ssmcsafe safety reference manual

SAFETYREFERENCE MANUAL

Mission Statement

Safety is the individual and personal responsibility of everyone at SSMC, management, and employees alike. Management is responsible for providing a safe work environment and the knowledge of how to work safely. Safety is an important factor in the operation of a business, and it deserves our attention. We have a responsibility to conduct a continually improving safety program. A safe workplace doesn’t result from only distributing memos and displaying posters. It is the result of a well-planned, well-organized, and well-executed safety program. SSMC’s management is committed to a successful safety program.

Employees are responsible to develop and use safe working habits every workday, to follow safety rules, and to report any unsafe condition of equipment or the building immediately to their supervisor.

Time, Effort, and Funding will be devoted to safety training, because an injury can be far more costly than training. The benefits of training are many, and they include lower medical costs, fewer lost-time injuries with the resulting pain and suffering, and higher productivity. With effective training, safety awareness can become a work habit, part of an employee’s consciousness, and part of our corporate culture.

SSMC has a high level of concern for our people, their health, and their families. Injury to an employee means emotional and financial hardship on the employee and their family, means a loss of prestige for the company in the community, and can seriously affect the friendliness and cooperativeness of our workforce. This is the most important reason for our commitment. Personal safety of SSMC employees shall not be compromised!

The principal goal of our safety program is a continuing commitment to safety and training, and the prevention of all accidents and injuries. If we utilize to the fullest the talents of our management and employee TEAM, we feel certain our efforts to achieve accident-free operations will be successful.

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Table of Contents

Introduction 6

SSMCSafe Installation Guide 7

Accountability Statements 9

President/EVP/General Manager......................................................................................................10

Safety Manager................................................................................................................................11

Management.....................................................................................................................................12

Transportation Manager/Supervisor.................................................................................................13

General Associates...........................................................................................................................14

Current Fiscal Year Insurance Pooling Requirements15

Preferred Work Method’s 21

Transportation..................................................................................................................................22

Garage/Maintenance.........................................................................................................................25

Processing........................................................................................................................................26

Tomato & Re-Pack...........................................................................................................................27

Hazard Assessment/Training/Monitoring of PWM’s Compliance 28

Hazard Assessment..........................................................................................................................28

Training ~ Pre-Shift Safety/Stretching Meeting...............................................................................44

Monitoring ~ Coach Card Program/Tracking...................................................................................45

Accident Policy/Procedure/Reporting 47

Transportation/Vehicle Accident Policy 48

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Filing Accident/Injury/Illness Reports..............................................................................................53

How to Conduct a Complete Accident/Illness Investigation............................................................56

Safety Orientation Training Packet 30/60/90 70

Required OSHA Training/Guidelines 71

Safety Steering Committee Guidelines 77

SEPP Manual and the Annual Management Risk Assessment79

Introduction......................................................................................................................................79

Terrorist and Other Threats..............................................................................................................80

Food Products 80

Anthrax 81

Coetaneous Anthrax 81

Gastro-intestinal Anthrax 81

Inhalational Anthrax 82

Facility Threats 82

Critical Control Points 83

Dangerous, Contaminated or Suspicious Letters or Packages Procedures........................................85

Response Guidelines for Security Coordinator.................................................................................86

SSMC Operating Company - Self Audit Questions 88

Employees........................................................................................................................................88

Visitors, Vendors & Contractors......................................................................................................88

Inbound (Delivery) Vehicles............................................................................................................89

Outbound (SSMC Vehicles).............................................................................................................89

Site Security Systems.......................................................................................................................90

Operational Security Procedures and Processes 91

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Facilities:..........................................................................................................................................91

Transportation:.................................................................................................................................94

SSMC Critical Control Recap95

Monthly Safety Assessments 96

Doctor/Clinic Relationship 100

Current D.O.T. Requirements 102

Visitor Awareness/Protection Program 107

Recommended Additions to Safety Programs 108

Personal Protective Equipment Program........................................................................................108

Vehicle Accident Packet Checklist.................................................................................................127

Vehicle Accident Report................................................................................................................128

Transportation Investigation Report...............................................................................................132

Accident Evaluation.......................................................................................................................133

The Safety Benchmark Report134

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IntroductionThis manual was written to assist you in developing and implementing

your own Safety Program. All of the documents within this manual are available on the accompanying disc, or on the SYSCO website: http://bbp.sysco.com/sites/Safety/default.aspx. It is recommended that as the safety manager, you become very familiar with this site. Most of the information needed to assist with a successful Safety Program can be obtained from this site. SSMC has its own section within this SYSCO website. Accident investigations, safety meetings, hazard assessments and C.O.A.C.H. Cards are used to develop and teach the Preferred Work Methods that will provide a safe and productive workplace for our employees. This manual gives the specifications that are necessary for all SSMC safety programs. These specifications are referred to as SSMCSafe. As you have read in the Mission Statement, our goal is the prevention of all accidents and injuries. SSMCSafe is built on the premise that every accident is preventable and that the past predicts the future. Keep this in mind while developing your Safety Program. The first section of this manual is the SSMCSafe Installation Guide. It is recommended that you utilize this guide when implementing your Safety Program. Once this manual has been distributed, you will be contacted by your regional safety director. Direct all questions about this manual or any other safety issue to your regional safety director. Good luck, and remember think SSMCSafe.

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http://bbp.sysco.com/sites/Safety/default.aspx

SSMCSafe Installation GuideThe following table outlines the pre-installation and installation steps for the SSMCSafe process. Please write the DATE each step was completed in the corresponding box.

Company: ____________________ Completed By: _____________________

Start Date: ____________________ Phone/Ext: ________________________

*Complete this report quarterly or upon completion of an installation Phase to your Regional Safety Manager.

Pre-Install Phase 2. A. Hiring practices review and

development A. Finalize PC Accountability

B. Accident Reporting/Investigation /Follow-up/Training

B. Implementation Planning

C. Written Safety Work Rules Phase 3.

D. Formalized Operations Training

A. Discuss / Create Draft supervisor accountabilities

E. Management Assessment/Survey

B. PWM Task Force development

F. Supervisor Survey C. Finalize supervisor training plans

G. Facility Audit/Regulatory Program Review

D. One-on-one meetings with supervision to discuss roles/accountabilities (draft form and supervisors objectives based on the assessment

H. Tracking Systems Review/Training

Phase 4

I. Hazard Assessment (Year) A. Finalize Supervisor Accountabilities

J. Established Planning Committee

B. Review / Acceptance of Supervisor objectives

Phase 1 C. Conduct supervisor training/sign accountability statement

A. Mission Statement/Accountability Statement for Planning committee

D. Discussion with supervision to determine # of observations required (PWM/COACH)

B. Set Goals

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Phase 5 Phase 7 A. Review of completed PWM A. Finalize employee Training Plans

B. Set # of observations required

B. Final review/approval of PWM’s to date

C. Continue PWM development (Task Forces

C. Conduct employee training

Phase 6 D. Employees review DRAFT PWM’s

A. Review Completed PWMs E. Finalize PWM’s / Begin observations (PWM & COACH)

B. Discuss Employee Training plans

Phase 8

C. Supervisor’s meeting: Observations & Feedback

A. Process Review / Review PWM’s to date

B. Observation results review

C. One month Follow-up

*Shaded areas are Planning Committee Agenda items

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Accountability StatementsCommitment is the basic requirement for a successful safety program. For safety to work most effectively we need this commitment throughout the SSMC organization, from top to bottom. SSMC’s senior management believes that safety is as important as cost, productivity, and quality.

In an effort to continually, improve safety within the SSMC organization, deliberate safety responsibility is necessary. The purpose of these statements is to establish specific employee accountability at all levels within SSMC that spells out the principles that are to govern all responsibilities regarding safety.

By signing these statements, every individual acknowledges their understanding and acceptance of responsibilities and activities toward safety. These statements must be re-signed on an annual basis by all individuals. Below are examples of SSMC-developed Accountability Statements.

Note: All of these documents are available on the Sysco Website in the SSMC section.

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President/EVP/General Manager

President/EVP/General Manager Statement of Accountability and ActivityAs a member of the Upper Management team of this SSMC Operating Company I will be responsible for the following:• To assume responsibility for the implementation of the company’s safety system.

• To assume responsibility for the effectiveness of the company’s safety system.

I hereby agree to accept the aforementioned responsibilities and to fully engage in the activities described above as a condition of my employment with SSMC.

Printed Name: ___________________________________

Signature: ______________________________________

Date: ____________________

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Safety Manager

SSMC Safety Manager’s Statement of Accountability and Activity

As the Safety Manager of this SSMC Operating Company, I will be responsible for the following:

• To accept responsibility and conduct activities for the safety system as delegated by upper management, or as outlined in this manual.

• To accept responsibility for the development, implementation, and success of the safety program.

• To continually monitor the safety program and to submit appropriate reports to management on a timely basis.

• To maintain accident records, according to OSHA and SSMC guidelines.

• To analyze past and current losses for the purpose of prioritizing and directing safety training requirements.

• To direct and assist in the development and writing of preferred warehouse methods and preferred delivery methods.

• To direct and assist in the development and implementation of work practice observation methods and checklists.

• To direct and assist in the development and implementation of safety awareness training for warehouse supervisors, transportation supervisors, and all SSMC employees within this Operating Company.

• To direct and assist in the development and administration of the safety orientation of new or current employees and the safety training and safe work practices that is in place or developed as a result of this program.

• To direct and assist in the development and implementation of compliance programs such as those required by DOT, EPA, OSHA, FDA, and any state-mandated programs.

• To conduct monthly safety inspections as part of a committee including department managers and appropriate supervisors.

• To assist in the formation of an accident review committee.


Printed Name: __________________________________________________

Signature: ____________________________________________________

Date: ____________________

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Management

SSMC Management Statement of Accountability and Activity

As a SSMC Manager I will be responsible for the following:

• To accept responsibility and to carry out safety system activities as assigned or as outlined in this manual.

• To be responsible for the complete and accurate investigation of all accidents, injuries and illnesses involving my employees during my shift.

• To carry out immediate retraining when accident investigation shows it is necessary, when an employee requests it, when government issues require it, or during safety observations.

• To use weekly safety observations to check on employee work habits and to retrain them if necessary. I will give the written observations to my manager at the end of each week.

• To train new and current employees in using preferred work methods.

• To hold weekly safety meetings with the people working under my direction, so that we can discuss problems established by loss history.

• To attend monthly departmental safety awareness meetings and to take part in these meetings.

• To conduct monthly safety inspections as part of a committee made up of the department managers and the safety director.

• To help develop and write preferred work methods (PWMs) for each job, such as selector, forklift operator, or loader. The written PWMs will allow the development of warehouse rules.


Printed Name: __________________________________________________

Signature: ____________________________________________________

Date: ____________________

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Transportation Manager/Supervisor

Transportation Manager/Supervisor Statement of Accountability and Activity

As Manager/Supervisor of transportation I will be responsible for the following:

• To accept responsibility and conduct activities for the safety system as delegated or as outlined in this manual.

• To provide leadership for departmental training and monthly safety awareness meetings to establish safety activities. Such leadership activities will include Reviewing accident investigations conducted since the last meeting Obtaining updates on the status of injured employees Discussing employee job assignments, training, and certification programs Identifying monthly safety awareness topics Reviewing employee safety observations Accepting responsibility and assigning responsibility for compliance with DOT, EPA,

OSHA, FDA, and state-mandated programs.

• To assist in the continual enhancement of preferred safe methods of transportation.

• To provide appropriate monthly reports to the vice president of operations or director of operations.

• To conduct a monthly safety inspection as part of a committee composed of the safety director and the vice president of operations.

• To assist in the formation of an accident review committee.


Printed Name: _________________________________________________

Signature: ____________________________________________________

Date: ____________________

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General Associates

SSMC Employee’s Statement of Accountability and Activity

As an employee I will be responsible for the following:

• To help develop safe work practices.

• To follow all safe work practices.

• To give a written report of unsafe conditions or unsafe acts to management.

• To report all accidents, injuries or illnesses to my supervisor immediately.

• To take part in safety meetings by speaking out and giving my viewpoints.


Printed Name: _________________________________________________

Signature: ____________________________________________________

Date: ____________________

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Current Fiscal Year Insurance Pooling Requirements

Current Fiscal Year Sysco’s Casualty Insurance Pooling Requirements

There are requirements that operating companies must meet to be eligible to participate in the Pool. These requirements are “best practices” directly related to safety and risk management and must be adhered to by all operating companies, both in and outside the Sysco program. The Corporate Risk Management and Safety Departments at Sysco send every company in the program a memorandum at the beginning of each fiscal year that describes the eligibility requirements for the Pool. The most recent copy of this memorandum must be printed and inserted into this manual to ensure that the requirements are on file. No money will be obtained from the pool if these requirements are found to not be met in full. This includes passing the unannounced DOT compliance audit by SSMC Corporate. It is extremely important that all levels of management at each SSMC Operating company understand the pooling concept and ensure compliance with all the requirements to protect its liabilities.

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SUBJECT: ELIGIBILITY FOR FY 08 CASUALTY INSURANCE POOL

As of July 1, 2007, all SSMC companies participate in Sysco’s Casualty Insurance program. Under this program, Sysco is responsible for the first $2,000,000 of each general liability loss, the first $5,000,000 of each workers’ compensation loss and first $5,000,000 of each auto liability loss. Specifically, an operating company is directly responsible for the first $250,000 of each loss!

An important advantage that Sysco’s Insurance Plan provides is that it affords its members the opportunity to participate in the Sysco Pool. The Pool is designed to lessen the monetary impact of a large loss incurred at a company by spreading the risk among all other operating companies in the program. For the portion of a claim above $250,000, the pool will pay 75% and the operating company will contribute 25% - so, for a $1,000,000 loss, the operating company would be responsible for $437,500. The remaining $562,500 will be paid by the Pool.

The internal pooling threshold and the eligibility requirements to participate in the pool for FY 08 have changed. Amendments to the FY 07 requirements are highlighted below.

Pooling Point: The operating company is responsible for the first $250,000 of each casualty claim, the pool will pick up 75% of any loss dollars up to $1,000,000. After $1,000,000, the pool will pick up 100% of the cost until the insurance company becomes responsible.

Eligibility: To participate in the pool, the following requirements must be met:

* Any WC or liability claims involving a fall from a piece of warehouse equipment, rack, etc., will be excluded unless the operating company and employee were following the corporate Fall Protection Standard (updated by the safety department and distributed on June 1, 2006) which includes use of proper fall protection equipment (including safety harnesses).

* Any AL claim involving a marketing associate, or any other employee who travels on company business six or more times a year where the employee does not maintain minimum limits of $100,000 per person, $300,000 per accident and $50,000 in property damage on their personal auto insurance will be excluded.

* Any product liability claims for which valid certificates of insurance (COI) and hold harmless agreement (HHA) are not on file for the supplier will be excluded. * Any general liability claim involving a contract employee (lumper, driver, warehouse employee, etc) for which a valid COI and HHA are not on file for the contract employment agency will be excluded.

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* Any general liability claim involving an outside contractor for which a valid COI and HHA are not on file for the contractor will be excluded. (HHA was distributed to operating companies as an attachment to 9/6/2004 Legal Department Memorandum).

* Delivery vehicle drivers, MA's, employees driving company vehicles, and those driving their personal vehicles 6 times or more a year on company business must have completed an accredited defensive driving course with a completion certificate on file before beginning to work. Each must be retrained after any citation or accident. The defensive driving course must be completed every two years by all employees that meet the requirements above.

Using a warehouse to driver program will not exclude any company from the pool.

* A warehouse to driver program must be formal and documented. An example of such a program is posted on the BBP web site.

* Accidents involving vehicle delivery drivers where the following was not done will be excluded:

Pre-hire:

1) All DOT hiring requirements met,

2) No DUI/DWI within the last three years,

3) No multiple DUI/DWI,

4) No more than (2) two moving violations in the past three years and/or one DOT recordable,

5) Not hired or put on a vehicle until drug screen results are received

6) If driver candidate does not have at least one year previous driving experience, they must complete a corporate approved driver training program. Model supplied on the BBP web site.

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Post-hire:

1) All drivers complete SYSCO standard training program, (in-house documented) minimum of 3 weeks as part of their orientation.

2) Corrective action and appropriate discipline meted out on all improper driving practices and/or accidents,

3) Ride-withs and coaching conducted with all drivers annually by supervisors,

4) Complete DDC or Smith System defensive driving course

* All serious accidents and fatalities must be reported to the TPA and SYSCO Corporate immediately, no later than 24 hours after notice. The TPA will dispatch a field adjuster, accident Reconstructionist and transportation attorney to the scene of all serious accidents and fatalities.

* A 3rd party audit of your safety program must be completed every 18 months by an approved vendor.

* In case of a fatality or serious accident, reserves of $25,000 for bodily injury and $25,000 for claim expense must be established immediately.

* A full safety audit will be conducted at the discretion of the corporate safety department on workers’ compensation, auto liability or general liability claims involving fatalities or serious accidents.

* An unannounced DOT compliance audit will be completed at each operating company by SYSCO Corporate or its representatives every 18 months.

Serious is defined as, but not limited to the following conditions or injuries and should be reported to the TPA and Sysco Corporate immediately:

WC, AL & GL

* Death * Any occurrence under workers compensation that involves two or more employees

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* Spinal cord injury and/or loss of use of the upper or lower extremities

* Brain injury, i.e., damage with disorientation, behavior disorder, personality changes, seizures, motor deficit, aphasia, hemi-plebian, paralysis and/or Reflex Sympathetic Dystrophy (RSD)

* Major Burns

* Amputation any and all

* HIV/AIDS allegations and/or diagnosis

* Diseases such as asbestosis, cancer or leukemia are alleged to have been caused or aggravated by - - under the WC or liability policies

* Illnesses alleged due to environmental/toxic tort exposures

* Sensory loss - such as sight or hearing

* Multiple fractures

* Serious injury involving body organs

* Hospitalization

* Electrocution requiring hospitalization

* Places life in jeopardy

* Results in substantial loss of blood

* Produces unconsciousness

Auto Liability

* Accidents where one or more injured parties are life flighted from the scene

* Accident involving significant injuries where one or more parties are taken from the scene by ambulance

* Accidents involving significant property damage to vehicles or real property. Accidents with the potential for significant loss of business or business income

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* Accidents involving school buses, metro buses or mass transit vehicles with multiple passengers

* Accidents with fuel spills and hazardous materials clean up

* Additional serious claims & issues

* All lawsuits naming the insurance company as a defendant, except when names in a direct action state, such as Louisiana

* All lawsuits involving class actions, allegations of bad faith and violation of unfair claims practices act

* Any issues impacting state laws, settlements and/or setting legal precedents

Summary: this is extremely important!!!

