responsibilities are to follow established customer or company rules pertaining to all disposal operations. If you are unfamiliar with proper disposal procedures, ask your supervisor. Project wastes, trash, and/or scrap materials will be taken into consideration before work begins. An employee will be shown how and where proper handling, organization, and storage of waste and scrap materials to minimize potential impact to the environment. Employees will be made aware of the proper method to dispose of wastes. 2. All waste containers must be adequately labeled for proper identification, management, transportation, and disposal.

3. Do not dispose of waste substances into drain, sewers, or surface water.

4. Under no circumstances is waste material to be dumped on lease roads, highways, customer locations, company facilities, or any place other than a proper disposal site.

SPILLS/RELEASES

1. Report any leaks, spills, and other environmental incidents to your supervisor immediately. If spills or releases of chemicals to the environment exceed specifiedthreshold amounts, it must also be reported to the environmental regulatory agencies.

2. All leaks, spills. Or releases must be addressed immediately by cleaning up the spilledmaterial, (if safe to perform such an action), stopping the release from spreading and initiating remediation efforts. If you are not familiar with the appropriate procedure, contact your supervisor or HSE representative.

ENVIRONMENTAL AUTHORIZATIONS/PERMITTING

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All required authorizations must be obtained before any construction, modification, or operation of equipment or facilities. All conditions or limits required by the permits or regulations must be followed. Contact the Environmental Department for consideration and approval. STORM WATER POLLUTION PREVENTION 1. All containers of product or waste shall be marked or labeled to identify their contents and be maintained in good condition. 2. Loading and unloading of chemical and waste materials by COASTAL, LLC or contract personnel shall be supervised at all times and restricted to areas where spills can be properly contained. 3. Empty drums shall be stored in a designated drum area, preferably under a roof, to Prevent storm water contact. 4. Precautions shall be taken to control soil erosion around ditches, culverts, and swales.

SAFETY PROGRAM FOR HAZARDOUS WASTE OPERATIONS (29CFR1910.120) Prior to entry of a hazardous material waste site, COASTAL, LLC shall evaluate site

characterization and analysis in order to provide adequate personal protective equipment to guard against identified hazards that its employees may become exposed.

During site entry, a more detailed evaluation of the site specific characteristics shall be performed to further identify existing site hazards and to further aid in the selection of appropriate engineering controls and protective equipment for the task to be performed.

Preliminary surveys will include all suspected conditions that may pose inhalation or skin absorption hazards that are immediately dangerous to life or health (IDLH). Examples of such hazards include, but are not limited to, confined space entry, potentially explosive or flammable situations, visible vapor clouds, or area where biological indicators such as dead animals or vegetation are located.

The following information to the extent available must be obtained from the site owner or operator:

a. Location and approximate size of the site. b. Description of job task to be performed c. Duration of planned employee activity. d. Site topography.

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e. Site accessibility by air and roadways. f. Pathways for hazardous substance dispersion. g. Present status, methods of contracting, and capabilities of emergency response

teams. h. Hazardous substances and health hazards expected at this site and their chemical

and physical properties. MSDS must be obtained and received. Once the hazards of the site have been positively identified, the appropriate PPE (Personal Protective Equipment) shall be selected and used. The risk associated with specific hazardous substances and health hazards are relayed to each employee. MSDS will be available in conjunction with the entire Hazard Communication Program at the site. Site Control Programs include a site map, work zones, use of the “Buddy System”, site communication of nearest medical assistance team. Employees are thoroughly trained in the following: (in accordance with OSHA 29CFR1910.120 (e)).

a. Names of personnel and alternates responsible for site safety and health. b. Hazards present on site. c. Use of PPE. d. Work practices that will minimize the risk of hazard. e. Recognition of symptoms and signs of over-exposure to a hazard.

