bp sdeis app l site specific hsse cape vincent

8/7/2019 BP SDEIS App L Site Specific HSSE Cape Vincent

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Cape Vincent Wind Energy ProjectProject Number: 0057356Date 12/5/2007

Revision 0 1 0092352\A4363 App L - Site Specific HSSE.doc

Site Specific

Health Safety Security &Environmental (HSSE) PLAN

For BP Alternative Energy

Cape Vincent

Wind Energy FacilityProject No. 0057356

Rev 0

12/7/2007


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Table of Contents

1. Zero Injury Safety Policy1.1 Performance Measurements1.2. Policy

1.3. Zero Injury Program Checklist1.4. Implementation of Zero Injury Techniques1.5. Safety Committee

2. Responsibilities ofBP Alternative Energy2.1. Corporate2.2. Project Safety Coordinator2.3. Project Manager2.4. Superintendent2.5. Foremen2.6. Employee Safety Responsibilities

3. Responsibilities of Subcontractors3.1. Subcontractor Pre-Mobilization Safety Review3.2. Subcontractor Safety Responsibilities3.3. Subcontractor Emergency Plan - Area Map3.4. Subcontractor Safety Questionnaire3.5. Subcontractor Safety Hazard Notification

4. Orientation / Training4.1. Orientation / Training #14.2. Orientation / Training #24.3. Orientation / Training #34.4. Landowner Orientation

4.5. New Employee / Subcontractor Orientation Log

5. Safe Work Programs5.1. Substance Abuse Policy (Non-DOT)5.2. Hazard Communication / Right-to-Know5.3. Hazardous Materials5.4. Hazard Communication Training Log5.5. Fire Protection and Hot Work Permits5.6. Lock Out / Tag Out / Check Out5.7. Fall Protection5.8. Respiratory Protection Program5.9. Voluntary Respirator Use Form

5.10. Confined Space Program(a) Confined Space Checklist(b) Confined Space Classification Table

5.11. Scaffold Standards5.12. Blood Borne Pathogens5.13. Electrical5.14. Environmental


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5.15. Snake / Insect Bites and Dangerous Animals5.16. Project Signs

6. Accident / Incident Reporting Procedures6.1. Site Security

7. Disruption Avoidance

8. Stretching Program

9. Severe Weather

10. Additional Policies and Procedures


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1. Safety Performance Measurements andZero Injury Safety Policy

1.1 Safety Performance Measurements

BP Alternative Energy (BPAE) have established the following goals tomeasure the success of safety performance at the Cape Vincent project:

1. Total Recordable Incidence Rate (TRIR) 2.02. Lost Time Incidence Rate 0.0

TRIR is a standard OSHA measurement based on 200,000 man hours of

work. The Lost Time Incidence Rate, also known as Days Away FromWork Case (DAFWC) is not an OSHA measurement. It describes theincidence rate of injury resulting in lost time and is also based on 200,000man hours of work.

In support of these goals the following leading indicators will be utilized:

1. Measure the effectiveness of Pre-Task Planning by scoringeach foremans card daily

2. Near Miss / Hazard Recognition reporting with real timetrend analysis and reporting to the project team

3. Investigate all property damage and vehicle damageincidents with reporting to the project team

4. Perform work observations on a scheduled basis to includeall subcontractors of every tier with the results reviewed anddistributed through the Site Safety Committee

5. Perform daily safety assessments with results andopportunities communicated daily at the POD meeting

While the TRIR goal is 2.0, the project team will strive to achieve ZeroInjuries.


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1.2 Policy

BP Alternative Energy is committed to eliminating workerinjury at every project site and every work place. Allemployees are empowered as follows:

1. To conduct their work in a safe manner.

2. To stop work immediately to correct any unsafecondition that is encountered.

3. To take corrective action so that work may proceedin a safe manner.

It is the Companys goal and expectation that no one willsuffer an injury in the execution of our work.

This safety plan captures the Zero Injury culture and the actionable processes which are

expected of every BP Alternative Energy project team member including subcontractors

and customers. To empower every person covered by this plan I pledge with out

qualification, my commitment to worker and work place safety and affix my signature

below as proof.