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Preferred Work Method’sA Preferred Work Method is a specific approach used in performing a task or duty. Most tasks or duties have multiple PWM’s. These methods are designed to prevent injuries as employees perform their work assignments. They can designate “what to do” as in “drivers of vehicles must wear seat belts when vehicle is moving” or what “not to do” as in “do not stand on pallets or climb into racks to reach product”.

SSMC Safe identifies the “Top 10” PWM’s for six different departments within a SSMC facility. These “Top 10” PWM’s must be implemented in each location. Associates must be continually Coached and trained on these PWM’s and expected to be in full compliance. As the Safety Program for each Operating Company grows, it may be necessary to add more preferred work methods. New PWM’s will be the result of a through accident investigation process that identifies the “root cause” on an accident and is designed to remove that root cause. These PWM’s are an operation’s front-line defense to ensure against future accidents and injuries.

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Transportation1. Always pre-trip your truck before driving. Make a habit of checking throughout the day for damage, oil leaks, loose hoses, etc.2. Check your load prior to leaving facility. Return to dock for assistance if there is a problem with the load. 3. Operator must wear seat belt while vehicle is moving.4. Observe ground and use 3-point stance when exiting tractor. Do not jump out of tractor or trailer.5. Maintain control of load while going down ramp:

Enter ramp with hand truck first, never back down a ramp. Enter ramp square with opening. Do not overload hand truck.

Or

Maintain good safety practices while using lift gate:

Lower lift gate to appropriate level for safe entry/exit off of lift gate. Do not enter/exit off of lift gate through side chains. Hook safety latches on kick plate (if applicable) while raising and lowering lift gate, when riding on

the lift gate.6. Keep trailer clean and free of debris. Stack empty pallets flat on floor and secure with load locks if necessary.7. Use proper lifting techniques:

o Stand close to product to be lifted.o Approach straight on to avoid twisting.o Get a good grip, lift with legs, knees bent and keep back straight.o Move feet and step to dropping point. Do not twist body over stationary hips.o Avoid reaching out at arm’s length to lift product.o Avoid stepping on pallets.o Do not climb on machines or racks.o When lowering product, step to drop point, keep product close to body, and bend knees and release.

Do not reach over product. 8. Open doors with caution; stand in position to avoid product or ladder falling out of door; and secure doors with latch.9. Prior to going up or down steps, look for spills, ice, objects or other hazards on stairs. If stairs are unsafe for hand truck, walk product in.10. When going up steps, rest tires against step, pull back on hand truck and while keeping back straight, use legs to pull hand truck up step.

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Pedestrian1. Pedestrians must wear close-toed flat soled shoes in the warehouse.

2. All pedestrians must yield to power industrial equipment.

3. When walking through the warehouse pedestrians must stay alert and anticipate danger. Make sure the

operators see you.

4. Do not walk on or across empty pallets.

5. Stay to the right through all curtains and doors using extreme caution at all intersections.

6. Avoid highly congested work areas.

7. Do not stand in doorways or in blind spots.

8. Never walk under raised forks of a forklift.

9. Pick up debris on floor and take appropriate action to clean up all spills prior to passing.

10. Obey all safety rules posted in the warehouse.

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Warehouse1. Operator looks in direction of travel when moving equipment first inch.

2. Operator must step to side or stop equipment prior to dismounting. Equipment must remain in control

at all times. No jumping off of equipment.

3. When turning, reduce to safe speed and keep all body parts within the confines of the equipment.

4. When traveling through doors, curtains and trailer doors slow down, sound horn, and yield to all traffic.

5. When approaching foot traffic, sound horn, make eye contact, and acknowledge pedestrian before

passing.

6. Use proper lifting techniques:

Stand close to product to be lifted.

Approach straight on to avoid twisting.

Get a good grip, lift with legs, knees bent and keep back straight.

Move feet and step to dropping point. Do not twist body over stationary hips.

Avoid reaching out at arm’s length to lift product.

Avoid stepping on pallets.

Do not climb on machines or racks.

When lowering product, step to drop point, keep product close to body, and bend knees and

release. Do not reach over product.

7. Pre-trip equipment prior to usage.

8. Operators must travel base first, forks or product trailing except: When maneuvering short distances, or

operating from front facing sit-down forklifts.

9. Forklift operators have the right of way while stocking. All other equipment operators must stay 4 bays

away from stocking forklifts.

10. While traveling, watch for debris and spills on floor. Pick up debris and take appropriate action to clean

up all spills prior to passing.

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Garage/Maintenance1. Safety glasses must be worn when working in shop area.


a. Stand close to product to be lifted.

b. Approach straight on to avoid twisting.

c. Get a good grip, lift with legs, knees bent and keep back straight.

d. Move feet and step to dropping point. Do not twist body over stationary hips.

e. Avoid reaching out at arm’s length to lift product.

f. Avoid stepping on pallets.

g. Do not climb on machines or racks.

h. When lowering product, step to drop point, keep product close to body, and bend knees and


3. Safety gloves and goggles must be worn when using air tools.

4. Hearing protection must be worn when using air tools.

5. Keep eye wash station clean and surrounding area free from clutter and debris.

6. Always use a three-point stance when exiting or entering the truck. Do not jump from vehicle.

7. Wheel clocks must be used when jacking up vehicles and using jack stands.

8. Always wear your seatbelt anytime the vehicle is moving.

9. Use extreme caution when traveling or working in the parking lot.

10. Make sure that emergency fire exits are clear and accessible at all times.

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Processing1. Keep all travel paths and work station area floors free from product and debris.

2. Use extreme caution when entering or exiting processing room doorway. Always yield the right of

way.

3. When handling or dispensing liquid chemicals, you must always wear splash proof safety goggles and

rubber gloves, with dry chemicals you must wear safety glasses and rubber gloves.

4. Extreme caution and care must be taken when carrying or using all cutting equipment. (knifes,

peelers, slicers)

5. Store all cutting equipment properly when not in use.











7. Keep work areas clean to avoid any falls.

8. Ensure work area is clear before shrink wrapping pallets.

9. Do not touch and product without wearing latex or vinyl gloves.

10. Report any accident immediately to the supervisor.

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Storage & Re-Pack1. When stacking empty boxes the height should not exceed 6 feet.

2. Use extreme caution whenever using sharp tools, and store properly when not in use.











4. Make eye contact with persons operating power equipment near you. Do not assume they see you.

5. Always wear gloves and goggles whenever cleaning or sanitizing with chemicals.

6. Ensure work area is clear before shrink wrapping pallets.

7. Never climb on racks or use forklifts to raise you up to remove product from coolers.

8. Keep work areas clean to avoid falls.

9. Use extreme caution when traveling through curtains and doorways.

10. Do not walk across empty pallets.

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Hazard Assessment/Training/Monitoring of PWM’s Compliance

A hazard assessment is necessary for every SSMC Operating Company in order to gain an understanding of where are largest safety risks are located. This initial hazard assessment will be time consuming, but is the backbone of every SSMC Safety Program. To assist with the constant training necessary, PWM’s have proven to be the best tool.

Because these Preferred Work Methods are the front line defense of every Operating Company, they must be trained to all employees, tracked for usefulness, and documented for auditing purposes. Each department manager will be required to hold their employees accountable for learning the appropriate preferred work methods. As stated earlier in the Statements of Accountability.

Examples of training can be seen in the next section on Pre-Shift Safety/Stretching Meetings. The monitoring of the Preferred Work Methods is accomplished through the Coach Card Tracking Program.

These guidelines combine with other elements outlined in this manual to comprise a comprehensive plan for the control of accidents, injuries, illnesses and losses in the workplace. Use them to develop your own safety system.

Hazard Assessment

A supervisor is paid to supervise. So why should a safety director or supervisor want to bother with hazard assessment, which involves the analysis and classification of workplace losses and hazardous conditions? There are several important reasons:

• Your past predicts your future. Until something is done, the same types of injuries/illnesses will be repeated.

• Assessment gives you A full account of accidents occurring under your supervision A clear picture of where your management is needed the most

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• Workers who are most often injured are identified. You can then give them the training needed to stop or reduce their accidents.

• Assessment and training lead to higher productivity and make your job easier in the long run. As you find the problems and train your employees, you’ll have fewer losses. You will have a group of healthy employees who come to work every day. Employee turnover will be reduced. As the program takes hold, the need to retrain employees will be reduced.

This section covers the following elements of hazard assessment:

Review of Past Loss HistoryEmployee Hazardous Condition ReportsSelf-Inspections

Review of Past Loss History

Begin your hazard assessment by reviewing your past loss history. The reason for doing this is to find out where most of your accidents/illnesses are happening and who is being injured.

Sorting Prior Claims

Break down your losses by sorting them three times:• First sort. Separate losses into four or more categories.

Warehouse shipping Warehouse receiving

(If your operation has three shifts, sort into 1st, 2nd, and 3rd.) Transportation All others

(Sales, administrative, supply and equipment, print shop, etc.)

• Second sort. Separate the first-sort categories by department.

Freezer shipping

Freezer receiving Dry shipping Dry receiving Cooler shipping Cooler receiving Delivery service associates

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(Sort by supervisory group or sort by job type: shuttle, city, country.)

• Third sort. Separate the second-sort categories by employee job title. Selector Loader Forklift operator Hy-rise operator Etc.

Be sure to note the worker’s compensation cost for each claim, so dollar values can be considered.

Searching for Common DenominatorsLook through your third-sort categories for the most frequent common denominators, losses that the job categories have in common, such as the following:

• A high frequency of accidents with similar products

• Warehouse equipment collisions

• Locations of slip-and-fall accidents

• Accidents on a particular day of the week

• Accidents with employees on overtime

(Repeat accidents/illness to the same person)

Once you’ve found the common denominators you can tell where safety training is most needed, and you can concentrate on the top priorities:

• Injuries/illnesses that happen most often• Injuries/illnesses those are most expensive

Making a Summary

Now that you have a clear picture of your past losses, you can see where the hazards are in your workplace. You can identify doors, aisles, and dock areas that need attention. And you can easily tell which workers need what kinds of training or retraining.

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Make a summary of causes and corrective actions. Write down the causes of each kind of loss and assign corrective actions to them. And don’t forget to note who’s responsible for each action item.

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Employee Hazardous Condition Reports

A hazardous condition report filed by an employee is one of the best tools you have for identifying safety problems. When employees are interested enough to fill out these reports, their concerns shouldn’t be ignored. Over the past several years American industry has found that when employees become involved in decisions affecting their own jobs the quality of work improves, efficiency improves, attitudes improve, and relationships with management improve.

Procedure for Filing a Report

The procedure for filing a hazardous condition report should be made easy for the employee:

• The employee picks up a report form. The easiest system of form distribution is a box on the wall that always contains blank forms. This way, the employee doesn’t have to go to an office or try to find someone to get a form.

• The employee fills out the form. The employee may want to discuss the hazard with his supervisor while writing the report.

• The employee gives the form to his supervisor. The supervisor should accept the form with a positive attitude, expressing an interest in looking into the unsafe condition and assuring the employee that he will get a response to his report.

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SSMCHAZARDOUS CONDITION REPORT

Employee reporting hazard: Date:

Location of hazard (Be specificwrite aisle, door, slot numbers, etc.):

Description of hazard:

Supervisor’s investigation and comments:

Supervisor’s actions taken:

PLEASE REVIEW AND EXPEDITE PROMPTLYPlease review this report and attach your comments, add your signature and the datebelow, and forward it for further review.1. Employee reporting condition: _______________________________________________2. Supervisor: _______________________________________________3. Director of Warehousing: _______________________________________________4. Safety Director: _______________________________________________5. Vice President of Operations: _______________________________________________6. Senior Vice President _______________________________________________

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The New Customer Delivery Report

The report contains customer information, directions to the customer’s location, delivery conditions, and special instructions. Once the form is processed, a copy is attached to the original invoice, which the delivery service associate receives for his first delivery to that customer.

New Customer Delivery Report

SSMC

NEW CUSTOMER DELIVERY REPORT

DM / MA: ________________________________________ # ________ Date: ______________

Customer: ______________________________________________________________________

Address: _______________________________________________________________________

_______________________________________________________________________Phone: (_____)__________________________ Contact Person: _________________________

Preferred Time of Delivery: _____:____ am pm

Directions to Account: ________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

Map:

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DELIVERY CONDITIONS: (Check all that apply)

1. Parking Lot: Black Top Concrete Gravel Dirt Caution: ______________________________________________

2. Entrance / Exit: Back Door Front Door Gate Caution: ______________________________________________

3. Stairway(s): Inside Outside Downstairs Upstairs Caution: _______________________________________________

4. Customer Racking / Storage Area: Stable Unstable Caution: _______________________________________________

5. Other: _____________________________________________________

Briefly Describe any potential condition(s) a delivery service associate may encounter at this customer’s location:________________________________________________________________________________

________________________________________________________________________________

If delivery area conditions warrant, can an alternative route or area be used: YES NO

Special instructions for the delivery service associate: (special delivery specifications, customer handicap etc.) _________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Customer’s business hours on day(s) of delivery: ____:____ am pm to: ____:____ am pm

Are there any parking restrictions that you are aware of: YES NOIf yes, what? _________________________________________________________________________

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PLEASE REVIEW AND EXPEDITE PROMPTLY

Please review this report and attach your comments, add your signature and the date below, and forward it for further review.

SIGNATURE DATE

1. Supervisor: __________________________________________ _________2. Director of Warehousing: __________________________________________ _________3. Safety Director: __________________________________________ _________4. Vice President of Operations: __________________________________________ _________5. Senior Vice President __________________________________________ _________

Please return completed original to the Transportation Director.

Ensure copy is attached to initial invoice for delivery service associate reference.

The safety director should see that the use of the form is explained to all of the marketing associates and the district manager.

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The Delivery Stop Condition Report

When a delivery service associate encounters a hazardous condition, he should complete a Delivery Stop Condition Report.

Just as the Hazardous Conditions Report is made easily available to other employees, the Delivery Stop Condition Report should be easy for delivery service associates to obtain. The delivery service associate should carry a few of these reports in his truck so he can note the time of delivery, conditions, and description of the hazard as he comes upon it.

An alternative to the delivery service associate’s carrying the form in the cab of the truck is to leave a voice mail message for the safety director. The safety director would then complete and follow up on the stop condition report.

Keep a log of all stop condition reports and discuss them in planning committee meetings to assure proper feedback.

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SSMC- DELIVERY SERVICE ASSOCIATEDELIVERY STOP CONDITION REPORT

Employee completing report: _________________________________ Date: ____________

Route Code: _____________ Time of Delivery: ____:____ am pm

Customer Name: ______________________________________________ # __________

Address: __________________________________ Phone: (_____)________________

____________________________________________

DM / MA: ____________________________________________________________

The following conditions have been noted at this customer's premises:

1) Parking Lot: Acceptable Unacceptable N/A

Explain: _________________________________________________________

2) Entrance / Exit: Acceptable Unacceptable N/A

Explain: _________________________________________________________

3) Stairway(s): Acceptable Unacceptable N/A

Explain: _________________________________________________________

4) Customer Racking / Storage Area: Acceptable Unacceptable N/A

Explain: _________________________________________________________

5) Housekeeping: Acceptable Unacceptable

Explain: _________________________________________________________

6) Other __________________ Acceptable Unacceptable N/A

Explain: _________________________________________________________

Brief Description of condition: ______________________________________________________________________________________________________________________________________________________________________________

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Sent to: DM, MA, and / or Delivery Supervisor for discussion with customer.

Recommendations from DM / MA on customer relations and action that can be taken:

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

Discussion with customer completed? YES NO

By whom? ________________________ Date: __________

Action Taken:

Customer will correct condition(s)

SSMC will assist customer to correct the condition(s)

Alternative delivery route made

Delivery to customer suspended or discontinued

No action taken Reason: _______________________________________

PLEASE REVIEW AND EXPEDITE PROMPTLY

Please review this report and attach your comments, add your signature and the date below,

and forward it for further review.

SIGNATURE DATE

1. Employee reporting condition: ____________

2. Delivery Supervisor: ____________

3. Transportation Director: ____________

4. Vice President of Operations: ____________

5. Safety Director: ____________

Please return completed original to the Safety Director.

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The Response Process

After receiving the form, the supervisor should do the following:

• Conduct an investigation of the hazardous condition and fill out the remaining sections of the form. If more room is needed for comments, write them on a separate page and attach it to the form.

• Correct the condition and note the actions taken on the form, attaching another page if needed.

• Sign and date the form and forward it and any attachments to the next person on the form’s review list.

• Provide a completed copy to the employee who is filing the report.

Persons at each level of the review process should briefly put their thoughts into writing, attach their comments, and promptly forward the papers.

The employee reporting the condition is the last person to sign the form, showing that he has had an opportunity to read the comments from the review process. He then gives the papers to the supervisor.

The forms should be filed in the safety office.

The purpose of the review process is to involve people at all operational levels and collect any ideas they may have for further improvement. A well-functioning safety program is built around teamwork. Everyone has a role in identifying hazards and suggesting solutions. No one is out there aloneand no one is to blame.

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Self-Inspections

Unsafe acts and conditions eventually result in injuries/illnessessome of them serious. And when you review your past loss history, you’ll probably find that the great majority of your injuries/illnesses were caused by unsafe acts and poor work practices.

Self-inspections allow you to identify these unsafe acts and practices before an injury/illness takes place, and they produce other effects:

• Self-inspections show that management is committed to the safety program.

• Self-inspections maintain standards by ensuring that everyone follows the preferred safe work practices.

• Self-inspections show you where your practices and procedures need improvement.

• Self-inspections measure the effectiveness of safety education by showing improvement (or the lack of improvement) in work behavior.

• Self-inspections reveal weaknesses in the safety program.

• Self-inspections motivate employees by showing the results of their safety efforts in a clear, measurable form.

• Self-inspections allow supervisors to see their progress.

• Self-inspections increase safety awareness.

This last effect is very important because unsafe actions result from a lack of safety awareness. We can’t write procedures to cover all the actions of employees, so we have to increase safety awareness to reduce unsafe acts.