Employees may not participate in field activities until they have been trained to a level required by their job function and responsibility. All employees shall at the time of job assignment receive a minimum of 40 hours of initial instructions off the site, and minimum of 3 days actual field experience under the direct supervision of a trained experience supervisor. (Those exposed to unique hazards receive additional training), or in accordance of OSHA CFR 1910.120 (e) (9), employers who can show by an employees work experience and/or training that the employees has had initial training equivalent to the required training shall be considered as meeting the initial training requirements. Each employee will be certified as having such training. A medical surveillance program is instituted by COASTAL, LLC for the following employees:

1. Employees that may be exposed to hazardous substances or health hazards at or above the established permissible exposure limits (PEL).

2. All employees who wear a respirator for more than 30 days per year. Medical examinations shall be in strict accordance of 29 CFR 1910.120 (f) and meeting

the criteria of 29 CFR 1910.120.

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Feasible engineering controls and work practices will be instituted to reduce and maintain employee exposure to or below PEL. An appropriate combination of engineering controls, safe work practices, and personal protective equipment has been established, prior to entry, to avoid the risk of overexposure of hazardous materials. The level of protection provided by PPE selection shall be increased protection is necessary to reduce employee exposures below established PEL’s for hazardous substances and health hazards.

It is the endeavor of COASTAL, LLC to ensure worksite safety to each employee to avoid all risk of all hazards.

HAZARDOUS NON-ROUTINE TASKS Before employees are assigned to hazardous non routine task, the employee will be given information about the hazards involved and will include the following information:

Specific chemical hazards,

Protective/safety measures the employee can take

Measures the company has taken to lessen the hazards including ventilation, respirators, presence of another employee and emergency procedures.

It is the policy of COASTAL, LLC that no employee will begin work on any non routine task without receiving a safety briefing from the supervisor responsible for undertaking the tasks.

CHEMICALS IN UNLABELED PIPES

Line breaking and maintenance task are often performed by COASTAL, LLC employees in areas where chemicals are run through unlabeled pipes. Prior to beginning work in these areas, the employee shall contact the COASTAL, LLC foreman for information regarding precautions which should be taken. The COASTAL, LLC foreman/customer representative has a copy of the blueprint for the plant piping system which identifies the location of all pipes and their contents.

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LEAD CADMIUM AND OTHER METAL EXPOSURES

All projects consisting of working with lead, cadmium, or other metal exposures shall be contracted to a third party contractor that is qualified and meets the requirements of 29CFR1910.1025 and 29CFR1910.1027 and their appendices. The above contractor shall complete a COASTAL, LLC contractor questionnaire and be approved by COASTAL, LLC management before beginning a project.

CRAFT SKILLS ASSESSMENT All workers shall be required to participate in craft skills assessment prior to beginning work. The assessment program shall consist of hands-on and/or a written assessment. This program shall be conducted by the COASTAL, LLC quality control/quality assurance representative. The program provides a mechanism for assessing the skills and knowledge of crafts people an identifying areas where a individual may need more training. Results of the skills assessment will provide data to measure trends and improvements in the overall quality, safety, and productivity of our workforce and focus attention on those areas of workforce development that require additional efforts.

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COASTAL, LLC

ENVIRONMENTAL MANAGEMENT 1. GENERAL

A. INTRODUCTION TPFI is dedicated to the maintenance of a clean environment and actively participates in all aspects of environmental control as it relates to the painting and sandblasting industry. B. PURPOSE This program has been created to establish a systematic procedure concerning the use, storage and disposal of paint related chemicals which are hazardous to the environment. D. SCOPE This program is tailored to the operations of TPFI, it includes all TPFI employees, management and the jobsites on which environmentally hazardous chemicals are used.

2. DEFINITIONS

A. CHEMICALS Chemicals- shall mean any liquids, powders, metals or substances which are used by TPFI. B. THINNER

1. Virgin-shall mean unused and clean as from the manufacturer. 2. Wash-same as B, (1). 3. Waste-shall mean used and unclean due to the cleaning of painting equipment.

3. TRAINING A. SAFETY& ENVIRONMENTAL COORDINATOR

1. Shall keep the management informed as to current regulations relating to TPFI operations. 2. Shall provide the appropriate training, inspections and corrective guidance to the individual employees in order to maintain environmentally clean jobsites.