Signature


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1.3 Zero Injury Program Checklist

Project Name: Cape Vincent Wind Project Date:Project Manager: Project Supt:

Yes No

Project Start-up Kit

Pre-Job Hazard Analysis

Orientation-Project Wide-First Day, First Hour

Second Orientation - Project Wide - By End of Second Week

Third Orientation - Project Wide - By End of Fourth Week

Daily Stretch Program - Project Wide

Daily Pre-Task Planning & Training - Project Wide

Near Miss Reporting

Near Miss & Accident Investigation Team & Procedure

All High Risk Activities Identified and Updated

Safety Critical Submittals Tracked

Lift Plans for All Critical & Engineered Lifts

Training Schedule Published

Monthly Project Wide Safety Meetings

Daily / Weekly Tool-Box Talks

Daily / Weekly Safety Audits

Project Safety Leadership Team (Committee)

100% PPE-Project Wide-Safety Glasses, Hard Hats, Hi-Vis Vests

Subcontractor Pre-Qualification & Updated Safety Statistics

Pre-Employment/Post-Incident Prohibited Substance Screening

Attach copies of meeting minutes, forms, logs, reports, etc.NOTE: Submit this checklist along with attachments to Energy Group Director, Safety &Quality with Monthly Reports.

1.4 Initial Implementation of Zero Injury Techniques

The Environmental Health & Safety Services Group has asked for the full support andcooperation of the Leadership Team of each operating group in implementing theattached Zero Injury Safety Policy. Further, the Environmental Health & Safety ServicesGroup empowers every manager and supervisor to proceed with implementation of thoseZero Injury techniques appropriate to each project. These techniques should be included


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in job-site safety programs as quickly as possible, while maintaining quality of the effort.Safety professionals will be available to assist with our commitment to support fieldoperations in our Zero Injury initiative.

All workers engaged on our projects shall be advised during safety orientation sessionsthat it is BP Alternative Energys expectation that there be NO INJURIES. All workersshall understand they are empowered to stop the work any time a risk of injury isrecognized, and that they shall immediately report any unsafe condition or take correctiveaction personally. Managers and supervisors must investigate every accident or nearmiss, and initiate changes that will eliminate the possibility of recurrence.

Achieving our goal of an injury free workplace mandates that we communicate to ourworkers our commitment to Zero Injury, and then ask the workers what help and supporttheir need to work in a manner that prevents injury.

Some of the techniques will require formal action by the Environmental Health & SafetyServices Group to provide proper legal and technical support. There are a number oftechniques that we can begin implementing immediately. A prioritized listing of some ofthese techniques follows:

I. Pre-project/Pre-task Safety Planning:

The Energy Group has formed a Safety Leadership Team headed by the group vicepresident. This Team functions as the implementation, coordination and prioritizing teamfor the group. The Team meets to analyze progress toward the Zero Injury commitmentand to set group Zero Injury technique implementation goals. The Team willcommunicate line managements responsibility and accountability for worker safety.

The Cape Vincent Wind Energy (Cape Vincent) project will establish a project safetycommittee for the purpose of coordinating project safety matters. Membership of theproject safety committee shall include BP Alternative Energy and subcontractors. Theproject will establish an accident review team, led by the project manager. This group willbe the initial response team for all accidents, incidents, including environmental incidents

and near misses, and is responsible for the investigation and reporting on all incidents.

A complete project safety analysis will be performed by the project manager andsuperintendent prior to beginning work in the field. Safety technique implementationgoals will be established. Job hazards and special conditions will be identified to identifyspecial safety requirements or conditions. Group safety professionals will assist in thiseffort.

The project schedule will be developed in contemplation of creating safe workingconditions. This applies to the project schedule, as well as short interval schedules.


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Pre-task safety planning will be completed by all foremen and trades people prior tobeginning any new task assignment. Pre-task Planning cards will be used in thisplanning process.

Subcontractors pre-qualification must include an assessment of safety performance andsafety program content. All subcontractors must have programs similar to Zero Injury tobe considered qualified to work on a BP Alternative Energy project. Subcontractors whoare not cooperative with our safety initiative will be excluded.

II. Safety Orientation and Training: BP Alternative Energy

Formal classroom safety training for project managers, engineers, accountants andadministrative staff, foremen and craft workers will be implemented for the project team.This includes BPAE and BPAE subcontractors of every tier and all visitors. Formal on-site First Day, First Hour Orientation is required of all persons prior to admittance to thework site.