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Policy and Procedure

Self-inspections must have the understanding and backing of top management. This means more than just saying, “OK, let’s do inspections.” It means

• Management’s overview of the development of inspection procedures

• Management’s approval of the time and resources to conduct the self-inspections

• Management understands that the inspections will uncover conditions that need to be correctedand that many of those corrections will cost money

Without top management’s willingness to invest money in the necessary corrections, self-inspections are an obvious sham.

To show management’s support of the inspection program, and to establish clear responsibilities, a statement of policy and procedures should be created and posted for all employees.

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SSMCProcedures for Safety Inspections

Each SSMC employee is responsible for reporting any safety or health hazard immediately. In addition, management has established the following self-inspection procedures for auditing hazards and unsafe work practices. Legitimate safety and health issues will be corrected on a prioritized basis.

Responsibility for self-inspections

The director of operations has ultimate responsibility for the self-inspection program.

Self-inspection coordinator and facilitator

The safety director will serve as self-inspection coordinator and facilitator.

Self-inspection team members

Self-inspection teams will be composed of the following members:

____________________________________________________________________________________________________________________________________________________________________________________________________________

Budget allocation

Initially we will budget two hours per inspection team member every other week, until we see if the time is adequate for an in-depth tour of the facility.

Timing of inspections

Inspections will be unannounced, at least once every two weeks.

Inspection tours

We will conduct two types of tours, on an alternating basis:

1. In-depth specific inspection tours of exposures. Inspection items for this type of tour will be determined in the manager/supervisor safety activities meetings.

2. Plant wide inspection tours.

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Inspection reports

Inspection teams will submit written reports of their findings to the department managers.

Responsibility for the resolution of safety items

• The supervisor is responsible for resolving safety problems on his shift that will cost no more than $________ to correct.

• If the cost to resolve a safety item exceeds $_______ the supervisor will submit a request, in writing, to his department manager. The responsibility then becomes that of the department manager.

• For capital expenditure items costing over $___________, the department manager will bring the item to the manager/supervisor safety activities meeting for discussion and resolution.

Time for completion of safety items

If a safety item can be readily handled, or if an emergency exists, the supervisor is responsible for resolving the item immediately.

Any item that is unresolved for more than two weeks is to be reviewed at the next manager/super safety activities meeting.

Program review

The director of operations will watch the progress of the self-inspection program. He will formally review the progress at three months and at six months and will revise the program accordingly.

Your comments will be welcomed.

Self-Inspection Checklists

Before beginning a self-inspection program you should develop checklists for the specific exposures in your facility. Conduct a tour of each work area and list the following in separate categories:

• Possible unsafe conditions

• Possible unsafe work practices

Untrained safety inspectors often focus on hazards in the facility without noticing unsafe work practices. Remember that unsafe work practices are the major causes of injuries, and they deserve major attention in any self-inspection program. By developing an inspection format specifically for your facility, you will assure that unsafe work practices are included.

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Training ~ Pre-Shift Safety/Stretching MeetingOne of the leading causes of worker injury is pulled muscles. A pre-shift safety and stretching meeting is a great chance to discuss current safety issues that may have happened recently within your facility; and stretch out before beginning work. These meetings are also a great opportunity for department mangers to stress the importance of safety in the workplace, and to obtain vital input from their employees. A simple document such as the one below will works great to record the daily meetings, and to verify that the stretching has taken place. This is an important part of every shift, every department, everyday!

Pre-Shift Safety/Stretching MeetingMust be Preformed each & Every Day before Beginning Shift

Date: _______________ Supervisor: _______________

Topics Discussed: _______________________________________________________________________

____________________________________________________________________

PWM’s Involved_________________________________________________________________________

____________________________________________________________________

Employees Feedback____________________________________________________________________

______________________________________________________________________________________

* Please have everyone’s signature in your department sign the attached sign off sheet. This will verify that the employee has attended the meeting and that the stretching has been completed.

Employee Sign off Sheet

Pre-Shift Safety/Stretching Meeting

Depart. ______________________ Date: __________________

Name: _______________________ Signature: _____________________

Name: _______________________ Signature: _____________________

Name: _______________________ Signature: _____________________

Name: _______________________ Signature: _____________________

Name: _______________________ Signature: _____________________

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Monitoring ~ Coach Card Program/Tracking

Coach Cards are an important element to the SSMCSafe process. Coach cards allow supervisors to communicate to the employees utilizing a tool that can generate important statistical information on the safety status of the center. This communication or Coaching allows the supervisor and employee to exchange information that relates to their preferred work methods. This can be a reinforcing exchange or a corrective exchange. The Coach cards are not a disciplinary tool or tracking device for discipline. In fact, it’s generally recommended that the Coach card not even be seen by the employee so they do not feel they are being written up. The important part of this process is the communication between the supervisor and the associate. By having this communication the associates feel their supervisors recognize the importance of the preferred work methods and will find leadership in their supervisors. The documentation of the communication is something the supervisor can do away from the associate for follow up and trending.

The information, SSMC tracks, allows us to formulate new training methods or resources and also reinforces a good safety training process. In other words, what elements of the SSMCSafe process are or are not working.

For example: John Doe is seen, by a supervisor, operating equipment with his feet hanging over the side. The supervisor Coaches the employee not to operate the equipment in this manner as well as the reasons why. The employee will be monitored for improved operating techniques over the next several weeks and may again be Coached to remove the bad habit. It may take the supervisor several Coaching sessions to break a habit that is created over a long period of time. Once the un-safe habit is broken the supervisor should Coach with a positive reinforcement to recognize the change. This process will break the un-safe act and prevent the employee or others from being injured. The Coach card will be tracked by the Preferred Work Method. This information is then used to show where the center is having problems with training. If a center notices a high amount of un-safe equipment operating Coach cards they will now know they will need to train ALL the employees in operating equipment again or change the current training process.

Over time, a center should notice an increase in positive Coach cards for safe behavior and a decrease in corrective Coaching. The center will also notice a decrease in employee injuries due to un-safe acts. This will create a safe and efficient working environment that everyone can be proud of.

The other benefit, often not recognized in the Coaching process, is the ability to monitor the success of your training and ultimately the success of each individual supervisor. Over time each supervisor should see significant improvement in safety compliance. If not, you will be able to recognize their weaknesses through the tracking of the communications they have on the Coach card tracking worksheet. You will find that many supervisors may not be successful in Coaching and will have to be re-educated or removed to improve your safety process.

Also a manager will now have the ability to monitor supervisor discussions with their associates. If a manager takes a look at the Coach card book(s) a supervisor completes they can go out and follow-up with the associates that have had corrective discussions to re-emphasize the importance of following the preferred work methods.

In time a supervisor will learn to utilize the Coaching tracking process to find issues in their area and will be able to follow up with discussions and provide positive reinforcements to our associates. On the next page is an example of a spreadsheet to utilize for tracking purposes.

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COACH CARD Tracking Spreadsheet

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PREFERRED WORK METHOD

FY: OCT NOV DEC TOTALType of COACHing + - + - + - +SELECTOR/RECEIVER Looking in direction of travel - 1st inch rule Honking horns through doorway

Etc. TOTAL

COACH CARD TRACKING SPREADSHEET


FY: OCT NOV DEC TOTALType of COACHing + - + - + - +DRIVER Proper use of 2-wheeler up - down ramp Proper use of 2-wheeler -customer sight

Etc. TOTAL

COACH CARD TRACKING SPREADSHEET


FY: OCT NOV DEC TOTALType of COACHing + - + - + - +OFFICE Lifting properly Extension cords placed properly

Etc. TOTAL

Accident Policy/Procedure/Reporting

If an accident involves a fatality or potentially serious claim, call the following immediately :

You’re Safety Regional Manager and the SSMC Corporate safety office.

Regional Safety Manager: ___________________ Phone Number: ___________________

Corporate Safety Office: 1-281-584-4198 Gallagher Bassett: 1-800-647-8806

You’re TPA: _________________________ Phone Number: ___________________

XXXXXXXXX - SSMCBrian Norwood - SYSCO (office) 1-407-858-0031(office) 1-281-584-4198 (cell) 1-407-399-6858

(cell) 1-281-788-5757

The activities to follow after an accident has been encountered are extremely important! The documents given; have been generated from the guidelines stated in the Current Year Insurance Pooling Requirements. As stated earlier in the manual, all requirements must be met to be eligible for any coverage on a claim. It is vital that every employee be trained on procedures to follow after an accident. Training on accident reporting must be given and documented twice per calendar year by the safety manager.

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Transportation/Vehicle Accident Policy

SSMCSafe

ACCIDENT POLICY

Below are the rules governing disciplinary action that will be taken by SSMC with regard to vehicular and physical accidents. The disciplinary rules are determined by the frequency and/or seriousness of the chargeable accident.

Chargeable accidents will be divided into (3) categories; (minor, major and terminal) being separated but not limited to the dollar value and/or the seriousness of the incident.

Total expenses are all damages and/or physical injuries to SSMC property or employees, truck units, other party’s vehicle or property, and additional expense directly connected to the vehicle accident or injury. Medical and death expenses directly or indirectly connected with the vehicular accident or injury are contributing factors to the total expense.

Disciplinary action is determined on a twelve (12) month history from the actual date on the last chargeable accident in the driver’s file.

MINOR ACCIDENT involves:

Vehicle damage and/or injuries Property damages of $1500.00 Accidents where SSMC is held responsible for damages and/or injuries Only minor injury, if any, to our driver or other persons

MAJOR ACCIDENT involves:

One or more vehicles, and/or injuries Property damage exceeding $1500.00 Accidents where SSMC is held responsible for damages And/or serious personal injury Careless driving or other major negligence

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TERMINAL ACCIDENT involves:

Major permanent disability or death to any person, Driving under the influence of alcohol or drugs or, Reckless driving or other gross negligence or Property damage exceeding $20,000.00 Failure to report any and all accidents no matter how slight

DEFINITIONS

Chargeable Accident – A chargeable accident is an accident that is caused by an employee who did not do everything in their control to prevent the accident. A chargeable accident can happen within the distribution facility, on the grounds of the facility or off company premises during the course of business. A vehicle, pallet jack, or other tools may or may not be involved. The Accident Review Committee will determine whether or not an employee has done everything reasonable to prevent an accident.

Non-Chargeable Accident – A non-chargeable accident is an accident that involves an employee in which the Accident Review Committee determines that the employee did everything reasonable to prevent the accident.

*RECOMMENDED DISCIPLINARY ACTION*

Written 3-Day 5-Day

Warning Suspension Suspension Termination

MINOR 1st 2nd 3rd 4th

MAJOR 1st 2nd 3rd

TERMINAL 1st

A combination of two minor and a major is termination.

A combination of one minor and one major is 1–Week Suspension

In many instances, discipline cannot be determined until the repairs and other cost are totaled and forwarded to SSMC. All accidents are reviewed by the SSMC Accident Review Committee to determine whether Chargeable or non-Chargeable only. It is the sole discretion of Management and not the Accident Review Committee to determine disciplinary action. Retraining may be required at the sole discretion of Management at any time after an accident has occurred. Once the accident is determined to have been chargeable, the driver involved will have the opportunity to appear at the

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Accident Review Committee if he/she so chooses. A notice with time and date of committee meetings will be posted on the bulletin board in the driver’s room. The Accident Review Committee may have a non-scheduled meeting to cover the circumstances of the more serious accidents.

The company reserves the right to send the employee for drug and/or alcohol screens after an accident has occurred.

Any driver having a history of chargeable accidents will be subject to termination. The company will not tolerate unsafe driving.

This policy does not apply to drivers during their 90 day probationary period. Any accident during the 90 day probationary period could result in termination.

ACCIDENT REVIEW COMMITTEE/MEMBERSHIP AND RESPONSIBILITY

The Accident Review Committee will be made up of the Safety Manager and members of the safety review committee. In the event that a member cannot attend a Safety Review meeting then a management designated alternate will be asked to attend in their absence.

FOLLOW THESE PROCEDURES IF INVOLVED IN AN ACCIDENT You must call a transportation supervisor and/ or warehouse supervisor and report your accident immediately after the accident occurs. All drivers are required to fill out a completed SSMC ACCIDENT REPORT PACKET at the scene of the accident. This report must be turned in before departing SSMC or in the case of resident drivers, at the end of the business day. The report must be sent back with the day’s invoices. ALL accident reports must be filled out accurately and completely. Any intentional false information of the accident report form will be cause for termination. Review your completed accident report with a transportation, warehouse or safety supervisor as is applicable. A driver may not be permitted to return to work until the accident report is turned into SSMC. After the accident report is completed and signed by the driver involved, it is retained by the Safety Manager. The Accident Report Packet is shown in the back of this manual. Always make sure your Supervisor has signed the accident report.

POST ACCIDENT PROCEDURES

VEHICLE ACCIDENTS

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Assess situation and proceed in a manner as to assure continued safety of the accident site.

Secure the area and or set necessary safety reflectors or flags to warn approaching motorists.

See to the safety and treatment of fellow employees and any other drivers or passengers involved.

Then see to the protection of company property.

Telephone SSMC and report to a Transportation Supervisor immediately your location, extent of damage and estimated delay. If no phone is available, ask another motorist to notify authorities and SSMC of the accident location and immediate needs. Telephone Police or Highway Patrol and report the location of the accident.

Start filling out the “Accident Report Packet” assigned to you. Filling out your accident reports at the scene of the accident is crucial, as the information will be more accurate. You will be required to turn in your written report to the Transportation or Safety department upon your return without fail. All accident reports must be given directly to a Transportation supervisor. Putting accident reports in a mailbox will not be tolerated. The report must include the following details:

Date and hour of the accident. How it occurred. Name, address, and telephone numbers of all persons involved in the accident (drivers and passengers). Also get name, address, and telephone numbers of all witnesses.

If another vehicle is involved, get the year, make, model and vehicle license number, other driver’s insurance company, address and phone number.

Take pictures of all four sides of all vehicles involved. Use the whole roll of film.

If traffic tickets were issued, name of drivers receiving citations and violation codes cited. Also, get the attending law enforcement officer’s name.

If bodily injury was incurred, names of injured, apparent extent of injuries, whether treated by EMS, doctors, or hospital.

When authorities have dismissed you or you have concluded your ACCIDENT REPORT PACKET, continue on your route only after your Supervisor has given you authorization.

PROPERTY DAMAGE

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Accidents involving property damage caused by your truck or powered industrial truck, such as backing into a building or fence, or otherwise damaging or mutilating property owned by an individual or establishment, must be reported at time of accident. Start filling out your ACCIDENT REPORT PACKET.

Include on your report the address or location of damage

Owner’s name, address, and telephone number

Apparent extent of damage

Date and hour of accident

Take pictures

Reporting of accidents, ALL ACCIDENTS, however slight, regardless of whether traffic, physical

injury or property damages MUST be reported at the time of accident. Be complete and detailed.

Drivers will be required to review the PTD course module that applies to the accident after an accident.

This policy is not retroactive for any disciplinary reasons. FAILURE TO REPORT AND FILE A TIMELY ACCIDENT REPORT AS OUTLINED IN THIS POLICY IS CAUSE FOR IMMEDIATE TERMINATION. Policy revision effective August 16, 2007.

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Filing Accident/Injury/Illness Reports

Managers and supervisors are responsible for collecting information about accidents and filing reports promptly.

Employees are never to fill out their own accident reportsthis is to be done only by the manager or supervisor.

Managers’ and Supervisors’ Responsibilities

If an accident occurs, department managers or supervisors should do the following:

• See to the safety and treatment of the employee. Then see to the protection of company property.

• Write down all the facts about the accident/injury/illness or loss immediately.

• Fill out an accident/injury/illness report. Fax or Email the appropriate forms and a completed accident report to your third-party administrator (TPA) by the close of the following business day. Risk facts and Riskmaster should be used if available.

Filing a Claim

All claims should be reported without delay, and all medical bills should be forwarded to your TPA.

It is important to provide detailed and accurate information. If you do not have all of the information necessary, report the claim anyway and provide more information at a later time.

Accident/injury/illness and Investigation forms are used to create a report and investigate and should fit the policies and procedures of your operating company. For example, your specific procedures may require the signatures of the supervisor, safety manager, and vice president of operations

Workers’ Compensation Employee Accident/Injury/Illness Reports and Employee Vehicle Accident/Injury/Illness Reports are filled out by the employee. It is important to have the employee personally complete these reports, so that you have a statement in his own words soon after the accident. If an employee hurts his shoulder playing baseball sometime after falling, straining his back, and filing a workers’ compensation report it will be difficult for him to claim that his baseball injury/illness is related to his previously reported work injury/illness.

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Documenting vehicle accidents is important for transportation and sales employees because it provides written testimony on or close to the date of the accident, should litigation occur.

Warehouse Supervisor’s Accident/Injury/Illness Investigation and Transportation Supervisor’s Accident/Injury/Illness Investigation Reports are filled out by supervisors. Notice that there may be several items on these forms that are also on the forms filled out by employees. Supervisors should not copy information from employee reports, but should seek to verify the root cause (s) of the accident or injury.

See that reports are filled out immediately after an accident/injury/illness, while the memories of the victim and witnesses are still fresh. Delaying this important task can result in inaccurate accident/injury/illness reporting.

OSHA Recordkeeping

OSHA requires us to keep records about the following:• Occupational deaths

• Occupational illnesses

• Occupational injuries involving

Loss of consciousness

Limited work or motion

Transfer to another job

Medical treatment other than first aid

These records are kept on two forms: OSHA 300 and 301. All operating companies must follow these federal guidelines and any other guidelines required by their specific states. Please refer to www.OSHA.gov for more information.

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http://www.OSHA.gov/

Location and Retention of Records

OSHA requires each SSMC location to keep its own records of occupational injuries and illnesses.

Location of Records

OSHA 200 and 300 logs and all supplementary records must be kept at the SSMC location where operations are performed, with one exception:

The log portion of OSHA 300 may be prepared and maintained at an alternate location. For details and restrictions to this exception, see the USDL publication OMB 1220-0029, “A Brief Guide to Recordkeeping Requirements for Occupational Injuries and Illnesses.”

Retention of Records

The log and summary portions of OSHA 200 and 300 and the supplementary records must be retained at each SSMC location for five years.

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How to Conduct a Complete Accident/Illness Investigation

The primary reason for conducting an accident/illness investigation is to find the true facts, so you can keep the same kind of accident from happening again.

Assigning blame and finding excuses are not reasons for an accident/injury/illness investigation.

Who Investigates Accidents/Injuries/Illnesses?