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B.EMPLOYEES 1. Shall be trained as to the individual chemical they use and proper procedures concerning the application, storage and disposal of the same.

C. RECORDKEEPING

1. Any meeting where environmental topics are to be discussed shall be documented prior to instruction by each individual signing the appropriate form.

2. All jobsite inspections shall be documented on the standard TPFI jobsite inspection form.

3. Employee violations of company environmental procedures shall be documented on the TPFI safety violation form and shall be considered as a safety violation resulting in immediate correction and appropriate disciplinary action.

4. PROCEDURE

A. MATERIAL SAFETY DATA SHEETS (MSDS) 1. The MSDS of each product used by TPFI shall be available to each employee. 2. The environmental information on each MSDS shall be the basis for safety meeting and special hazard meetings regarding environmental topics. 3. The MSDS of each product shall be the initial source of information used in the determination of environmentally hazardous chemicals for storage and disposal.

B. USE OF HAZARDOUS CHEMICALS

1. PREPARATION a. Always keep unused chemicals in a covered container b. Place ground cover on ground before opening any paint containers. c. Whether stirring with a power tool or by hand, do not allow the exposed stirring instrument to touch the ground. d. Always place lids back on empty containers. e. Immediately clean up any spilled chemical and place contaminated soil in such a position as to not leach into the ground.

2. APPLICATION

a. Never spray a chemical on the ground b. Always to as much as possible to prevent excessive overspray.

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c. When brushing, minimize dripping by not over soaking the brush with chemical. d. Always do as much as possible to prevent dripping on to the ground.

3. CLEANING a. Never allow wash thinner to be poured on the ground

b. Make sure all wash and waste thinner containers are labeled according to the minimum requirements of U.S.E.P.A. and D.O.T. c. Make sure all thinner containers are in good conditions and closed d. Never spray wash thinner on ground when cleaning a spray gun. e. Always dispose of waste thinner into the proper container designated for that purpose only.

C. DISPOSAL OF HAZARDOUS CHEMICALS

1. Five (5) gallon containers shall be available at each jobsite for the purpose of collecting waste thinner. 2. As the (5) gallons containers become completely full, they will be emptied in one of two locations:

a. The fifty-five (55) gallon drum in the TPFI yard designed and labeled for waste thinner. b. Those fifty-five (55) gallon drums in a refinery or jobsite which have been specifically designed and labeled by the owner for waste thinner.

3. All five (5) and fifty-five (55) gallon waste container must be closed at all times except when adding or dispensing waste thinner. 4. All hazardous waste chemicals which are not disposed of by another company (C,2,b) shall be stored on the TPFI property for no longer than six (6) months after the accumulation date at which point the hazardous waste will be shipped off site to an appropriate disposal facility by an appropriate shipper.

D. DISPOSAL OF EMPTY PAINT CONTAINERS

1. Remove lid from empty container and allow to air dry. 2. Remove label from container 3. Crush cans and place into dumpster for disposal.

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ALCOHOL AND DRUG ABUSE POLICY

1. STATEMENT OF PURPOSE COASTAL,LLC’S most valuable resource is its employees. By selecting the best employees and providing them an environment for professional growth and development, COASTAL, LLC can deliver the highest quality of services to the community, therefore, the health and safety of all employees and their families is a serious concern. COASTAL, LLC will not tolerate any drug or alcohol use which imperils the health and well being of its employees or threatens its reputation in the community. Employees have the right to work in an alcohol and drug-free environment and to work with persons free from the effects of alcohol and drugs. COASTAL, LLC is therefore committed to maintaining a safe and healthy workplace free from the influence of alcohol and drugs. 2. MANDATORY REFERRAL FOR DECLINING JOB PERFORMANCE OR ERRATIC ON-THE-JOB BEHAVIOR COASTAL, LLC’s supervisors will be alert to declining job performance or erratic on-the-job behavior. This may be the product of an employee’s personal problem; therefore, the supervisor will refer the employee to the company doctor for a urine and/or blood test for alcohol and drug abuse (Drug Screening). If an employee tests negative, he or she will then be referred for counseling. An employee who was mandatorily referred for testing because of declining job performance or erratic on-the-job performance, and who tests positive for alcohol or drugs will be in violation of the company’s Alcohol and Drug Policy and will be subject to immediate termination. 3. ARREST OR CONVICTION UNDER CRIMINAL DRUG STATUTE Employees must notify their immediate supervisor within five days of any arrest or conviction of a criminal drug statute.