All employees will receive safety orientation prior to their first work assignment (First Day,First Hour). The orientation must include an explanation of our commitment toeliminating worker injury and that employees are empowered to stop work any time an

unsafe condition is recognized. Production or schedule will never take precedence overworker safety. Second orientation will occur 2 weeks after hire date and third orientationwill occur 4 weeks of hire date for all above listed personnel. For details on orientationsee sections 3 and 4.

III. Drug and Alcohol Abuse Program:

Studies have proven that a high percentage of accidents on construction sites involveworkers under the influence of alcohol or other controlled substances. Therefore, anAlcohol and Substance Abuse Testing Program will be implemented on the project. Theprogram will include pre-employment screening, post-accident / incident testing andrandom employee testing, and is outlined in detail in Section 5.1.

IV. Incident Investigation:

All incidents must be promptly reported using a First Incident Report form. This willprovide information to the proper parties to facilitate a coordinated and appropriateresponse. Incidents include; personal injury and property damage accidents, near missevents where personal injury or property damage did not occur but could have, hazardrecognition and events with an environmental component.

Investigations of all incidents will occur as soon as practical with formal documentationand reporting to the Environmental Health & Safety Services Group, Energy Group andBP Alternative Energy. Toolbox safety meetings will be used to review incidents. Thesetalks will discuss actions taken to prevent any future occurrences. Incident investigationreports must include an explanation of the cause and preventive action taken.

The project team will collect Subcontractor man hour and worker injury safety statisticsrelated to our project. This information, along with BP Alternative Energy man hour,miles and workforce safety statistics will be reported to the group Director of Safety &Quality and BP Alternative Energy site representative by the fifth of each month.

Accident / Incident reporting procedures are outlined in detail in Section 6.


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V. Safety Recognition

Plan Provisions: A program of safety recognition, with appropriate incentives, will bedeveloped as appropriate for a project.

Eligible Participants:

VI. Short Service Employee Management:

The purpose of Short Service Employee (SSE) Management is to ensure that new ortransferred BP Alternative Energy employees, contractors and subcontractors areidentified, appropriately supervised, trained and managed in order to prevent injury tothemselves or others, property damage or environmental harm.

The intention of the SSE Program is to identify and manage those individuals who arerelatively new to the work in which they will be engaged. These individuals should beassisted in their growth and knowledge on matters pertaining to HSSE. This includes butis not limited to:

Viewing of the BP Immersion Series (Inclusion to SSE program is under review) Site or office HSSE British Petroleum orientation Selected HSSE training programs such as defensive driving, general safety

requirements, etc.

A Short service employee is an inexperienced worker; defined as anyone with less thansix (6) weeks of continuous employment with present employer at the current project site,or less than six (6) months in the same or similar job type with the present employer.This includes BP Alternative Energy employees, contractors and subcontractors.Vendors/suppliers that do not perform any work activities at the project site other thanroutine pick up and delivery are excluded.

While on site locations, a hard-hat sticker with the letters, SSE-Please Help Keep Me

Safe should be incorporated as part of assigning new-employees to a location. This willassist in readily identifying new employees who may need assistance or guidance inlearning site specific HSSE policies, standards and procedures.

Superintendent Responsibilities:

ensure that a formal on-site safety orientation is developed and implementedat the site. Ensure this orientation is provided to the SSE by aknowledgeable, experienced employee prior to SSEs initial workassignment.

assign a mentor to the SSE from among the experienced crew members thathas proper operations knowledge and skills and displays the appropriatesafety leadership and work ethic

conduct an HSE performance review with the SSE after 4 weeks,

documenting progress to date and areas in need of continued improvement,counseling SSE on areas for improvement (NOTE: Contractors shall beevaluated by their own companys appropriate supervisor or foreman.)

accept responsibility for the safety of a SSE assigned to his crew or areathrough example setting and observation skills.

ensure Pre Task Planning Cards and Integrated Work Instructions (IWI) areutilized as a training tool with the SSE.