The investigator of most accidents/injuries/illnesses is the shift supervisor. This is the person who

• knows the job procedures• understands the hazards• knows the environmental conditions• knows the unusual conditions of a job• is familiar with the employee’s job experience• knows the employee’s strengths and weaknesses• leads the effort to prevent future accidents/injuries/illnesses

The investigation of major accidents/injuries/illnesses or incidents requires a team effort.

Here are the three basic kinds of accidents and the people responsible for investigating them:

1. Injuries that may require medical treatment but do not cause lost time from work.

These accidents are investigated by the shift supervisor.

2. Serious injuries and all occupational illnesses, or major equipment damage.

These are investigated by an accident/injury/illness investigation team that includes the shift supervisor and one or more of the following people:

Senior management Safety officer Legal representative

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3. Near-miss incidents that do not cause injuries and may or may not result in damage to the building, equipment, or product.

These incidents are reviewed by the safety committee.

When to Begin the Investigation

Begin the investigation as soon as the injured/ill person is receiving first aid and is comfortable.

The investigation should include • making a record of the accident site and conditions• interviewing witnesses• interviewing other employees• interviewing the injured/ill person

Making a Record of the Accident/Injury/Illness Site and Conditions

An instant camera or video recorder should be available to record details of the accident/injury/illness scene

• Immediately after the accident/injury/illness (after the employee is treated) and• Before work begins again

These photographs could become important evidence in a workers’ compensation claim or in a lawsuit, so photos should be taken from several different angles to show what happened.

After taking photos a transportation supervisor should make notes about the weather conditions, if this is important.

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Getting at the Root Causes of Accidents/Injuries/Illnesses

One of the most common weaknesses in accident/injury/illness investigation is failure to identify the basic causes of accidents/injuries/illnesses. Here are some of the reasons this can happen:

• Poorly trained investigators gloss over information or do not dig deep enough.

• It’s a normal human tendency to look for the one thing that “caused” the accident/injury/illness. When some investigators can point to one act that the employee did to cause the accident/injury/illness, the investigation is over as far as they are concerned.

For example, an employee strains his back while selecting an item. The cause may be listed as employee carelessness. But the root cause may have been a heavy item stored in a hard-to-reach slot location, or a slippery floor due to poor housekeeping.

• Some supervisors tend to overlook a condition or practice when it was considered to be “normal” before the injury/illness.

The best investigators are willing to recognize any condition that in any way had a part in the injury/illness. They are ready to question and challenge what was acceptable in the past.

• Some investigators are unwilling to admit that conditions under their supervision have contributed to an injury/illness. To them, it’s just like admitting blame or fault.

The point of the investigation is not to find fault but to identify the root cause of the injury/illness and fix it.

• Many investigators will not identify a particular condition because they don’t know a practical solution for the problem.

These investigators make the mistake of thinking something should not be identified as a cause unless it can be corrected. But it’s best to discuss the problem with employees and managers before injuries/illnesses happen.

For example, an employee slips and is injured because of water on a produce room floor. The investigator thinks, “These produce room floors are always wetwe can’t do anything about it.”

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But something can be done about it: Squeegee the floor regularly until floor drains and catch basins can be installed to remove the water that drips from iced produce. “Install floor drains? But that’s expensive!” Yes, but accidents/injuries/illnesses can be expensive too.

Here are some of the ways accidents/injuries/illnesses can cost you:- Medical expenses Higher insurance premiums Loss of employee’s productive time Lost time cleaning up after the accident/injury/illness- Lost time filling out and filing accident/injury/illness reports Lost time investigating the accident/injury/illness Lost time reviewing the results of the investigation Possible loss of product Possible loss of equipment Possible damage to building Possible legal action Possible fines by federal and state agencies Pain and suffering of the employee

Important Points about Accident Investigation

When investigating an accident, be sure to do the following things:

• First, get aid for the injured/ill employee.

• In the case of a serious injury/illness or accident, immediately rope off the area to keep anything from being moved or changed. Then get the advice of your company’s safety officer before continuing the investigation.

• Interview the injured/ill employee as soon as it’s appropriate and get his or her statement about what happened.

• Interview witnesses separately and privatelynot in a group. Make notes of what they say, or record them on tape.

• Get additional input from safety specialists and occupational health people, especially about the steps necessary to keep the same kind of accident/illness from happening again.

• Be open-minded. Accidents/illnesses are hardly ever caused by one simple thing. More often, several things are involved.

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• Talk over your findings with your manager and the safety manager.

• Prepare your report within 48 hours after the injury/illness. If you need more time, talk to your manager.

Interviewing Witnesses

Getting accurate statements from the injured/ill employee and witnesses may be the most important thing you can do to find the cause of a serious injury/illness. Keep the following points in mind when interviewing witnesses:

• Remember that witnesses remember things more accurately right after the accident/injury/illness.

• Interview witnesses separately and privately. If they are allowed to talk it over and compare stories, their statements may change.

• Don’t pre-judge anything until all the information is in.

What you think happened may not agree with what the injured person or witnesses say. It’s important to have doubts about what you think and about what witnesses say until you’re sure of the facts.

How to Conduct an Interview

Follow these guidelines to conduct an effective interview:

• Choose a quiet, private area for the interview and talk to one person at a time.

• Try to put the person at ease at the start of the interview. Mention your concern about the injury and say that you’re trying to find out what happened to keep it from taking place again.

• Tell the witness that the aim of the investigation is to find the causes of the accident/injury/illness, not to blame anyone.

• Ask for suggestions to keep the accident from happening again.

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• Don’t interrupt or frown at the witness.

• Take notes, or record the statement on tape.

• Go over the statement with the witness at the end of the interview to be sure you have it right.

What to Ask and What to Report

The thoroughness of your investigation shows up in the reports that you fill out. If you’ve done a good job of investigating, and if you have a good understanding of the root causes of the accident/illness, your reports should be detailed and accurate.

Here are two examples: investigations of a selector accident and a driver accident. Warehouse and transportation supervisors should read both examples.

Selector Injury/Illness. Imagine a workers’ compensation accident form that’s completed like this:

Describe what employee was doing including: Equipment, Tools, Materials used, Etc.

Injured while selecting.

This doesn’t tell us much. Did the supervisor actually investigate the accident/injury/illness? If he/she did, do they understand what happened?

To get at the root causes of this particular accident, the supervisor should follow this line of questioning:

SUPERVISOR: What happened, Fred?

FRED: Hurt my back.

SUPERVISOR: Well, come sit down over here and take the strain off it. Where did you hurt it?

FRED: Here (pointing to his lower back).

SUPERVISOR: Did you hit it on something, or did you pull it?

FRED: Pulled it.

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(Obviously, Fred is a man of few words, and the supervisor will have to ask very specific questions.)

SUPERVISOR: Well, let’s start with where you were working when this happened.

FRED: OK.

SUPERVISOR: Fred, where were you working when this happened?

FRED: There (pointing to a rack).

SUPERVISOR: What were you doing?

FRED: Selecting six-tens.

SUPERVISOR: Were you lifting something, Fred?

FRED: Yes.

SUPERVISOR: What were you lifting?

FRED: That case of green beans.

SUPERVISOR: Was it in a floor slot or a second-tier slot?

FRED: Floor slot.

SUPERVISOR: Was it at the front of the pallet, the middle of the pallet, or the back of the pallet?

FRED: In the back.

SUPERVISOR: You were reaching back in there and trying to lift it at the same time?

FRED: Yes.

SUPERVISOR: Did you try to pull the case to the front of the slot before lifting it?

FRED: No.

SUPERVISOR: OK, Fred, I understand what happened. You should never lift and reach at the same time. When you come across a situation like this, you should use the preferred work method.

FRED: The what?

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SUPERVISOR: The preferred work method. Don’t you remember the training about lifting heavy objects?

FRED: No.

SUPERVISOR: Oh, that’s rightyou’re new on the job. I shouldn’t have let you start without safety training. We’ll get it done right away.

This is the preferred work method for this situation: When you have to lift a case that’s hard to reach, pull the case to the front of the slot where you can get it close to your body before lifting it (the supervisor demonstrates, pulling then lifting the case). That puts a lot less strain on your back muscles.

It’s usually easier to get information than when talking to Fred, but now the supervisor knows what happened. There was not just one cause of the accident, but three:

1. The employee didn’t follow the preferred work method while lifting.

2. The employee had not been trained in proper lifting techniques.

3. More employee observations should have been made.

So, here’s the information that should have been put on the accident/injury/illness form:Describe what employee was doing including: Equipment, Tools, Materials used, Etc.

New employee had not received proper training. Pulled a lower back musclewhile reaching at arm’s length and lifting a case of 6/10 green beans.

Driver accident. Now imagine another workers’ compensation accident form that’s completed this way:


Driver fell from ramp.

Again, this doesn’t tell us much. What was the driver doing? Wheeling product down the ramp? Jumping from the ramp to the ground? Tap dancing on the ramp? We don’t know.

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As an investigator you know that falling from the ramp was just part of what happened. In questioning the driver and witnesses, you learn that the driver was taking product down the ramp on a two-wheeler when he lost his balance and fell to the ground. But you still don’t know why this happenedyou’ll have to dig deeper. You’ll have to ask more questions.

We won’t go through a conversation as we did with Fred the selector, but you know how it’s done. Just keep asking the right questions until you get at the root causes of the accident. In this case you might need to ask questions such as these:

• How did the driver stack the two-wheeler?• Was the two-wheeler overloaded?• Was the load correctly balanced?• Was the load stacked so high that the driver couldn’t see where he was going?• Was the driver wearing gloves?• Was the driver wearing the proper footwear?• Were the driver’s shoes dry and clean?• Was there a foreign substance on his shoes?• Was there grease from the kitchen on his shoes?• Was the driver behind on his route?• Was the driver tired?• How many hours had the driver been working?

By asking these and other appropriate questions you’ll get at all the facts. Then you’ll be able to write a clear and detailed answer on the form:


Driver was taking heavy, unbalanced load down the ramp on a two-wheeler. When load started to tip forward he tried to save it, lost his balance, and fellfrom ramp to ground, bruising his shoulder.

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Question Checklist

A good investigator asks more questions and gets more information than he needs. He finds out all the facts he can about an accident/injury/illnesseven those facts that don’t seem important at the time. Then he can sort through the information and find the true causes of the accident/injury/illness.

Getting answers to the following questions will help guide your investigation in the right direction. When you ask these questions, they will lead to more detailed questions about the particular accident. Remember: If the associate begins to respond with only Yes and No you may be placing the associate in a defensive role or you may be filling the blanks for them instead of having them tell you what occurred.

Who?

Who was injured/ill? Who was working with him or her? Who else was involved? Who else saw the accident/injury/illness? Who gave first aid or medical treatment?

What?

What did the injured/ill employee say happened? What was the injured/ill worker doing at the time of the injury/illness? What was the position of the worker at the time of the accident/injury/illness? What physical position was the worker instanding, bending? What was the nature of the injury/illness? What task was being done? What products were involved? What equipment was involved? What preferred work method should the employee have been using? What personal protective equipment, if any, was required for the job?

Investigator’s tip: Keep the investigation going until you’re sure you’ve found all the causes of the accident/injury/illness.

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What had other people done that might have contributed to the accident/injury/illness? What operating problem, if any, caused the accident/injury/illness? What safeguards, if applicable, were in place? What did witnesses see or hear? What safety regulations, if any, were not followed? What unsafe working conditions, if any, were involved? What were the lighting, heating, and environmental conditions? What should be done to keep this accident from happening again? What will be done, by what dates, to keep it from happening againand who will do

it? What new safety regulations, if any, are needed to keep the accident from happening

again? What shift was the employee working? What ergonomic factors, if any, were involved?

When?

When did the accident/injury/illness happen? When did the employee start his or her shift? When did the employee first start this job? When did the employee start with the company? When did the employee receive safety training for this job?

Where?

Where did the accident/injury/illness happen? Where was the employee standing or working at the time? Where were the eyewitnesses at the time? Where were you (the supervisor) at the time? Where were the other people who were involved at the time? Where did the injured/ill employee first get first aid and/or medical attention?

Investigator’s tip: Expressing your interest and concern about the accident/injury/illness and its prevention shows your employees that safety is important to SSMC.

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Why?

Why was the employee injured/ill? Why did the injured/ill employee do what he or she did? Why did the other person do what he or she did? Why was the employee in a particular position? Why was he or she using the equipment involved? Why did he or she keep working under the circumstances? Why you (the supervisor) weren’t told if the equipment was not working right?

How?

How many back-to-back shifts had the employee worked before the accident/injury/illness?

How did the employee become injured/ill? How could the employee have avoided the injury/illness? How could other workers have helped avoid the injury/illness? How could witnesses have prevented it? How could company management have prevented it?

Investigator’s tip: Take copies of the preferred work methods with you when you investigate an accident/injury/illness.

Follow-Up Measures for Enhancing Accident Reduction

After the formal accident injury/illness investigation and report writing, follow-up action is necessary. In fact, the steps that follow the investigation may be the most important elements of successful accident/injury/illness prevention.

Immediate actions may have been taken by the supervisor to get unsafe conditions corrected. But in most situations there are longer-term steps, frequently involving management action beyond the supervisor’s scope of authority that should be taken. These are spelled out in the accident/injury/illness report.

It’s important that the accident report’s recommendations to prevent recurrence be specific and thorough—broad statements of intent are not enough. Within the supervisor’s realm of responsibility the report should list, specifically, who is responsible for corrective action and within what time frame.

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However, many of the recommendations may be beyond the immediate supervisor’s authority, such as those requiring equipment changes. In cases requiring large expenditures or allocation of resources, top management’s approval may be needed. And some changes can involve people and departments over whom the supervisor has no control. With these factors in mind, you should address the following questions in your safety manual:

• Who gets a copy of the accident/injury/illness report?• Who decides if the report’s suggestions should be adopted?• If changes are decided on, who makes sure they are implemented?• Who determines which changes to make first?• Who evaluates whether the new program is working?

The Higher Level Review Process

In most organizations, sound accident/injury/illness prevention procedures call for the review of the written accident prevention report and follow-up measures by higher levels of management. The thrust of this review is to assure that the recommended actions are appropriate and that such actions are actually taken.

Review of accident/injury/illness investigations by a higher level of management assures that the investigation is conducted thoroughly, in line with company-required procedures as outlined in the safety manual. Such a requirement shows that upper management is interested in accident/injury/illness prevention and the steps planned to prevent recurrence.

Following is an example of a process for higher-level review. Your operation should have a similar process, in writing.

• First Aid Cases

All first aid cases are investigated by the immediate supervisor, and a written report is prepared.

• More Serious Injuries and Job-Related Illnesses

All physician-treatment cases that do not result in lost time and all occupational illnesses are investigated by the immediate supervisor. The accident/injury/illness report is approved by the department manager.

All lost-time injury/illness cases are investigated by the accident investigation committee. The accident report is reviewed and approved by the vice president of operations. The committee consists of

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– The supervisor of the injured employee– The department manager– The safety manager– The chairman of the safety committee– A safety committee member form the department involved– The injured employee

• Major Equipment or Building DamageThese incidents are investigated by the accident/injury/illness investigation committee.

Ongoing Review to Improve the Quality of Investigations

Accident/injury/illness investigation procedures need regular review to be sure that they are providing relevant information to improve your safety program. Take these steps to maintain the quality of your process:

• Insist that all occupational injuries and occupational illnesses be reported to the appropriate company-designated person.

• Train all levels of management and supervision in how to investigate accidents, injuries and illnesses.

• Insist that all accidents, injuries and illnesses are investigated and that reports go to a ranking manager for review or approval. Return incomplete or inadequate reports to the appropriate level for correction.

• Establish controls to follow up on corrective action.

• Assist with implementing any corrective actions that go beyond the scope of authority of the person submitting the report. Support financial expenditures designed to correct unsafe conditions.

• Follow up to be sure that corrective actions are completed in the time frame pledged by the persons responsible.

Wellness/Claims Management

Effective claims management can lower the bottom-line cost of claims by reducing medical expenses and returning employees to work more quickly.

However, performing this function can also limit the time available for a Wellness manager’s other activities, allowing injury/illness trend cycles to become established.

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Safety Orientation Training Packet 30/60/90All new employees to SSMC must be given a Safety Orientation Packet, with testing and feedback collected at 30/60/90 days. This Safety information can be given with other important new-hire required documents. Due to the fact that Safety is such a large amount of information to understand, it is exceptionally important that the follow up feedback and testing be conducted promptly. This ensures the employee understands all of the training, as well as, gives the supervisor the ability to give direct input back to the employee on their progress in their job function. It also allows the employee to give input back about any specific issues the employee may be concerned about.

Employee Training Evaluation30 DAY: ______ 60 DAY: ______ 90 DAY: ______

Employee Name: _______________________ Date: ______________

Department: ___________________________

Supervisor: ____________________________

The purpose of this 30-60-90 day training evaluation is to evaluate and review your training progress. Your supervisor has outlined below some areas in which you may need to improve on over the remainder of your 90 day training period. Please feel free to ask questions as your supervisor is willing to help you in any way possible to ensure you obtain the training needed to become a successful SSMC Associate.

Specific Areas of Accomplishment: ___________________________________________

____________________________________________Specific Areas of in Need of Improvement: ____________________________________

____________________________________________Employee Comments: _____________________________________________________

____________________________________________

Employee Signature: ___________________________

Supervisor Signature: ___________________________

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Required OSHA Training/Guidelines The six sections of the OSHA Training Guidelines below are required training. The training on Hazard Communication, Blood Borne Pathogens, Lock-Out Tag-Out, and Emergency Preparedness/Evacuation are required training on every employee within a given Operating Company. There are not any exceptions to this training. The training on Fall Protection and Power Truck are to be given as necessary by the guidelines description in each section. The Training materials needed for each area can be obtained from JJ Keller. Detailed information will be given in the final section of the Manual. Below is the audit guidelines used by the 3rd party auditors for OSHA required training. You can use this guide to determine whether or not you have completed the required training.

HAZARD COMMUNICATION PROGRAM

1. Does the Company have a formal Hazard Communications Program which is in compliance with OSHA 29 CFR 1910.1200(h)? If so, does the program have the following attributes:

a. The program is written;b. Program management responsibilities are defined;c. Includes an outline of employee training;d. Includes a map of the warehouse that identifies hazardous chemical locations;e. Clean-up procedures in the event of a spill.f. Methods and observations that may be used to detect the presence or release of hazardous chemicals;g. Measures employees may take to protect themselves and other affected persons from the physical and

health hazards of chemicals;h. Written program is available to employees.

2. Is there a procedure to obtain a list of chemicals in inventory by location? Do slots change daily? In the event of a disaster how does the company obtain chemicals on hand by slot number?