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4. PROHIBITIONS COASTAL, LLC policy prohibits the following:

1.Use, possession, manufacture, distribution, dispensation or sale of illegal drugs or drug paraphernalia on company premises or company business, in company supplied vehicles, or during work hours.

2. Unauthorized use or possession, dispensation or sale of controlled substance on company premises, on company business, in company supplied vehicles or during working hours. 3. Storing in a locker, desk, automobile or other repository on company premises any illegal drug, controlled substance or any alcohol.

4. Being under the influence of an unauthorized controlled substance illegal drug or alcohol on company premises, in company supplied vehicle, or during working hours; being “under the influence” of alcohol is defined as a blood alcohol content of .10; being “under the influence” of an unauthorized controlled substance or illegal drug is defined as testing positive at a specified ng/nl level. 5. Use of alcohol off company premises that adversely affects the employee’s work performance, his own or other’s safety at work or company’s regard or reputation in the community. 6. Possession or use of illegal drugs off company premises that adversely affects the employee’s work performance, his own or other’s safety at work or company’s regard or reputation in the community. 7. Switching or adulterating any urine sample submitted for testing. 8. Refusing consent to testing or to submit a urine or blood sample for testing when requested by management.

9. Refusing to submit to an inspection when requested by management.

10. Conviction under any criminal drug statute for a violation occurring in the workplace.

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11. Arrest or conviction under any criminal drug statute under circumstances which adversely affects the company’s regard or reputation in the community.

12. Failure to notify the immediate supervisor of any arrest or conviction under any

conviction under any criminal drug statute within five days of the arrest or conviction.

13. Refusing to sign a statement agreeing to abide by Company’s Alcohol and Drug Abuse Policy.

5. OTHER TESTING The Company requires that every newly hired employee be free of alcohol or drug abuse. Each offer of employment shall be conditioned upon the consent of a blood and/or urine test for alcohol and drugs. The company will not hire any applicant who fails to consent to the drug test. Whenever COASTAL, LLC suspects that an employee’s work performance or on-the-job behavior may have been affected in any way by alcohol or drugs, or that an employee has otherwise violated this policy, the company may require the employee to a urine and/or blood sample. An employee who tests positive for alcohol or drugs as a result of such a test will be in violation of this policy. Whenever COASTAL, LLC standard policy requires an employee to undergo a physical exam, that examination will include a urine and/or blood test for alcohol and drugs. An employee who tests positive for alcohol or drugs during such an exam will be in violation of this policy. Whenever COASTAL, LLC determines that an employee may have contributed to an accident involving a fatality, serious bodily injury, or substantial damage to property, the company may require the employee to submit to a urine and/or blood test. An employee who tests positive for alcohol or drugs as a result of such a test will be in violation of this policy. COASTAL, LLC will afford applicants and employees subject to testing the opportunity, prior to testing, to list all prescription and non-prescription drugs they have used in the last thirty days and to explain the circumstances surrounding the use of such drugs. Applicants and employees subject to testing must sign, prior to testing an approved form consenting to the testing and consenting to the release of the test results to the COASTAL, LLC owners.