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provide daily coaching and feedback to the SSE about safe work practices. validate and document that all the above is accomplished

Mentor Responsibilities:

accept responsibility for the safety of an assigned SSE through example

setting and observation skills. teach and coach the SSE in his/her roles and responsibilities and safe work

practices for all assigned duties; review the known potential hazards for thework to be performed.

display a positive work ethic and lead HSE by example at all times. review the purpose of and how to participate in the development of a proper

pre task plan and how to utilize the integrated work instructions with the SSE. observe SSE during each task he/she performs and provide adequate

feedback by using the Safety Observation process techniques. provide prior approval for any new task initiated by the SSE. be knowledgeable of applicable HSE policies, procedures, standards and

expectations. participate in the performance review with the SSE after 4 weeks.

Mentors shall be responsible for multiple SSEs.

SSE Responsibilities:

attend first day, first hour safety orientation upon arrival at their first field

assignment and prior to performing any work and all subsequent safety

training and orientations.

learn designated roles and responsibilities; adhere to all policies and

procedures taught or shown to him/her.

learn the location and application of all emergency response equipment (fire

extinguishers, eye wash stations, emergency shutdowns, first aid kits, etc.).

actively participate in and review the Pre Task Plan and Integrated Work

Instruction for any task they are directed to perform.

seek assistance and guidance from the mentor when uncertain about any

part of the job or for a task he/she has never performed.

understand the obligation to stop work that he/she feels is unsafe or does not

understand, or when conditions have changed. when required, wear the appropriate level orientation sticker on his/her

hardhat at all times when working as an SSE. understand and clarify any concerns during performance reviews.

All SSEs shall be identified by the appropriate level orientation sticker on their hardhat.There are 3 levels of orientation numbered 1 through 3. Each sticker has a specific color:

1=Red2=Light blue3=Dark blue

All SSE personnel must attend the first day, first hour orientation #1 prior to beginningwork. Two weeks after receiving orientation #1, all employees shall receive orientation#2. Two weeks after receiving orientation #2, all employees shall receive orientation #3.


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For all SSEs, applicable Contractor and HSE policies, procedures and standards shall bediscussed, including but not limited to:

Site or area specific Emergency Response Plans, including location ofequipment/supplies

Contractor and applicable BP Safety Standards

BPs Golden Rules of Safety Job Safety Analysis purpose and process Job Observation purpose and process Worker responsibility to stop the job when appropriate Incident and Near-Miss reporting

Each SSE shall be assigned a Mentor who shall be responsible for providing individualoversight and training. The Mentor shall be knowledgeable of the appropriate BP andContractor policies, procedures and standards. No new work shall be assigned to orinitiated by the SSE without prior approval from the Mentor.

Exceptions: Office work groups may adopt the mentor process as needed to provideadequate guidance to the SSE while minimizing adverse impact to personnel

assignments and scheduling. Consideration may include, but not be limited to, assigningmore than one person to perform the specific duties of the Mentor, allowing the TeamLeader to also act as the Mentor and condensed mentoring process upon demonstrationof skills and knowledge.

The Project Superintendent shall meet with the Mentor to discuss, document andapprove the SSE's professional development after six (6) weeks of hands-on experience.Discussions can occur earlier, at managements discretion, based upon the SSEsassignments and/or individual progress. Within the first six (6) weeks, the SSE must:

demonstrate a working knowledge of the applicable site safety policies andprocedures.

demonstrate safe work practices and be receptive to constructive criticism forobserved practices.

improve or correct unsafe practices in a timely manner. apply accident prevention tools in a pro-active manner. the Team Leader and Mentor may agree upon an earlier graduation from SSE

status provided the SSE fully demonstrates all of the above criteria and hascompleted all required HSE training.

Failure to meet any of the above criteria will result in an extension of the SSEstatus (by BP approval) or a discipline process according to BP or Contractorprogressive discipline procedure, leading up to and possibly including terminationif warranted by observed unsafe performance.

Documentation shall be retained by the appropriate employer and per their retentionrequirements.


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1.5 Safety Committee

The purpose of a safety committee is to bring hourly workers and management togetherin a cooperative effort to promote safety and health on the project. The committee will beformed during project preplanning and will be active at mobilization. This group will bethe initial response team for all accidents, incidents, including environmental incidents

and near misses, and is responsible for the investigation and reporting on all incidents.