3. At what intervals are the program updated (Should be yearly)?4. Do special procedures exist for the delivery of hazardous materials? If not, determine how the company

communicates the dangers and safeguards of hazardous materials to employees. If a program does exist, do those procedures include:

a. Including a Hazardous Materials Load Manifest;b. Ensuring all materials listed have weights;c. Ensuring proper quantities of hazardous materials are placarded (required if carrying 1,000 lbs. or

more).d. Procedures for handling trailer spills.

5. Ensure the MSDS Handbook is located near workers and is readily available to them.6. Are the MSDS filed in an organized manner and are individual MSDS easy to locate? Recommended: File first by where product is used (i.e., maintenance, garage, inventory, cooler, etc.) and then by suppliers (SSMC Brand, Ecolab, etc.). Individual MSDS books should at least contain sheets for product used/handled in that area.

7. Are procedures in place to ensure that MSDS are obtained for new chemicals and chemicals with changes in chemical make-up?

8. Determine the company’s policy regarding MA’s delivering chemicals. If the policy allows MA’s to deliver chemicals, do MA's receive hazardous material training? Note: MA's would be required to receive HAZMAT training upon hire and every three years according to DOT 49 CFR 172.704.

9. Ensure that a formal employee training program exists and includes the following:a. Identification of those employees requiring training;b. Ensures training is given annually, and at the time of initial hire, assignment changes, and introduction

of new hazards into work area;c. Documented proof of training and testing;d. Documented training materials.

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MATERIAL HANDLING EQUIPMENT TRAINING

1. Ensure procedures exist to train an employee for all materials handling equipment operated during the course of employment (in accordance with 29 CFR 1910.178(L)).

2. Are all new employees trained immediately on equipment specific to their duties?3. Training should be conducted for all employees on a regular basis (at least every three years). How often

is it performed?4. Who is responsible for training employees? 5. Do equipment operators have a current SSMC license identifying which equipment they can use?6. Ensure proof of training is maintained.7. Review training materials for adequacy.8. Does each operator perform pre-shift inspections daily?

PREVENTATIVE MAINTENANCE PROCEDURES

1. Determine if the Company has established a formal preventative maintenance program for each major type of equipment (i.e., forklifts, tuggers, trucks, pallet-jacks, etc.). If the Company performs its own repairs, ensure the following:

a. Adequate controls exist over access to replacement parts including tires, parts, oil, etc.b. Repair parts, tires, oil, etc. set up as a prepaid expense when purchased. What is the dollar amount of

parts on hand? Is it reasonable?c. Repairmen are charged with responsibility for use of and control over small hand tools.

2. Inspection reports must be completed daily to indicate compliance with 29 CFR 1910.178 (q) (7). Ensure daily inspection reports are prepared as follows:

a. Reports are signed by the operator (only pre-trip reports are required).b. Procedures exist to ensure that the mechanic is made aware of all exceptions on the reports. Document

these procedures.c. Mechanic signs of on the report and work order once the repairs have been completed.d. Next operator signs off that work was completed (Step can be performed by completing a pre-trip report

the following day).e. Reports are retained as required by OSHA.f. Control log is maintained to ensure that all reports are received and followed up on.

3. The Company or contractor maintains the following detailed maintenance records:a. File for each piece of equipment from date of purchase to present.b. All completed repairs from daily inspection reports are supported by work orders or third party

invoices.c. Preventative maintenance inspections and repairs are documented and supported.d. Mechanic signs off on all work orders and inspections.

4. What procedures exist to ensure that preventative maintenance is performed at the required intervals (i.e., miles, hours, etc.)? How are these intervals determined?

5. Does the Company use, or has considered software to schedule preventative maintenance and truck maintenance performed?

6. Are mechanics certified (expertise through supplier training, workshops, etc.) to work on each type of equipment?

CONTROL OF HAZARDOUS ENERGY: LOCK-OUT TAG-OUT

1. Does the Company have a formal written Lock-out/Tag-out program that is in compliance with 29 CFR 1910.147? If yes, obtain and ensure it include the following:

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a. For authorized/affected employee - - Definition of potential hazardous energy sources; - Purpose and use of energy control procedures; - Methods and means necessary for energy isolation and control.b. Procedures relating to the prohibition of attempting to restart or reenergize a machine once it has been

locked out.c. An annual audit of authorized employee’s lockout/tagout practice conduction and documentation.d. Energy control procedures are written for each piece of equipment with two or more energy sources?

Note: OPCO must produce actual written procedures.2. Do procedures to enforce Lock-out /Tag-out with employees and contractors include a disciplinary

statement for non-compliance?3. Is training performed upon job assignment and retraining if there is a change in job assignment, new

procedure or when annual audit identifies a weakness?

BLOOD BORNE PATHOGENS PROGRAM

1. Does the company have a written blood borne pathogen exposure control plan and training program which is in compliance with 29 CFR 1910.1030?

2. Ensure the exposure control plan includes the following:a. Listing of all tasks and procedures or where exposure could occur;b. Methods of controlling exposures;c. Post-exposure evaluation and follow-up procedures;d. Communication of hazards to employees;e. Record keeping on exposed employees;f. Plan is updated annually and is accessible to employees.

3. Ensure that a verifiable employee training program exists and includes the following:a. General explanation of epidemiology and symptoms of blood diseases;b. Modes of transmission;c. Explanation of the company’s exposure control plan;d. Activities that may involve exposure;e. Preventative methods;f. Post exposure follow-up evaluation;g. Emergency contacts;h. Appropriate actions to take and Personal Protective Equipment available.

4. Ensure training is performed annually and records are kept for three years. Note: records should include training session dates, outline of materials, name and qualifications of persons conducting training, names and job titles of attendees and signed receipts for each employee.

AMMONIA SAFETY PROGRAM

1. Does Company have a formal Anhydrous Ammonia Safety Program? If yes, the program should be in writing and include the following attributes:

a. Process Safety Management Program and Response Management Program (PSM and RMP). The Company must be able to produce these.

b. Addresses SARA Title III reporting requirements:i. Report release of ammonia in excess of 100 lb. per 24 hour period immediately;ii. Submit ammonia MSDS (initial and with changes);iii. Submit inventory forms (Tier II) during the first quarter of each year;

c. Availability and location of maintenance and personal protective equipment to be used for preventative maintenance and emergencies (includes equipment for eyes, face, head and extremities, protective clothing, respiratory devices and protective shields).

d. Ammonia gas detection equipment installed.

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e. Addresses availability and location of maintenance and personal protective equipment to be used for preventative maintenance and emergencies (includes equipment for eyes, face, head and extremities, protective clothing, respiratory devices and protective shields).

f. Document procedures for ammonia safety training.i. Subject to CFR 1910.119 (PSM Standard) if > 10,000 lbs. of anhydrous ammonia.

2. Does the Company participate in the Local Emergency Planning Committee (LEPC) for their community?

3. Has the Company identified an Emergency Response Plan and team? If team is comprised of employees, have they been adequately trained? If services have been contracted to a third party, do employees know how to contact them in case of emergency?

4. Ensure that a copy of the ammonia MSDS is located in the engine room.

SSMCSafe

1. Does the Company have a written mission statement?2. Does the Company have statements of accountability signed by all employees, management and

supervision?3. Is there a Steering Committee at the Company? How often do they meet? Who is on it?4. Have Preferred Work Methods (PWM) been developed for all jobs? 5. Has Preferred Work Method training been conducted? How often?6. Are Supervisors responsible for performing PWM observations? How many? How often?7. Are Supervisors responsible for performing COACH Card observations? How many? How often?8. Are Supervisors responsible for conducting weekly 10-Minute Safety Meetings?9. Does the company have a written 30-60-90 day Training Program?

Safety Goals10. Are they on track to achieve their goals? If they do not appear to be on track, have they formed an

action plan to get back on track?11. What can Corporate do to better support this Company in implementing and maintaining SSMCSafe?

DISASTER PREPAREDNESS & EVACUATION PROCEDURES

1. Have emergency escape procedures and emergency route assignments and assembly areas been identified?

a. Confirm the existence of floor plans and emergency maps that clearly show escape routes. Are these maps posted around the facility?

b. Is there a procedure to protect employees who remain in their work area(s) to perform shut-down or critical operation procedures prior to their evacuation?

c. How does the Company account for all employees after the evacuation has been completed? Note: Plan must include these procedures.

d. How does the Company report fires and other emergencies?e. Has a chain of command been established (using the Incident Command System) to minimize confusion

including outlining responsibilities of individuals to coordinate evacuation procedures?2. Ensure training for employees includes:Safety Training

a. Evacuation plansb. Alarm systemsc. Reporting procedures for personneld. Shut-down procedurese. Types of potential emergencies

3. Ensure training is performed for all employees when the plan is initially developed, and if the plan is changed for any reason, as well as for all new employees upon hire.

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4. Have SSMC Emergency Preparedness Plan modules (orange binder) been completed for pertinent hazards (i.e., earthquake in California, hurricane in Miami)? All modules may not be applicable for certain operating companies. Ensure those applicable are included.

FALL PROTECTION

1. Inquire as to the type of equipment the Company uses. Acceptable equipment includes double locking snap hooks, self retracting lifelines, and Type III full body harnesses.

2. Ensure that fall protection equipment is used in conjunction with any machinery or device that elevates anyone, employee or not, above the ground.

3. Is fall protection equipment inspected before each use and is a monthly inspection performed and documented in writing?

4. Who is responsible for destroying all damaged fall protection equipment?5. Ensure training is conducted during new-hire orientation and again annually for all employees.

SSMC DEFENSIVE DRIVING

1. Does the Company have an approved Defensive Driving Program (Smith System or D.D.C.) active and in place?

2. Are all drivers and MA's trained within 30 days of hire?3. Are drivers and MA's retrained within 30 days of a citation or accident?

LOSS CONTROL

1. Who is the individual responsible for monitoring insurance claims?2. What tools does the company use to monitor insurance claims?3. Who reviews the Open Claims Listing from the Loss Run (senior management should review the report

with the insurance coordinator)?4. Does the coordinator and the controller discuss reserve amounts with the insurance carrier’s claims

administrator periodically? Are unreasonable reserve amounts challenged?5. What controls are in place to ensure that the President and the Regional Safety Manager are made aware

of all litigated claims, assessments, and other significant legal matters involving the Company?6. Is the Company aware of the state’s law regarding the Second-Injury Fund? In most states, a

reimbursement may be available from the state under the Second-Injury Fund for claims filed by an employee who incurred a second injury which combined with prior permanent partial disability results in permanent total disability.

7. Discuss with the coordinator any open claims with unusually high, or low, outstanding net values and document any significant comments (The initial review can be done during pre-review).

8. Does the company have safety meetings for warehouse personnel and truck drivers? How often and when was the last meeting held? Obtain a copy of the last meeting's agenda.

9. Describe the company’s safety incentive program.10. Does the company have an established safety committee that meets regularly? Document the committee

members and how often they meet.11. Who evaluates safety controls?

OTHER

A. Determine if a copy of each of the following notices are posted in each physical location of the Company:1. Poster: ”Safety and Health Protection on the Job:”2. Emergency Phone Numbers (medical assistance, hospital, ambulance, fire department and police).

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3. Summary of Occupation Injuries (OSHA Form 300) which includes all recordable occupational injuries and illnesses (posted no later than February 1 and remains in place at least until April 30 of each year).

4. Ensure “Floor Load Protection” plates noting the maximum load acceptable are affixed in a conspicuous place on balconies or scaffolds used for storage or other means. As well, ensure any balcony/scaffold 10 feet or higher above ground has a 4 inch toe board, guardrails and an affixed ladder or stairway provided for proper access (29 CFR 1910.22 & 1910.29).

5. Citations must be posted at or near the place of an OSHA violation.

B. Other safety observations:

1. Ensure emergency exits and fire extinguishers are not obstructed.2. Does the Opco have an Early Suppression Fast Response (ESFR) sprinkler system? Note: If not, pallets

cannot be stacked more than 6 feet high per the National Fire Protection Association (NFPA Code 13).

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DAILY OPERATIONS

1. Does the Company have a Contractor Safety Program?2. Ensure the Company has hold harmless agreements and Certificates of Insurance with each and every

contractor that performs work on the Company's premises.3. Inquire as to how the company ensures Contractors comply with all Federal, State, and Local laws in

addition to SSMC policies and procedures.4. Are contractors required to check in each day before performing work?5. Ensure contractors are restricted to work areas only.

RISK NAVIGATOR

A. 26C8 Worker's compensation claims are reported to the third-party administrator (Gallagher Basset or Cunningham Lindsey) within 48 after the employee reports the claim to their supervisor.

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Safety Steering Committee GuidelinesThe Safety Steering Committee is a group of individuals responsible for the General Safety and Operating policies, procedures, and expenses affecting the SSMC Operating Company. This Committee will be responsible for the continued growth and maintenance of the facility’s Safety Program, including additional Preferred Work Method development. Most of the financial decisions will be made during the committee’s monthly meetings. It is important that the company’s decision makers are on this committee, and attend the monthly meetings.

Steering Committee Meetings Guidelines

Steering Committee Members:

President/EVP or General Manager VP or Director of Ops VP or Director of HR VP or Director of Finance VP or Director of Sales and Marketing Maintenance Manager Warehouse Manager Transportation Manager Safety Manager Wellness/Claims Manager

Roles and Accountabilities

Review information provided by Safety Department and Other Departments Management in: Overall Safety Performances-SSMCSafe, Goals, Objectives Proactive measures Departmental safety performance Regulatory Performance (OSHA, EPA, DOT, Etc) Create and maintain accountabilities at all levels in the organization Ensure SSMCSafe is implemented effectively and maintained Ensure all associates are maintaining their accountabilities and expectations in SSMCSafe.

Individual Roles and accountabilities

President/EVP/General Manager should hold each member of the SCM team accountable to their goals and accountabilities VP or Director of Ops should hold each member of his operation team responsible for their goals and accountabilities VO or Director of HR makes sure that all legal issues as it relates to the company policy are maintained.

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VP or Director of Finance ensures that any expenses make sense and are approved accordingly. They also can bring an understanding of how cost associated with safety affect the bottom line of the organization. VP or Director of Sales and Marketing works with the group to ensure that customer issues are/or Sales and marketing issues are addressed and corrected. Maintenance Manager keeps the group informed on status and cost of any fleet, maintenance or construction changes. Warehouse/Transportation brings information regarding their individual department performance, issues and needs.

Individual Roles and Accountabilities

The Safety Manager brings reports and information regarding root cause, performance (i.e. Coach Card report), training needs and any safety issues that are not being addressed. They will also provide information on company goals. Wellness/Claims manager brings financial change information for the month and any major associate changes or concerns (i.e. legal notifications)

Meeting Needs

Meet Monthly Maintain one hour schedule Documentation: Sign-in sheets and meeting minutes Should be a summary discussion and decision place

1. Do not spend time on issues that are already being addressed in other meetings (i.e. what happened in an accident)

Other

Approve Preferred Work Method changes Approve process changes Approve training time, length and other needs Address performance issues Maintain pro-active projects

Ultimate Goal

Commit to stay pro-active and eliminate potential injuries/accidents through the sharing of information and commitment to make a difference. All associates will follow PWM’s and rules at all times to ensure their safety and well-being. Ensure that all associates are given the opportunity to participate in the process. NO ASSOCIATE SHALL BE INJURED AT SSMC!!

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SEPP Manual and the Annual Management Risk Assessment

Whether your Operating Company is in Hurricane zone, Earthquake zone, or Flood zone you must have a plan in place to address steps to be taken if an Emergency arises. The SYSCO Emergency Preparedness Plan will give you guidelines and forms to use whenever needed. The entire SEPP manual is available on the SYSCO safety website. The sections that apply most directly to each Operating Company must be printed and kept bound by the safety manager. This version of the SSMC Emergency Preparedness Plan must be updated at least twice per year in the Monthly Steering Committee Meetings.

An outline is given below on this annual Risk Assessment. The outline is extremely detailed and well thought-out. This assessment must be done in order to identify any risk areas that may have not been addressed in the previous assessment. Again, these sections are not developed for additional paperwork, they have been deemed as required for our Operating Company’s continued Safety. These Assessments must be done in a detailed manner, with several Steering Committee members attending.

Operational Threat and Risk Management Assessment Workbook

Introduction

Quality control and security measures in place at SSMC Operating Companies, our suppliers and customers have provided the highest quality and safest food supplies in the industry. Since the September 11th attacks, SSMC recognizes the need to review our security practices and procedures.

Safeguards that we developed to address long-standing food safety issues and past tampering incidents are being re-examined and strengthen.

This guide will assist you in reviewing, and implementing protective measures to prevent or minimize the potential for attacks on the food supply, our employees and our facilities.

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Terrorist and Other Threats

Food Products

According to a recently published guide by the United States Air Force on Food Safety and Security, there are four primary classes of agent that pose a potential threat to food products. Those agents are:1) Biological agents that are delivered in the form of liquids, aerosols or solids (e.g., Salmonella, E. coli, etc.). Biological attacks would generally be silent at the time of occurrence and become apparent only later through the accumulation of severe illnesses in the population.2) Chemical agents that can be delivered as airborne droplets, liquids, aerosols or solids. They are generally classified as classical chemical warfare agents (nerve, blister, blood and choking agents) and toxic industrial chemicals (e.g., pesticide, rodenticides and heavy metals). Some characteristics of food contaminated by chemical warfare agents include:3) Radiological agents: radioactive elements that can be delivered in liquid or solid form.4) Physical agents: materials that could cause adverse health effects if eaten (e.g., bone slivers, glass fragments and metal filings).

AnthraxThree forms of anthrax occur in humans: coetaneous, gastro-intestinal, and inhalational. The coetaneous variety is by far the most common and responds very well to common antibiotics.

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Agent Taste Odor Color

Mustard Affected Garlic Meat discolored

N-Mustard Affected Fishy No discoloration

Arsenicals Acidic Unpleasant Meat and vegetables discolored

Nerve Not affected None No color change

Cyanide Bitter almond

Bitter almond

No color change

White phosphorous

Acidic Garlic Glows in the dark

Gastrointestinal and inhaled varieties though more severe, are much more rare, and do respond to antibiotics as well. Each form is described in more detail below.

Coetaneous AnthraxOver 95% of all anthrax cases worldwide are coetaneous infections. In these cases, the spores enter the body through an open wound in the skin, such as a cut or abrasion. Merely touching spores does not result in infection. Even when spores enter the body, infection only occurs when there are sufficient bacteria to overwhelm the body’s local immune response.