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Prior to taking any action, the company will give all applicants and employees who test positive for alcohol or drugs the opportunity to explain the test results. 6. INSPECTIONS Whenever COASTAL, LLC suspects that an employee’s work performance or on-the-job behavior may have been affected in any way by alcohol or drugs, the company may search the employee the employee’s locker, desk, or other company property under the control of the employee, as well as the employee’s personal effects or automobile on company property. Whenever it deem appropriate, COASTAL, LLC may use trained dogs to detect illegal drugs in personal and company property on company’s premises. 7. CONSEQUENCES FOR VIOLATION OF THIS POLICY Violation of this Alcohol and Drug Policy may result in severe disciplinary action, including discharge for a first offense, at COASTAL, LLC’s sole discretion. In addition to any disciplinary action for a positive test for alcohol or drugs, The Company may, in its sole discretion, refer an employee for assessment, counseling, and referral to a treatment program for alcohol or drug abuse. Employees referred as a result of a positive test for alcohol or drugs must immediately cease any alcohol or drug abuse, must subject themselves to periodic unannounced testing for a period of twenty-four months, and must comply with all other conditions of the treatment and counseling program. Employees who under go counseling and treatment for substance abuse and who continue to work, must meet all established standards of conduct and performance. COASTAL, LLC will promptly terminate any employee who tests positive for alcohol for drug abuse or who test positive on a periodic unannounced test for alcohol or drugs during the twenty-for month period following completion of the rehabilitation program. 8. CONDITION OF EMPLOYMENT Compliance with COASTAL, LLC’s substance abuse policy is a condition of employment. Failure or refusal of an employee to cooperate fully, sign any required document, submit to any inspection or test, or follow any prescribed course of treatment will be grounds for termination.

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9. RESERVATION OF RIGHTS COASTAL, LLC reserves the right to interpret, change, rescind or depart from this policy in whole or in part without notice. Nothing in this policy alters an employee’s status. Employees remain free to resign their employment at any time for any or no reason. COASTAL, LLC retains the right to terminate any employee at any time, for any or not reason. 10. CONSENT I have carefully and thoroughly read COASTAL, LLC’s Alcohol and Drug Abuse Policy. I agree, without reservation to follow that policy

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PROCESS SAFETY MANAGEMENT The purpose of this program is to prevent or minimize consequences of catastrophic releases of toxic, reactive, flammable or explosive chemicals. These releases may result in toxic, fire, or explosion hazards. Before conducting any process hazard analysis required by 29CFR1910.119, the company shall complete a compilation of written process safety information to enable the company and the employees involved in operating the process to identify and understand the hazard posed by those processes involving highly hazardous chemicals. This 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. Material safety data sheets are to be included in this compilation of written process safety information. The company shall assure that each employee and each contract employee is trained in the work practices necessary to perform his/her job. Prior to beginning a project that fall under the process safety management standard the company shall assure that all employees and contract employees attend and participate in a site specific orientation. This site specific orientation shall assure that all employees are instructed in the known potential fire, explosion, or toxic release hazards related to his/her job and the process and the applicable provisions of the emergency action plan. Documentation showing that each employee has received and understood the required training. This documentation shall include the identity of the employee, the date of training and the means used to verify that the employee understood the training. COASTAL, LLC and contractor employees shall abide by COASTAL, LLC and it’s customers safe work practices to provide for the control of hazards during operations such a lock/out-tag/out; confined space entry; opening process equipment or piping; and control over entrance to a facility by maintenance, contractor, laboratory, or other support personnel. COASTAL, LLC and its contractors shall advise the COASTAL, LLC customer of any unique hazards presented by COASTAL, LLC customer of any unique hazards presented by COASTAL, LLC or its contractors work, or any hazards found by the COASTAL, LLC or its contractors work. The COASTAL, LLC customer shall 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 29CFR1910.252(a) have been implemented prior to beginning the

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hot work operations; it shall indicate the day(s) authorized for hot work; and identify the object on which hot work is to be performed. The permit shall be kept on file until completion of the hot work operations. Incident investigation COASTAL, LLC shall investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace. An incident investigation shall be initiated as promptly as possible, but not later than 48 hours following the incident. An incident investigation team shall be established and consist of at least one person knowledgeable in the process involved, including a contract employee if the incident involved a contractor, or other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident. Resolutions and corrective actions must be documented and maintained for 5 years. All employees, contract employers, and contract employees must respect the confidentiality of trade secret information when the process safety information is released to them.