I. Committee Membership

Membership of the project safety committee shall include BP Alternative Energy andsubcontractors. The project will establish an accident review team, led by the BPAlternative Energy project manager.

The safety committee will be comprised of both hourly workers and managementemployees. No more than 40 percent (40%) of the committee may be managementemployees. Hourly workers will select representatives by peer nomination and/or votingprocess for the remaining committee member positions. There will be no less than fiveand no more than ten members on the committee at a given time. In addition, the BP

Alternative Energy site safety representative will be an ex officio member of thecommittee. Employees of subcontractors are also eligible to serve on the committee ashourly worker representatives or management representatives.

The committee will be co-chaired by an hourly worker representative and a managementrepresentative.

Members will serve on the committee for the duration of the project. If a committeemember is no longer assigned to the project, then the vacancy must be filled prior to thenext safety committee meeting.

II. Committee Duties

Team Objectives Provide a Forum for the various groups at the site/facility (BP, Contractors andSubcontractors) to meet and discuss HSSE matters that impact personnel at thelocation.

Key Outputs:Discuss and review these HSSE requirementsWork as a coordinated team to stay engaged in HSSE ManagementDiscuss emerging HSSE issues, concerns and trends.Brainstorm solutions to HSSE opportunities for improvement.Monitor key performance indicators.Identify HSSEaccomplishments and challengesVerify effectiveness of HSSE plan activities

BoundariesOfResponsibility

Have the authority to make recommendations of proposed HSSE solutionsthrough Management of Change , have authority to make or change establisheHSSE policies, processes or proceduresHave procurement authorityWork within the parameters of the project or site HSSE plan


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III. Committee Meetings and Inspections

The safety committee will meet weekly. A written agenda will be developed and meetingminutes will be kept. The committee will conduct inspections and work observationsmonthly. Results of each inspection and observation are to be documented on a ProjectSafety Assessment Form.

Any recommendations given by the committee will receive a response from the employerwithin a reasonable time limit.

IV. Work Observations

Work observations are events in which committee members observe a specific workactivity for the purpose of finding health and safety improvements to the work process. Aminimum of one work observation a month will be conducted and a written report ofobservation findings, issues and implemented solutions will be prepared.

V. Membership Entitlements

Each member will be allowed one hour to prepare for each meeting. Also, each memberwill be permitted time to attend meetings, conduct inspections, perform work observationsand carry out other duties. Members will be paid for these times at the regular properrate.

VI. Committee Postings

The following items will be posted where other required jobsite postings are located.A. A list of the committee membersB. Safety committee meeting minutesC. Safety committee inspection reports


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2. RESPONSIBILITIES OF BP ALTERNATIVE ENERGY

2.1 Corporate

BP Alternative Energy is committed to the elimination of worker injury throughout ourcompany's operations. This company-wide commitment to Zero Injury is the only logical

and humane approach to a safe workplace. We are not willing to tolerate any injury toour own workers, or to the worker of any contractor while engaged on our projects. Anylesser commitment conveys the erroneous message that accidents are inevitable andthat some level of injuries is acceptable. Meeting this challenge will take time, hard work,and will require a commitment to safety from all team members on this project.

The health and safety of BP Alternative Energy team members, contractors, and thegeneral public is the most important part of any work we do. BP Alternative Energy, andparticularly the Cape Vincent Project Team, is committed to safely constructing a qualityproject on time and within budget.

Every member of this project team has specific safety responsibilities. Theseresponsibilities begin with the Project Manager and the Superintendent and extend to the

foremen and crew levels.

Specific safety responsibilities of the project manager, superintendent, foremen, workers,and subcontractors are listed on the following pages.

All team members at the project are expected to be accountable and responsible in theirsafety commitment to a Zero Injury workplace.

The BP Alternative Energy Zero Injury Program Training Manual is incorporated byreference into this plan. A copy of our BP Alternative EnergyZero Injury Program TrainingManual has been distributed to all Project Managers and Superintendents and isavailable for review at the jobsite office.

2.2 Project Safety Coordinator

The primary responsibility of the Project Safety Coordinator is to be a resource for theProject Manager and Superintendent in the safety effort. The primary duties involvetraining/education, working directly with crews and individuals every day providing safetyleadership, motivation, guidance and correction, record keeping, reporting, and servingas a technical resource for supervisory and field personnel.