The incubation period of coetaneous anthrax may last from 0.5 to 12 days before infection begins. Infections begin as a raised itchy bump or papule that resembles an insect bite. Within 1-2 days, the bump develops into a fluid-filled vesicle, which ruptures to form a painless ulcer (called aneschar), usually 1-3 cm in diameter, with a characteristic black necrotic (dying) area in the center. Pronounced edema is often associated with the lesions because of the release of edema toxin by B. anthracis. Lymph glands in the adjacent area may also swell.

Approximately 80% of these infections will heal even without treatment. When serious complications occur, including death, they result from systemic infection or respiratory distress caused by edema in the cervical and upper thoracic region after the infection spreads through the lymph system. Survival improves to over 99% when antibiotics are used, with lesions becoming sterile within 24 hours of beginning medication and all symptoms resolving within several weeks. Deaths are rare following appropriate antibiotic therapy.

Gastro-intestinal AnthraxThe intestinal disease form of anthrax follows the consumption of contaminated food. Even when spores are ingested, infection occurs only when there are sufficient bacteria to overwhelm the body’s local immune response. The incubation period lasts from one to seven days. This form of the disease is characterized by an acute inflammation of the intestinal tract. Initial signs of nausea, loss of appetite, and vomiting are followed by abdominal pain, vomiting of blood, and severe diarrhea. This form can also occur as an oropharyngeal infection with symptoms of sore throat and difficulty swallowing presenting with oral or tonsillar ulcers, usually associated with fever and swelling of the neck. The presenting sign may be an acute abdomen with fever and ascites.

As with the other forms of this disease, gastrointestinal anthrax is not known to be contagious – it is not spread from person to person.

Inhalational AnthraxThis form of anthrax results from inhaling B. anthracis spores, and is now most likely to occur following an intentional release of B. anthracis. Even when spores are inhaled, infection occurs only when there are sufficient bacteria to overwhelm the body’s local immune response

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(8,000 – 50,000 spores). The incubation period commonly lasts from one to six days, but may be as long as 43 days. The onset of infection is gradual and nonspecific. Fever, malaise, and fatigue may be present initially, sometimes in association with a nonproductive cough and mild chest discomfort. These initial symptoms are often followed by a short period of improvement (ranging from several hours to days), followed by the abrupt development of severe respiratory distress with dyspnea (labored breathing), diaphoresis (perspiration), stridor (high-pitched whistling respiration), and cyanosis (bluish skin color).

As with the other forms of this disease, inhalational anthrax is not known to be contagious –it is not spread from person to person.

Facility Threats

When assessing your current security capabilities and processes, it is important to keep in mind four basic methods in which a threat could be carried out against a food distribution facility. The four basic tactics that an aggressor could use in an effort to tamper with the food supply are:1) Exterior attacks that damage facility assets and introduce an agent from outside the facility and/or asset.2) Forced entry by using tools to enter a facility through an existing passage or to create a new opening in the facility in order to gain access to the facilities contents.3) Covert entry by using false credentials or other means of deception or stealth in order to gain access to the facilities contents.4) Insider compromise by using someone with legitimate facility access to tamper with food products.Your greatest threat is from current or former disgruntled employees, small competitors, upset customers, outside carriers and onsite vendors, and contractors (i.e. lumpers, cleaning services etc).

It is important to develop an action plan that effectively addresses each of these potential contamination methods while remembering that both external and internal threats are possible at your facility.

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“Critical Control Points”

Below is a sample of a “Critical control point” analysis for a SSMC Distribution Operating Company. You should review, update or add additional control points as identified.

1. Incoming Correspondence / Packages:

Mail – Fed Ex. /UPS/ U.S. Postal Service Overnight Express

Phone – Fax – E-mail

Packaging or Contents are threatening, suspicious or contaminated.

2. Product Returns:

Product, supplies, or other returns from known and unknown persons, vendors or customers are considered points.

3. Incoming Product: suppliers, vendors, common carrier, back hauls, or rail

4. Personnel:

Employees

Applicants/New Hires

Temps.

Disgruntled current or past Employees

On Site contractors (facility maintenance, lumpers, etc.)

5. Facility Security:

Building

Employee identification

Visitors

Outside Carriers/lumpers

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6. Utilities:

Water - Air - Electricity – Refrigerant – Natural Gas

7. Transportation:

Trucks/Trailers on site

Truck/Trailer / off site

Outside Carriers

8. (Other)

"Critical Control Point" Self Audit Work Sheet - Example

Operating Company- SSMC

Critical control point – Incoming Correspondence/Packages

Current intervention policies, procedures and processes (list)

Check box if changes or additional training is needed.

After evaluating "Critical control point" area, the following action steps are recommended:

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Dangerous, Contaminated or Suspicious Letters or Packages Procedures

Identifying Suspicious Letters or Packages

Suspicious packages and letters may include the following characteristics. Bear in mind that the existence of one of these characteristics does not mean that the letter or package is a bio-terrorist threat or dangerous device. Each facility’s security should develop specific mail handling procedures.

Excessive postage Handwritten or poorly typed addresses Incorrect titles Title, but no name Misspellings of common words Oily stains, discolorations or odor No return address Excessive weight Lopsided or uneven envelope Protruding wires or aluminum foil Excessive security material such as masking tape, string, etc. Visual distractions Ticking sound Marked with restrictive endorsements, such as “Personal” or “Confidential” Shows a city or state in the postmark that does not match the return address

Any packages letters or suspicious packages should immediately be reported to the "Security Coordinator".

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Response Guidelines for Security Coordinator

General Guidelines

The most important guideline to consider is to stay calm and to reassure others. The actual risk of exposure is extremely small. Most suspected exposures turn out to be false alarms, either from deliberate hoaxes or from jumping to conclusions.

Clear communication with employees and other agencies will help dispel fears and will help ensure compliance with instructions should precautionary measures need to be taken at some point.

Do not handle, shake or empty the contents of any suspicious envelope or package.Call or have someone call the appropriate local health dept or law enforcement agency. Ask for and follow their instructions.ISOLATE the unopened suspicious envelope or package.If you do not have a container readily available, then cover the envelope or package with anything (paper, trash can, clothing etc.)Leave room, close the door, and section off the area to prevent others from entering.Ensure that all persons who have touched the suspicious package wash their hands with soap and water to prevent spreading of any contaminate.List all the people who were in the room or area when the suspicious letter or package was discovered.

Routine use of Gloves and Masks

Use of gloves and masks are not generally recommended for private company mail handlers at this time. The risk of exposure is extremely small. Dust masks do not provide protection against spores. However, some facilities may allow employees to wear approved HEPA filer masks voluntarily if they wish. If employees do want to wear gloves for comfort, avoid latex and use vinyl or nitrile instead, preferably of the un-powdered variety.

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Responding to Possible Contamination from Aerosolization

These guidelines are for responding in the event that a small aerosolizing device is triggered, or if you receive warning that the air handling system is contaminated, or warning that that a biological agent was released in the facility.

1. Turn off local fans, HVAC (heating, ventilation and air conditioning) or units in the area.

2. LEAVE area immediately.

3. CLOSE the door, or section off the area to prevent others from entering (i.e., keep others away).

4. Your Local Emergency Response 911 system must be notified immediately of an aerosolized exposure. Ask for and follow their instructions, including possible evacuation.

5. SHUT down the HVAC system in the building, if possible.

6. If possible, list all people who were in the room or area. Give this list to both the local public health authorities so that proper instructions can be given for medical follow-up and to law enforcement officials for further investigation.

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To be included in S.E.P.P. Manual

SSMC Operating Company - Self Audit Questions

Employees

1) Do employees sign or check in and out of your facility?2) Do they have employee ID? Cards?3) Are there procedures for off-shift facility entry?4) Are there procedures for friends & relatives visiting employees?5) Are there procedures for law enforcement personnel entering your facility?6) Are all employees informed of your security, firearms, and drug and alcohol policies before

they work at your facility?7) Do they have limited access or time windows?8) Do they report suspicious people, objects or things?9) Upon termination of employment are employees

1. Informed of access restrictions, in writing.2. Asked to account for all keys.3. Immediately removed from access to all computers and voice mail.

10) Are terminated employees escorted from facility and all pertinent personnel notified?11) Are security officers furnished with a photo picture of all terminated employees?

Visitors, Vendors & Contractors

1) Do visitors, vendors and contractors sign or check in and out of the facility?2) Do you have a visitor badge system?3) Do you verify non-employees and their Company affiliation before they enter your facility?4) Do vendors and contractors meet their SSMC contact person and travel to their destination

within the facility for the first time?5) Are visitors, vendors and contractors informed of your security, firearms, and drug and

alcohol policies before they work at your facility?6) Do all contractors sign a hold harmless for the actions of their employees?7) Do all contractors and vendors hold their employees to the same background and security

checks requirements as your employees? 8) Are visitors met or escorted to their SSMC contact?

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Inbound (Delivery) Vehicles

1) Are inbound vehicles containing products, supplies and materials scheduled before they arrive?

2) Are first-time vehicles and drivers contacted before they enter the facility?3) Are inbound drivers required to show proof of their Company affiliation before they enter your

facility?4) Are all inbound drivers informed of your security, firearms, and drug and alcohol policies

before they enter your facility?5) Do the drivers sign in and out of the facility?6) Are inbound drivers told about your policies regarding their passengers entering your facility?7) Are all inbound shipping documents verified before the vehicles are positioned at the facility

and unloaded?8) Are inbound drivers told where to smoke, take breaks, find a restroom and obtain food or

beverages at your facility?9) Are inbound drivers informed of your site-specific vehicle and pedestrian traffic areas?10) Are inbound drivers told what areas are off-limits to them, their passengers and their vehicle?11) Are inbound drivers given a list of company procedures?

Outbound (SSMC Vehicles)

1) Are personnel, vehicles, lading and the paperwork checked (as appropriate) for each outbound vehicle?

2) Is a pre-trip inspection completed and verified (as required) for all Company vehicles?3) Are vehicles spot-checked (or are they all checked) for unauthorized Company property when

exiting your facility?4) Are outbound vehicles logged out of the facility?

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Site Security SystemsVehicle/Personnel Ingress and Egress

1) Are all ingress and egress points for personnel and vehicles properly lighted?2) Are building entry keys and access cards properly controlled for visitors, vendors, contractors

and employees?3) How are lost or stolen keys or access cards handled?4) Are your employee parking, will-call and truck loading/unloading areas secure?5) Do all vehicles check or sign in and out of your facility?6) Do you have a policy to prevent and manage the tailgating of personnel and vehicles into or

out of your facility?7) Is your facility fenced?8) Do you allow fire arms or weapons on-site (including parking lots)9) Do you have posted procedures at entry points (parking lot, gates, company entrances)

Internal/External Surveillance

1) Do you have an internal and/or or an external security system?2) Do you have cameras or motion detectors covering all critical areas?3) Do the cameras work properly in all areas regardless of temperature or background lighting

conditions?4) Do the cameras allow you to pan, tilt, and zoom to a specific area?5) Is the camera system properly maintained and secure?6) Are completed security tapes archived in a secure location for a sufficient length of time?7) Do exterior doors have alarms in “non-traffic” areas, such as fire exits?8) Are all contracting personnel who work on your security system properly identified, trained,

licensed, bonded and insured before they are allowed access to your security system?9) Have you posted security policies and procedures?

Security Officers

1) Does your facility have physical security (security officers) on duty 24/7?2) Are the security officers your employees or contractors?3) Has your security company signed a hold harmless agreement?4) Do you know how your security company screens and assigns personnel?5) Are you notified and do you interview any new or different security personnel. 6) Do you have proof that the security officers are trained, physically and mentally capable and

bonded appropriately for their level of work?7) Are the security officers able to enforce your workplace violence, drug and alcohol,

firearms, emergency and security policies?8) Does security complete building or perimeter tours on foot or in a vehicle?9) Does security have a current list of standing orders that cover potential routine and emergency

situations?10)Do the security officers carry any type of weapons?

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Operational Security Procedures and Processes

The following are measures that SSMC Operating Companies have implemented to increase security within their organization. These procedures are used to prevent or minimize any attempts to introduce contaminants into the food supply or cause harm to our employees, Customers and the general public. The listing of these procedures is intended to assist Operating companies evaluate their current security status, recognize additional risk and suggest additional security procedures and processes to deter future threats.

Facilities: Posted policy at all entry points (no firearms, visitors must check in, etc.) Assigned responsibility for security. Accountability for all keys. Develop programs to prevent security breaches with respect to control panels, HVAC

Units, electrical boxes, gas and pressure valves, etc. Check all perimeter lights and remove all clutter from fences and gates. Make certain

gates and doors are locked when not in use. Eliminate roof access to unauthorized personnel. Remove all exterior ladders to the roof.

Secure all roof hatches with an interior padlock with keys maintained under management control.

Minimize the number of entrances to controlled areas. Provide locks for entry doors, windows and roof openings. Minimize the number of gates in perimeter fencing and keep them locked at all times. Video cameras and security patrols at interior and exterior areas. Test alarm and security systems periodically to assure they are functioning properly. Security on inbound and outbound docks. Products are inspected by a qualified

employee. On site vendors and lumpers. Demand the same background and security checks as your

employees. Limit lumper mobility within the facility to a specific dock area and assigned restroom

only. Review outside driver guidelines and limit outside driver mobility within your facilities. All visitors and non employees limited to single entry point. Emergency or “Help Signal” for front desk or receptionist. Verify all potential employee references and review hiring procedures. Security patrols should be documented, but random.

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Written company policy on terminated or past employees. Office hours with safety procedures for after hours work. Conduct random drug and criminal background checks on all employees. Roster of employees working on any given day. Know who is and who should be on the

premises and where they should be located. Ensure that only authorized staff enters your facilities and limit access to

high-risk/vulnerable environments. If applicable, restrict access to food preparation areas to authorized personnel only.

Create work area authorization/restrictions for employees. Provide staff with photo identification name cards and/or key-swipe cards and always

provide visitors with proper identification, never allowing them to be unescorted in your facilities.

Introduce color-coded hats or garments to help supervisors quickly recognize if someone is out of place.

Immediately delete all facility and computer access capabilities when access authority is rescinded for any employee or once an employee has been terminated.

Limit the amount of personal belongings brought to the facility (e.g., purses, gym bags, thermoses, drink containers, etc.)

Have employees store clothes and other personal belongings in designated areas separate from food storage and/or preparation areas.

Ensure that no staff can carry anything onto the distribution floor from the outside, especially from locker rooms.

Re-check your computer security including hardware, software, passwords, paper records and e-mails from unknown sources.

Use known suppliers and contractors and ask those suppliers and contractors to implement the same precautions you are taking. Ensure all your suppliers have heightened security and quality assurance procedures in place.

Check all incoming engineers and contractor staff and do not allow any unnecessary tools, etc., to be taken into any distribution facility. Limit their access to only those areas of the plant relevant to their work.

Maintain a vendor “in and out” log for all non-company personnel. Ask suppliers and contractors to assign the same people to visit your operations each time,

if possible. Implement a visitor ID badge system. Employees do not wear freezer suits exiting or entering facility. Hold security badges and visitor/contractor passes in a secure area to prevent theft and

misuse. Develop a plan to identify and contain mislabeled products.

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Review the sourcing of any raw materials, if applicable, and reassure yourself of their integrity and security.

Check the safety and security of all utilities, especially water. Check all security/seals on incoming shipments. Consider any necessary procedure

changes. Request that all mail from your suppliers and customers carries the sender’s company

name or logo. Advise your mailroom not to open any suspicious mail. Ask all of your staff to refrain from having personal mail sent to your offices. Train and discuss with all reception and security staff the implications of security/crisis

management. Ensure that everyone understands his or her individual role in the event of a security breach.

Create an incident response team and security coordinator for each shift. Eliminate potential hiding places within facilities where a contaminating agent could be

temporarily placed before being delivered to its target. Include food safety and security measures in purchase contracts. Mandate that your suppliers place a unique product number and UCC-UPC bar code on

all four sides of each shipping container. This will increase traceability in the event of a product recall or withdrawal.

Train your employees to recognize and report suspicious activity. Reward and hold all staff accountable for being alert to and reporting signs of product tampering.

Immediately investigate and document all reports of unusual activity. Place all new employees with a mentor (a supervisor or co-worker) with increased

oversight during probation. Review procedures for handling damaged and/or returned products. Develop procedures to ensure that food security details are kept confidential. Review supervision of maintenance and sanitation staff. Perform random inspections of facilities and vehicles. Check safety and security of hazardous materials. Have security personnel transport cash to and from bank. Have panic alarms and camera coverage at driver cash collection point.

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Transportation:

Require that all suppliers and shippers take whatever actions necessary to insure product safety including the safe delivery of product to our property and the actions of the delivery personnel.

Ensure that our customers and freight forwarders understand that they are responsible for onsite product safety.

Require transportation companies to conduct criminal background checks on all drivers. Implement trailer lock and seal program on storage and drop trailers. Develop and implement security procedures for drivers to adopt when stopping for meals,

fueling, breakdowns, etc. Secure cab and remove keys when vehicle is parked. Develop procedures for trailer security at customer's site.

RESOURCES

Emergency operations at FDA: 301-443-1240.Emergency operations at USDA: 202-720-5711.Food Distributors International – NAWGA/IFDA

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Critical Control Points Pre-review Controls Post Review Action Steps

1. Incoming Correspondence/Packages

2. Product Returns

3. Incoming Product

4. Personnel

5. Facility Security

6. Utilities

7. Transportation

8. Other

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Monthly Safety AssessmentsOnce a month, the Safety Manager and at least one other member of the Steering Committee must conduct a Safety Assessment. These Assessments must be documented. The outline below should be used as a template. It is important to realize that Safety must be addressed in every square foot of the Operating Company. Many accidents happen in low traffic areas that are just not well maintained. This is why it is important to conduct this Assessment on a monthly basis.

Monthly Safety Assessment

Location:_________________ Date: __________ Inspector's Name: ___________________

Are conditions and protection satisfactory?All "no" answers require comments and a completion date for corrective action.

Yes No Comments DateBuilding PerimeterSidewalks Outside Building Walls Rat Stations Post Indicator Valve

Outside Dock AreaWheel Chocks Dock Levelers Doors Strip Curtains Lighting Floors Clean trash Receptacles Area Neat & Orderly

Inside Dock AreaRacks Free of Damage Aisles Marked Properly Doors Electrical Outlets Fire Hose (check nozzle) Fire Extinguishers Lighting Floors Clean Trash Receptacles Safety Posters Area Neat & Orderly Aisles Unobstructed

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Receiving AreaRacks Free of Damage Aisles Marked Properly Doors Electrical Outlets Fire Extinguishers Lighting Floors Clean Trash receptacles Safety Posters Area Neat & Orderly Aisles Unobstructed Emergency Exits

Yes No Comments DateFire Hose (check nozzle)

Forklift Charging AreaRacks Free of Damage Aisles marked Properly Doors Electrical Outlets Charger Connections Fire Extinguishers Lighting Eye Wash Stations Emergency Shower Safety Goggles Rubber Gloves Floors Clean Trash Receptacles Safety Posters Area Neat & Orderly Aisle Unobstructed Batteries Clean Chargers Properly Marked

Warehouse EquipmentOverhead Guards Batteries Clean Battery Cover Intact Battery Connections Unfrayed Machines Clean No worn or broken parts/hoses Tires in Good Condition Capacity Card Visible Warning Signs Legible Controls Clearly Marked Check Lift Chain Slack

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No Visible Leaks Load Rest Intact

Cooler "One"Doors Strip Curtains Floors Clean Racks Free of Damage Aisles Marked Properly Pipe Bollards Undamaged Lighting Electrical Outlets Fire Extinguishers Emergency Exits Safety Posters

Yes No Comments DateEmergency Lighting Trash Receptacles Area Neat and Orderly Aisles Unobstructed Product Stored Properly Walls Structurally Sound No Visible Cooler Unit Damaged No Ice Build Up on Cooler Unit Coils Drains Working No Broken Pallets in Racks

Ripening AreaDoors Strip Curtains Floors Clean Racks Free of Damage Aisles Marked Properly Fire Extinguishers Pipe Bollards Undamaged Lightning Electrical Outlets Emergency Exits Safety Posters Emergency Lighting Trash Receptacles Area Neat & Orderly Aisles Unobstructed Product Stored Properly Walls Structurally Sound No Visible Cooler Unit

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DamagedNo Ice Build Up on Cooler Unit Coils Drains Working No Broken Pallets in Racks

Processing RoomDoors Strip Curtains Floors Clean Racks Free of Damage Aisles Marked Properly Fire Extinguishers Pipe Bollards Undamaged Lightning Electrical Outlets Emergency Exits Safety Posters Emergency Lighting Trash Receptacles Area Neat & Orderly Aisles Unobstructed Product Stored Properly Walls Structurally Sound

Yes No Comments DateNo Visible Cooler Unit Damaged No Ice Build Up on Cooler Unit Coils Drains Working No Broken Pallets in Racks

Office AreaDoors Unobstructed Floors Clean Aisles Unobstructed Lighting Electrical Outlets Fire Extinguishers Emergency Exits Safety Posters Emergency Lighting Trash receptacles Area Neat & Orderly Files & Books Stored Properly No Electric Heaters Under Desks No Smoking Extension Cords Used Properly

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Doctor/Clinic RelationshipThis section highlights the importance of developing a relationship with the Operating Company’s local Doctor and/or Clinic. This relationship will be used for several purposes. Some of these purposes include Pre-Employment drug screening, non-emergency injuries, Post-Offer Physical Capabilities Testing, as well as Post-Injury or Accident drug testing. By developing this relationship on a local basis, you will be able to have the local Doctor or Clinic customize what is most beneficial to your Company. An example of what a Doctor/Clinic might use to develop a Physical Capabilities Test is given.

PHYSICAL REQUIREMENTS:

1. Amount of each day spent:Standing Walking Sitting Total 100%

2. Employee works: Inside Outside Total 100%

3. While performing the job, employee is required to:

*How Often?How

Long?

A. Twist/Turn Yes x No Frequently All shift

B. Stoop/Bend Yes x No Frequently All shift

C. Squat Yes x No Occasionally All shift

D. Kneel Yes x No Occasionally All shift

E. Crawl Yes No x Very Rarely

F. Climb Yes x No Very Rarely All shift

G. Step up/Step down Yes x No Rarely All shift

H. Balance Yes x No Very Rarely All shift

I. Walk Above Ground Yes x No Occasionally

J. Reach Upward Yes x No Occasionally All shift

K. Reach Forward Yes x No Occasionally All shift

L. Wrist Rotation Yes x No Rarely All shift

M. Grasping Yes x No Rarely All shift

N. Pinching Yes x No Rarely All shift

O. Manipulating Objects Yes x No Very Rarely All shift

P. Push/Pull 21 – 50 lbs. Yes x No Frequently All shift

Q. Push/Pull 50 lbs. Yes x No Frequently All shift

4. Lifting Requirements in pounds**:

1 - 10 11 - 20 21 - 35 36 - 50 51 - 75 76 - 100

Frequent Frequent Frequent Frequent Frequent Frequent

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5. Carrying Requirements**:

35 lbs. 50 lbs. 100 lbs.

Frequent OccasionalVery rarely

** Very Rarely = < 1% Rarely = 1-10% Occasionally = 11-33% Frequently = 34-66% Continually = 67% +

***This description does not state or imply that these are the only duties to be performed by the person in this job. Employees may be required to follow and perform other job-related duties as requested by their supervisor.

****Position functions are subject to reasonable accommodation for qualified individuals with disabilities. Some position functions may exclude qualified individuals with disabilities who pose a direct threat or significant risk to the health and safety of themselves or other employees.

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Current D.O.T. RequirementsBelow are the current requirements and suggested testing from the Department of Transportation. As mentioned earlier in this Manual, these are not suggested, they are required. Without adherence to these requirements, the SSMC Operating Company is not eligible for the pooling money on any accident claim. It must be noted that a single claim can put a Company out of business. These requirements and training must be preformed and documented in a timely manner.

DOT REQUIREMENTS

A. APPLICATIONS

1. Expectation: Must have on file three years of previous addresses.

2. Expectation: Must have on file previous experience and what equipment driven.

3. Expectation: Must have on file accidents for the previous three years

4. Expectation: Must have on file moving violations for the previous three years.

5. Expectation: Must have on file ten years of previous employment (if applicable).

B. BACKGROUND

Driver’s files need to have in file employment verification.

1. Expectation: Three years of previous employment must be verified.

2. Expectation: Two years of previous drug screen and alcohol results must be verified.

C. DOT PHYSICAL

1. Expectation: Must be renewed every two years.

2. Expectation: Must have three years worth in file, after two years employment

D. PRE-EMPLOYMENT DRUG SCREENING

1. Expectation: Must have negative results back before the new employee can be dispatched.

E. ROAD TEST

1. Expectation: A complete and consistent road test to ensure the operator can operate the vehicle that he is assigned.

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F. MVR OR ABSTRACT

1. Expectation: Must have three years worth in file after three years of employment.

G. DRIVER’S CERTIFICATION OF VIOLATIONS

1. Expectation: Driver must declare any moving violations, and or suspension on their CDL for the past 12 months.

H. ANNUAL REVIEWS

1. Expectation: Employer needs to complete before employment anniversary date of each year.

I. 7 DAY PREVIOUS HOURS OF SERVICES (NEW DRIVER WITH LESS THAN 6 MONTHS EMPLOYMENT).

1. Expectation: This record is for new drivers and must remain in the file for the first six months of the employee employment.

J. COPY OF CURRENT CDL

1. Expectation: All employees must have in the file a current copy of the employee’s most current CDL.

K. DRIVER ORIENTATION

1. Expectation: All employees must have a copy of the most current FMCSR given to every driver with the receipt placed in the employee’s file.

2. Expectation: All employees must have a copy of company policy pertaining to safe operation of company vehicles.

3. Expectation: All employees must have in file a copy of the training for hours of services.

4. Expectation: Pre-trip and Post trip DVIRS.

5. Expectation: The operating company must have in place a system for reporting moving violations, roadside inspection, load and weight limits, and license suspension.

L. RANDOM TESTING

1. Expectation: Quartile reports, Summary, random list, minimal 50% drug, and minimal 10%alcohol.

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M. REPORTABLE ACCIDENT

1. Expectation: The operating company needs to keep on file a ledger or a spreadsheet for DOT reportable accidents with documentation for follow-up on post-accident drug and alcohol testing.

N. MANAGER COMPLIANCE

1. Expectation: Is there any documentation of training for hours of service and reasonable cause training in drug and alcohol for supervisor.

2. Expectation: System are in place to insure the drivers turn in all paperwork.

3. Expectation: The operating company is required to run hours of service audits and document where the driver with hours of service violation was retrained, written up, or suspended.

O. MAINTENANCE FILES

1. Expectation: The operating company’s perform annual inspections on trucks and trailers.

2. Expectation: The operating company’s document repairs completed on any DVIRS and defects.

3. Expectation: The operating company’s perform B maintenance.

4. Expectation: The operating companies have all files properly labeled

5. Expectation: The operating companies are required to have documentation that all brake mechanics are certified.

P. RECORD KEEPING

1. Expectation: All logs are retained for 6 months.

2. Expectation: DVIRS are retained for 3 months.

3. Expectation: maintenance files are kept for 5 years.

4. Expectation: Drivers file are retained for 3 years after leaving.

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Q. DRIVER TRAINING PART 383 Entry level drivers-driver with less than 1 year experience must be train in:.

1. Expectation: Driver Qualification part 391.

2. Expectation: Hours of service part 395

3. Expectation: Driver wellness(basic health-Diet, exercise, excessive use of alcohol, stress, sleep aponea,blood cholesterol, blood pressure, and weight..

4. Expectation: Whistle blower protection-29cfr part 395

5. Expectation: Date issued.

6. Expectation: Name and address of training provider.

7. Expectation: Name of driver.

8. Expectation: Statement that driver has completed training in the mandated requirements.

9. Expectation: The printed name and signature of the person attesting that the driver received the training.

SSMC Safe REQUIREMENTS

A. All delivery customer service associate and or marketing associates have completed an approved defensive driving course

1. Expectation: All delivery service associate have completed an approved defensive driving course with documentation in file.

2. Expectation: All Marketing associate have completed an approved Defensive driving course with documentation in file.

B. SAFETY MEETINGS

1. Expectation: The operating companies are required to perform safety meeting monthly with all drivers and all meetings are documented with all drivers in attendance and subject matter that was covered in the meetings.

C. 30-60-90 DAY EVALUATION

1. Expectation: All documentation is placed in file and guidelines are being followed.

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D. DRIVER RETRAINING

1. Expectation: After a driver is involved in an accident, is driver retrained and documented.

E. DRIVER ORIENTATION

1. Expectation: All employees must have in file a copy of accident reporting procedures and disciplinary policy.

2. Expectation: All employees must have in file a copy of preferred work methods used at the operating company.

3. Expectation: All employees must have in file the documentation for proof of training on Blood Borne Pathogens.

4. Expectation: All employees must have in file the documentation for proof of training on Haz-Com.

5. Expectation: All employees must have in file the documentation for proof of training on Operations procedures.

6. Expectation: All employees must have in file a copy of defensive driving course (Smith System/SSMC).

F. TRANSPORTATION SAFETY SUPERVISOR OR TRAINER

1. Expectation: The operating company has in place a transportation safety supervisor or trainer.

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Visitor Awareness/Protection ProgramA Visitor Awareness & Protection Program reduces liability on the Operating Company from visitors and vendors who come on property. Each non-vendor visitor that comes onto site must, at a minimum, read and sign off on the Pedestrian Preferred Work Methods. Each Operating Company must have badges issued to all visitors showing they are a visitor. Each Vendor that comes onto site must sign a Hold Harmless Agreement and provide their Certificate of Insurance. It is recommended that the Vendor’s employees read and sign off on the Hazard Communication and Fall Protection Guidelines provided in this Manual. Below is an example of a Contractor Safety Agreement.

CONTRACTOR SAFETY AGREEMENT

The individual or organization named above (herein called the contractor), hereby agrees that the following provisions shall apply to and be a part of each and all of contractor’s operations at Company sites.

A. The contractor shall accept full responsibility for assuring the use of safe work practices by

contractor’s employees.

B. The contractor shall accept full responsibility for contractor’s employees having full knowledge

of all existing fire, safety and health hazards associated with Company operations.

C. The contractor shall accept full responsibility for contractor’s employees having received and

read a copy of Company Contractor Safety Rules.

D. The contractor throughout the performance of any work that utilizes subcontractors shall be

responsible for subcontractors receiving and following “Contractor’s Safety Rules” and for being

informed of hazards associated with the Company.

E. The contractor shall comply with all state, local and public safety codes, laws and ordinances

pertaining to the work being performed.

This is to certify that I have read and received a copy of the Company Contractor Safety Rules. I agree to provide a copy of these rules to all employees and subcontractors for their reading and practice.

I understand that should I require additional information or assistance in providing my employees specific knowledge regarding the hazards associated with their work at Company sites, that I should contact the Safety department.

I further understand that should I, my employees, or any subcontractors I employ, refuse to follow Company Safety Rules, it will result in a request for said person’s removal and may affect any and all future contracts.

Dated:____________________, 20___ By: _______________________________________

Title: ______________________________________

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Recommended Additions to Safety ProgramsThis section contains additions that will compliment the sections described above.

Personal Protective Equipment Program

Application:

Personal Protective Equipment (PPE) for the eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided to our employees by (company name). The equipment must be used by employees when it is found necessary for protection against workplace hazards. (Company name) will also maintain the personal protective equipment in a sanitary and reliable condition.

Scope:

The Personal Protective Equipment Program addresses the requirements of protective equipment, including personal protective equipment for eyes, face, head, hands, and feet. The elements of this standard also explain the specifications for the type and manufacture of personal protective equipment. The (company name), must provide necessary equipment and enforce the use of this equipment to avoid potential injury or illness. This program is also designed to maintain equipment in a sanitary, reliable, and safe condition to further reduce the likelihood of injury. Responsibilities and administrative duties include:

1. Development of a written program which describes how PPE is selected and managed at this facility.

2. Perform and Certify Hazard Assessments of each workplace to identify hazards and to indicate the type of PPE required for protection.

3. Properly select PPE based upon the Hazard Assessment, enforce the use of PPE, and replace damaged or defective equipment.

4. Provide informative training and retraining sessions to ensure all employees understand the purpose of this program. Documented training to verify the activity.

5. Review the program periodically and revise when needed.

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Hazard Assessment and Equipment Selection:

The intent of this program is to assess each work area with the purpose of determining if hazards are present, or likely to be present. The PPE Hazard Assessment indicates which work areas, job functions, and employees will be required to use personal protective equipment (PPE).

The hazard categories are listed on the Hazard Assessment to assist with the identification of hazard exposures. The evaluation will consider the potential for injury and whether the potential is high, possible or low. After deciding the likelihood that an injury could occur, the assessment will then indicate the potential seriousness of any injury or illness that may result. The PPE Hazard Assessment then indicates the type of required PPE selected to provide protection for our employees.

In work areas or job classifications that expose the employee to hazards, our company management team will:

select PPE based upon the hazard assessment

communicate PPE selection decisions to affected employees

select PPE which properly fits each affected employee

require employees to wear PPE to avoid injury

not allow the use of defective or damaged PPE

Workplace Hazard Assessment Certification:

The Safety Management team will generate and certify (sign and date) a document of hazard assessment that is included in this program. The hazard assessment will serve as written certification identifying the work places evaluated, the person responsible for verifying that the evaluation was performed, and the dates of the hazard assessment.

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Employee Training:

Our company is committed to providing training to each employee who will be required to use PPE. The requirement for using PPE will be determined by the hazard assessment. Each affected employee will be trained to know at least the following:

when PPE is necessary

what PPE is necessary

limitations of PPE

how to properly put on, take off, adjust, & wear PPE

proper care, maintenance, useful life, & disposal of PPE

Before being allowed to perform work requiring the use of PPE, each affected employee will demonstrate an understanding of the training they receive. It is our company’s responsibility to verify that each affected employee has received and understood the training through a written certification containing the name of each employee, date of training, and subject matter covered during the training.

Employee Retraining:

Affected employees will be retrained when management feels they no longer have the understanding and skill required by this program. Circumstances where retraining is required include, but will not be limited to:

changes in the work place that render previous training obsolete

changes in the types of PPE to be used which render previous training obsolete

inadequacies in an affected employee's knowledge or use of PPE which demonstrates the employee has not retained the requisite understanding or skill

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Eye and Face Protection

Eye and face protection used by our employees will comply with ANSI Z87.1-1989. The Safety Manager will verify that PPE utilized at our facility will meet the criteria stated by the American National Standards Institute. This criterion is included in below for reference.

IMPACT

TYPES OF WORK

Chipping, grinding, machining, masonry work, riveting, and sanding

HAZARD EXPOSURE

Flying fragments, objects, large chips, particles, sand, dirt, etc.

RECOMMENDEDPROTECTION

Spectacles with full, half, or detachable side shieldsSpectacles with non-removable lenses or lift front lensesCover goggles with indirect or direct ventilationCup goggles with direct or indirect ventilationSpectacles with a temple headband, or For severe exposure, add a face shield

Note: Care shall be taken to recognize the possibility of multiple and simultaneous exposure to a variety of hazards. Adequate protection against the highest level of each of the hazards must be provided.

Note: Face shields shall only be worn over primary eye protection.

Note: Persons whose vision requires the use of prescription (Rx) lenses shall wear either protective devices fitted with prescription (Rx) lenses or protective devices designed to be worn over regular prescription (Rx) eyewear.

Note: Wearers of contact lenses shall also be required to wear appropriate covering eye and face protection devices in a hazardous environment. It should be recognized that dusty and/or chemical environments may represent an additional hazard to contact lens wearers.

Note: Non-side shield spectacles are available for frontal protection only.

LIMITATIONS These do not provide unlimited protection.

Note: Caution should be exercised in the use of metal frame protective devices in electrical hazard areas.

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DUST

TYPES OF WORK

Woodworking, buffing, general dusty conditions

HAZARD EXPOSURE

Nuisance dust


Cover goggles with indirect or no ventilationCup goggles with indirect ventilation

LIMITATIONS Atmospheric conditions and the restricted ventilation of the protector can cause lenses to fog. Frequent cleaning may be required.