Responsibilities:

Assist Project Manager in: Researching and writing:

- Site Safety Plan

- Crisis Management Plan- Emergency Response Plan- Severe Weather Safety Plan- Other project specific safety plans as required

Attending the Project Safety Analysis Meeting. Establishing a medical provider with the assistance of the Operating Group

Safety Director.


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Assist in preparing a map of the emergency route from the project site to themedical provider.

Procurement of the Project Safety Start-Up Packet. Preparation of Safety 3-Week Look Ahead Schedule. Review and implement project start-up package. Review the safety procedures with each foreman as required.

Provide training to the craft workers on safe work procedures. Help implement the Zero Injury Program. Ensure that the Zero Injury Program is kept up to date. Use Nine High-Impact Zero Injury techniques.

Assist Superintendent with: Procuring proper safety equipment. Reviewing upcoming safety hazards and planning an appropriate safety

requirement to eliminate and/or mitigate those hazards. Instituting site specific Emergency Response Plan. Providing New Employee Safety Orientation. Conducting accident investigations. Providing care for injured employees. Help maintain contact with injured employees. Coordinate with insurance carrier. Itemize restricted duty list(s). Providing information to the Foreman for the weekly Toolbox Safety

Meetings. Attending Dailey Job-wide Safety Meetings. Execution of the SSE Management Program.

Obtain and review subcontractors: Health and Safety Manual. Job Hazard Analysis for each phase of work. Site specific work plan Material Safety Data Sheets (MSDS). Designated Safety Coordinator. 24-hour contact phone numbers. Name of First Aid and CPR trained personnel. Obtain and review MSDS sheets for all hazardous materials BP Alternative

Energy brings on site.

Other Responsibilities: Obtain minutes of subcontractor weekly Toolbox Safety Meetings. Lead weekly Safety Meeting with subcontractors Safety Coordinators, if

applicable. Conduct daily audits and notify Superintendent of results. Ensure that all daily audits are completed and signed off.

Attend weekly Subcontractor Coordination Meeting. Attend as many Subcontractor Toolbox Meetings as possible. Work with BP Alternative Energy Claims Manager on any claims. Attend and be a part of the industry safety organizations such as OSHA,

AGC, ASSE, etc. Improve personal safety education and training skills.


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Provide the mandatory Zero Injury, OSHA 30-Hour, Mobile Crane Safety,Safety Pre-Task Planning & Communication, Disruption Avoidance, AccidentAnalysis, Top Driver, Forklift Safety and First Aid/CPR training courses.

Participate as ex officio member of Site Safety Committee.

2.3 Project Manager

The Project Manager has the overall responsibility for the entire job. This includesestablishing a properly functioning project safety program, with the assistance of theGroup Director, Safety & Quality and the BP Alternative Energy Environmental Healthand Safety Services Group.

Pre-construction phase responsibilities:

Identify a medical provider from the options provided by the Group Director, Safety &Quality.

Establish: Site Safety Plan. Crisis Management Plan.

Emergency Response Plan. Severe Weather Safety Plan. Environmental plan Other project specific safety plans as required.

Ensure that all personnel know their roles and responsibilities in each plan. Periodicallyreview and update plans as required.

Conduct a project safety analysis meeting, checking plans, specifications, andconstruction methods to identify any special hazards in advance. Attendees shouldinclude, but not be limited to Project Manager, Superintendents, Foremen, ProjectEngineers, Field Engineers and Group Director, Safety & Quality.

Define and provide any general conditions safety, with technical assistance from

Operating Group and/or Corporate Safety, to include furnish, install, maintenance andremoval of all general conditions safety equipment, i.e. barricades, guardrails, PPE, etc.This includes all types of contracts including CM and Owners Representative.

Assess and document Subcontractors Safety Performance & Safety Programs includingobtaining worker injury statistics in standard OSHA reporting format.

Demand that subcontractors insurance meets contract requirements and containsadditional insured provision.

Arrange and conduct pre-construction subcontractor safety meeting identifying hazardsand verify that subcontractor safety standards meet BP Alternative Energy and OSHAstandards.