CHEMICAL

TYPES OF WORK

Acid and chemicals handling degreasing, plating

HAZARD EXPOSURE

Splash, irritating mists


Splash - Cover goggles with indirect or no ventilation Cup goggles with indirect ventilation For severe exposure add face shields

Irritating mists - Cover goggle with no ventilation

LIMITATIONS Splash - Ventilation should be adequate but well protected from splash entry

Irritating mist - Note: Face shields shall only be worn over primary eye protection

BEWARE OF Spectacles, welding helmets, hand shields

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HEAT

TYPES OF WORK

Furnace operations, pouring, casting, hot dipping, gas cutting, and welding.

HAZARD EXPOSURE

Hot sparks, splash from molten metals, high temperature exposure

RECOMMENDED PROTECTION

Hot sparks - Spectacles with full, half, or detachable side shieldsSpectacles with non-removable lenses or lift front lensesCover goggles with indirect or direct ventilationCup goggles with direct or indirect ventilationSpectacles with a temple headband, or For severe exposure, add a face shield

Splash from molten metals - Face shields worn over cover goggles or cup goggles, both for indirect ventilation

High temperature exposure - Screen face shields, reflective face shields

For all three types:

Note: Operations involving heat may also involve optical radiation. Protection from both hazards shall be provided.

Note: Face shields shall only be worn over primary eye protection.

LIMITATIONS Spectacles, cup and cover type goggles do not provide unlimited facial protection.

Note: Operations involving heat may also involve optical radiation. Protection from both hazards shall be provided.

BEWARE OF Protectors that do not provide protection from side exposure.

OPTICAL RADIATION

Electric Arc Welding

TYPES OF WORK AND HAZARD

Electric arc welding

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Welding helmet that is hand held

Welding helmet with a stationary window

Welding helmet with lift front

Note: Welding helmets or hand shields shall be used only over primary eye protection

Typical Filter Lens Shade 10-14

LIMITATIONS Protection from optical radiation is directly related to filter lenses density. Select the darkest shade that allows adequate task performance

Note: Filter lenses shall meet the requirements for shade designations in Table 1.

BEWARE OF Protectors that do not provide protection from optical radiation.

Note: Filter lenses shall meet the requirements for shade designations in Table 1.

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OPTICAL RADIATION

Gas Welding, Cutting, Torch Brazing


Gas welding, cutting, torch brazing


Cup goggle with direct or indirect ventilation

Spectacle with headband temple

Cover welding goggle with indirect ventilation

Welding helmet with stationary window, lift front, or that is hand held

Face shield

Typical filter lens shade for:

Gas welding 4-8

Cutting 3-6

Torch brazing 3-4

LIMITATIONS Note: Face shields shall only be worn over primary eye protection.

OPTICAL RADIATION

Torch Soldering


Torch soldering


Spectacle with half, full, or detachable side shields

Spectacle with no-removable lens or lift front

Face shield

Typical Filter Lens Shade 1.5 - 3

LIMITATIONS Note: Face shields shall only be worn over primary eye protection.

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OPTICAL RADIATION

Glare


Glare


Spectacle with no or half side shields

Note: Welding helmets or hand shields shall be used only over primary eye protection.

Note: Non-side shield spectacles are available for frontal protection only.

LIMITATIONS Shaded or special purpose lenses, as suitable

Note: Refer to Section 6.5, Special Purpose Lenses

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Hazard Assessment Results for Eye and Face Protection:

On the basis of the certified hazard assessment on file with this program, eye protection will be used while performing the job functions listed below:

Work Area Job Function

Each employee in these work areas will use eye and face protection when exposed to eye or face hazards from flying particles, hot objects, injurious chemicals, liquid acids and caustics, gases, vapors, or potentially injurious light radiation.

Eye protection will provide side protection when there is a hazard from flying objects. Affected employees requiring prescription lenses shall wear eye protection that incorporates the prescription in its design. Employees with prescription requirements may wear eye protection that can be worn over the prescription lenses without disturbing the proper position of the prescription lenses or the protective lenses.

Eye and face protection used by our employees will be distinctly marked to facilitate identification of the manufacturer.

Employees involved in welding, cutting, or brazing, shall use equipment with filter lenses that have a shade number that will provide protection from injurious light radiation. The following table should be used to determine the appropriate shade numbers for various operations.

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Filter Lenses For Protection Against Radiant Energy

Operations

Electric Size

1/32 in. Arc Current

Minimum

Protective Shade

Shielded metal arc welding

Less than 33-55-8More than 8

Less than 6060-160160-250250-550

781011

Gas metal arc welding and flux cored arc welding

less than 6060-160160-250250-500

7101010

Gas Tungsten arc welding

less than 5050-150150-500

88

10

Air carbon Arc cutting

(Light)(Heavy)

less than 500500-1000

1011

Plasma arc welding less than 2020-100100-400400-800

681011

Plasma arc cutting

(Light(Medium)(Heavy)

Less than 300300-400400-800

8910

Torch brazingTorch solderingCarbon arc welding

3214

Filter Lenses for Protection Against Radiant Energy

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Operations Plate thickness--(in.)

Plate thickness--

(mm.)

Minimum

Protective Shade

Gas Welding: Light Medium Heavy

Under 1/81/8 to 1/2Over 1/2

Under 3.23.2 to 12.7Over 12.7

456

Oxygen cutting: Light Medium Heavy

Under 11 to 6Over 6

Under 2525 to 150Over 150

345

Head Protection

Head protection used by our employees will comply with the American National Standards Institute (ANSI). The program administrator will verify if head protection is required at our facility and, if so, the program administrator will select head protection that meets the criteria stated by the American National Standards Institute. This criterion is included in this section of the program for reference.

Protective Headwear Types and Classes

Helmet Types

Type 1 - Type 1 helmets shall have a full brim.

Type 2 - Type 2 helmets have no brim but may include a peak.

Helmet Classes

Class A - Class A helmets are intended to reduce the impact force of falling objects and to reduce the danger of contact with exposed low-voltage conductors. Representative sample shells are proof-tested at 2,200 volts (phase to ground).

Note: This voltage is not intended to be an indication of the voltage at which the headgear protects the wearer.

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Class B - Class B helmets are intended to reduce the impact force of falling objects and to reduce the danger of contact with exposed high-voltage conductors. Representative sample shells are proof-tested at 20,000 volts (phase to ground).

Note: This voltage is not intended to be an indication of the voltage at which the headgear protects the wearer.

Class C - Class C helmets are intended to reduce the impact force of falling objects. This class offers no electrical protection.

Protective Headwear Materials

All materials used shall conform to the requirements of this standard. All materials that come in contact with the wearer's head shall be those generally known to be nonirritating to normal skin.

Hazard Assessment Results for Head Protection:

On the basis of the certified hazard assessment on file with this program, head protection will be used while performing the job functions listed below:


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Foot Protection

Where necessary, employees will wear safety shoes to protect them from foot injuries that may occur due to recognized hazards in the work area.

Safety shoes or boots with impact protection will be required for persons who carry or handle heavy objects. Heavy objects could be dropped, potentially causing serious injury. Other activities will be included where objects might fall onto the feet or where other exposures may occur, causing injury. The safety shoes used by our employees will be obtained from a supplier that can provide shoes that comply with the test requirements noted in ANSI Z41-1991.

Hazard Assessment Results for Foot Protection:

On the basis of the certified hazard assessment on file with this program, eye protection will be used while performing the job functions listed below or in the following work areas:


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Hand Protection

When it is determined by the hazard assessment that employees are exposed to potential hand injuries, personal protective equipment will be worn. Hand protection will be utilized to prevent cuts, abrasions, burns, and skin contact with chemicals that are capable of causing local or systemic effects following exposure. Performance characteristics of gloves relative to the specific anticipated hazard will be identified by the Safety Chairperson and used as the basis for selection. The most effective hand protection will be selected for each job function.

Hazard Assessment Results for Hand Protection:

On the basis of the certified hazard assessment on file with this program, eye protection will be used while performing the job functions listed below:


Respiratory Protection

When employees are required to wear respiratory protection, the Safety Management team will verify that requirements of the respiratory protection standard have been fulfilled. Persons required to wear respirators will be identified in the Respiratory Protection Program. Proper selection of respirators will be indicated based upon the respiratory hazard. Medical evaluations will be provided to all persons required to wear respirators and fit testing will be done to ensure all will achieve a proper face to face piece fit. Equipment inspection, maintenance, and proper storage practices will be observed. And employees expected to wear the equipment will be properly trained.

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Hazard Assessment Results for Respiratory Protection:

On the basis of the certified hazard assessment on file with this program, eye protection will be used while performing the job functions listed below or in the following work areas:


Personal Protective Equipment - Cleaning & Maintenance

Personal protective equipment will be kept clean and in effective working condition. Cleaning is particularly important for eye and face protection where dirty or fogged lenses could impair vision.

Our company is responsible for assuring the adequacy, proper maintenance, and sanitation of personal protective equipment. Methods will be designed to regularly clean, inspect, and replace equipment to ensure the safety and health of our employees. Employees will be instructed to notify their supervisor when personal protective equipment becomes lost, damaged, or in need of repair or replacement. Facilities for cleaning safety glasses and head protection will be provided and employees will be instructed to maintain their equipment. Periodic review will be made during work hours to assess the condition of personal protective equipment.

Respirators will be cleaned and inspected on the frequency indicated in our Respiratory Protection Program. Documentation indicating cleaning, repair, and replacement of respirators will be kept in this program file.

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Hazard Assessment Formfor Personal Protective Equipment Selection

Work Area: Date of Hazard Assessment: Job Function: Hazard Exposure: Person Conducting Hazard Assessment: (Name and Job Title)

Person Authorized to Certify Hazard Assessment: ______ (Name and Job Title)

CATEGORY

POTENTIAL

(High, Possible, Low)

SERIOUSNESS OF POTENTIAL

(High, Medium, Low)

PERSONALPROTECTIVEEQUIPMENT

Impact Sources:Struck by or strike against

Penetration Sources:Sharp objects that pierce or cut

Compression (roll-over):Rolling or pinching

Chemical sources:Handling of injurious chemicals

Heat Sources: High temps. resulting in burns, eye damage, and ignition of protective clothing

Harmful Dust Sources:Airborne contamination

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Light (optical) Radiation Sources:Welding, cutting, brazing, high intensity lights

Reassessment of Hazards

The Safety Management team for our facility will reassess the workplace hazard situation as necessary by identifying and evaluating new equipment and processes, reviewing accident records, and reevaluating the suitability of previously selected PPE. Each certified reassessment will be kept on file with this program for verification.

OSHA 200 LOG INJURY REVIEW

Review Date:

Next Review Date:

Type Locations Total

Eye injuries

Face injuries

Head injuries

Hand injuries

Foot injuries

Respiratory disorders

FIRST AID INJURY REVIEW

Review Date:

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Next Review Date:

Type Locations Total

Eye injuries

Face injuries

Head injuries

Hand injuries

Foot injuries

Respiratory disorders

TRAINING LOG

PERSONAL PROTECTIVE EQUIPMENT

NAME OF TRAINER: DATE OF TRAINING:

EMPLOYEE NAME

(print)

EMPLOYEE NAME

(signature)

DEPARTMENT

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Vehicle Accident Packet Checklist

OVERVIEW

1. Report all accidents, no matter how slight, immediately to your supervisor and start filling out your Vehicle Accident Packet.

2. Obtain necessary information from other party. You are requiredto use your Vehicle Accident Packet at the scene of the accident.

Auto/Auto

a) Driver’s name, address, and telephone numberb) Name and telephone number of driver’s insurance companyc) Year, make, and model of card) License plate numbere) Description of damagef) Description of injuriesg) Name and telephone number of any Witnessesh) If the police arrive: Obtain Officer’s Name and the Police Report Number

Fixed Object/Landscape

a)Name, Address, and Telephone Number of Owner/Manager

b) Exact Location of Accident

c) Description of Damage

d) Name and Telephone Number of any Witnesses

3. Take pictures of accident scene:a) Take a picture of the entire scene, using all exposures availableb) Pictures are mandatory! If no pictures are taken this could be a terminating offensec) Take pictures of damage/no damaged) Look for skid markse) Power lines-Take a picture of where the line connects to pole or building

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4. Complete a Vehicle Accident Report (Report is located in dispatch office) using the information obtained from the Vehicle Accident Packet (your assigned). This report must be completed with a supervisor prior to leaving at the end of your shift without fail.

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Vehicle Accident ReportDRIVER INFORMATION

Driver’s Name Date of Birth Sex Date of Accident/ Time of Accident

AM PM

Driver’s Address Driver’s License No. State

Date of Hire No. HRS. on Job SSN Driver’s Home Phone Time employee began work

AM PM

Approximate Speed Were Authorities Contacted Police Report Number

Exact Location of Accident, If a customer name of customer, phone # and address:

Tractor Number Trailer Number Were there any Injuries?

Detailed Description Of Accident (use back of sheet if needed)

SSMC Produce driver wearing seat belt? Other Driver(s) wearing seat belt?

What types of chemicals were spilled due to accident? What Quantity? Was HazMat Called?

SSMC VEHICLE #____

Year Make Model VIN Plate#

Supervisor’s Name Trailer Year, Make,Model VIN

OTHER VEHICLE OR PROPERTY DAMAGE

Describe Property or Vehicle (if auto. YR., Make, Model, Plate No) Insurance Agency Name & Policy No.

Other Party’s Name Business Phone Residence Phone

Other Party’s Address Customer Yes No

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Other Driver’s Licence No. Describe Damage Estimate Amount Where Can Vehicle Be Seen?

Name of Employee Completing Report:

Date of Report: Who is Driver’s Supervisor?

INJURED

Name and Address SSN Phone Date of Birth

SSN Phone Date of Birth

WITNESSES OR PASSENGERS

Name and Address SSN Phone Date of Birth

SSN Phone Date of Birth

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INDICATE BELOW THE EXACT LOCATION, AT THE TIME OF THE ACCIDENT, OF OUR VEHICLE AND ANY OTHER VEHICLE INVOLVED.

SHOW MEASUREMENTS IF POSSIBLE.

Accident Call Record

- INCOMING CALL ~ ASK IF PICTURES HAVE BEEN TAKEN!!-

Drivers Name: ______________________________

Date of Accident: _______________________ Time of Accident: ________________ am pm

*Fatality(ies)/Serious Accident? ____________ If Yes, notify ____________, at ________________,

Your TPA at _______________, and your regional safety manager __________________, at ________________.

Equipment Number: Tractor_____________ Trailer _________________ Bobta. __________________

Person Calling: _________________________ Time Called: _______________ am pm

Other Party’s Information:

Name: _____________________ Phone#: _________________ Drivers Lincese#: ________________________

Address: ____________________________________ Insurance Policy#: _________________________________

Type of Accident: ( ) Auto/Auto ( ) Fixed Object ( ) Landscape

Brief Description of Accident: ( ) Minor ( ) Major

_______________________________________________________________________________________________

Exact location of Accident Name and Address:_______________________________________________________

Number of vechicles involved: __________ SSMC Vehicle: _____________________________

Damage to Product? : ____________ Damage to Vehicle? : _________ Damage to property of others? :_________

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Description of Damage:__________________________________________________________________________

Police Called? :________ **SSMC driver ticketed? :______ Other driver ticketed? :____________

**Any Vechicle Towed? :_____ *Fatality? :______ **Injuries? :______ How Many: _____ Who: __________

Ambulance called? :__________ Anyone taken to hospital? :___________ Who? :________________________

Anyone treated at scene? :_______ Who? :__________________________

Who was dispatched to scece from SSMC? :_______________________________

Report Received by: _____________________________ Date/Time: _________________________

*IF YES TO FATALITY, DRIVER MUST HAVE A DOT DRUG/ALCOHOL SCREEN IMMEDIATELY.

** IF YES TO EITHER PARTY TICKETED AND AY VEHICLE TOWED AND/OR INJURIES THAT REQUIRE IMMEDIATE TREATMENT AWAY FROM SCENE, CONTACT YOUR

MANAGER OR SAFETY MANAGER AFTER TAKING INCOMING CALL SHEET REPORT.

Transportation Investigation Report

Employee’s Name : __________________________________ Accident Date: __________________

Occupation: Delivery Driver Delivery Driver Hostler

(local) (domicile)

Date Accident Reported:________________ Time Reported: __________ am pm

Normal Days Employee Works During Week (circle) Su M Tu W Th F Sa

Name Of Witnesses:__________________________________________________________________

Exact Location of Accident NAME, PHONE # AND ADDRESS OF OTHER PARTY:

_________________________________________________________

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______________________________________________________________

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Accident Evaluation

Complete Description of Accident:

_______________________________________________________________________________________

_______________________________________________________________________________________

_______________________________________________________________________________________

Description of Equipment or Property Damaged:

_______________________________________________________________________________________

_______________________________________________________________________________________

_______________________________________________________________________________________

Equipment Number: _____________________ Did Equipment malfunction? Yes No

Malfunction was immediately tested by: ____________________________________

Test noted the following:

Was Drug Alcohol Screen Performed? Yes No If no explain: _________________________

Supervisor pulled manifest!? Yes No If no explain: _____________________________

Were photos taken of the accident scene/damage? Yes No If no explain: ____________________

Retest for Certification-PTD course: Yes No Re-evaluation: Yes No

I, _____________________, have completed Module _____, ___________________________, on the

Professional Truck Driving Course.

Name: ______________________________ Date: ____________________________

Signature: _______________________________ Supervisor: _______________________________

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The Safety Benchmark Report

The Safety Benchmark report is a tool used to measure each individual Operating Company’s safety performance, as well as that of the entire corporation. The report is produced by Risk Management Operations of the Corporate Treasury Department and distributed by SYSCO’s Safety Department. The report is generated on a monthly basis and is available at:

http://intranet2.sysco.com/riskManagement/benchmark_report.htm

This report is a very important report for all Safety Managers. This will compare your Operating Company against the entire corporation, and is viewed by all upper management. Review is done of this report on a monthly conference call. Safety Managers from all SSMC Operating Companies are required to participate in this monthly conference call. Mark Wooten, Director of Safety and Claims for SYSCO is in charge of these calls. This call is intended to create a forum to discuss the current Benchmark report, and to talk about any issues that may have arisen during the previous month.

The following documents will give you an idea of how to read the Benchmark Report and the pages of the monthly report that pertain to SSMC are also attached. The above website also contains a presentation that will give you a better understanding of the Safety Benchmark Report. As stated earlier in this manual, the SYSCO safety website: http://bbp.sysco.com/sites/Safety/default.aspx contains all the necessary information needed to create and maintain a exemplary safety program.

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http://bbp.sysco.com/sites/Safety/default.aspx

http://intranet2.sysco.com/riskManagement/benchmark_report.htm

ssmcsafe safety reference manual

Documents