Arrange and attend Zero Injury orientation for all subcontractors prior to their start date.

Obtain the following subcontractors safety submittals: Written copy of Site Specific Safety Plan with a written Hazardous

Communication Program. A copy of all MSDS sheets for each substance used or anticipated to be

used on the project.


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Name of the designated project safety coordinator. Name of the company safety director or individual responsible for company

safety program. Emergency contacts and phone numbers Name of person(s) First Aid/CPR certified A plan for proper disposal of all substances in a manner prescribed by the

Resource Conservation and Recovery Act and/or other applicable laws andregulations.

Identify Builders Risk exposures.

Construction phase responsibilities:

Arrange for Supervisor safety training. All Supervisors should be aware of their safetyresponsibilities and have the authority to carry them out. Periodic review sessions ofthese duties shall be held.

Attend the mandatory Zero Injury, OSHA 30-Hour, Mobile Crane Safety, Top Driver,Safety Pre-Task Planning & Communication, Disruption Avoidance, Accident Analysis,Forklift Safety and First Aid/CPR training courses.

Review daily pre-task planning outlines.

Provide all safety equipment needed to complete the job.

Ensure that sufficient funds are allotted to the Superintendent to fund necessaryprograms.

Ensure that safety is the first topic discussed at all meetings.

Implement a weekly Safety Progress Meeting with all subcontractor and BP AlternativeEnergy supervisors. Note: On smaller projects this could be in addition to theSuperintendents or Owners Meetings.

Participate in the project safety committee.

Issue written subcontractor charge-back forms for cleanup and safety deficiencies.

Issue Non-Contract Compliance forms for safety deficiencies.

Consult with Safety and Legal Departments if subcontractors need to be removed from aproject due to safety issues.

Maintain an understanding of safety by reviewing safety policies, attending meetings andparticipating in other company activities designed to promote job safety.

Perform a weekly job walk to determine whether the safety of the projects could beimproved.

Conduct or attend Daily Job-wide safety meetings.

Ensure subcontractors sign waiver and indemnity forms prior to hoisting on borrowedequipment.


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Establish a Project Safety Committee for the purpose of coordinating project safetymatters. Membership of the project safety committee must include Subcontractors.

Establish and Champion an Incident Review Team. This group will be the initialresponse team for all accidents and near misses, and is responsible for the investigationand reporting on all incidents. Post incident reviews will be conducted and changesinitiated that will eliminate the possibility of reoccurrence. The team leader shall be theSafety Coordinator.

Maintain log of Subcontractors Worker Injury Safety Statistics.

Perform Pre-Project/Pre-Task planning with Subcontractors for major tasks that requirespecial safety analysis.

Conduct Pre-construction meetings with Subcontractors to review scope of work and sitesafety orientation.

Implement Pre-Employment/Post-Accident Substance Abuse Testing for all BPAlternative Energy staff.

Insure that Daily Safety Audits, Project Self Assessments and Work Observations areperformed and documented by on site BP Alternative Energy staff. Keep a record ofthese audits on site.

** See section 2.A.-10 of the Zero Injury Program Training Manual for further

responsibilities.

2.4 Superintendent

The Superintendent has primary responsibility for implementing the safety program at theproject on a daily basis.

Pre-construction phase responsibilities:Assist the Project Manager in development of a Site Specific Safety Plan.

Participate in a project safety analysis meeting, planning safety measures before the jobstarts.

Identify any special safety hazards in advance by reviewing plans, specifications andconstruction methods with technical assistance from the Operating Group SafetyDirector.

Assist the Project Manager in establishing an Emergency Response Plan.

Assist Project Manager in defining and providing for general safety conditions.

Assist the Project Manager with Subcontractor pre-construction safety meetings.

Assist the Project Manager in obtaining Subcontractors safety submittals.

Establish first aid and trauma stations.

Obtain first aid training for BP Alternative Energy field supervisors.


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Insure that all required OSHA and Zero Injury information is posted and maintained.

Arrange pre-start-up meeting with each subcontractor.

Sponsor first orientations and conduct second and third orientations for BP AlternativeEnergy and subcontractor employees.

Plan, conduct or review the daily pre-task planning outlines.

Implement the nine High Impact Zero Injury techniques.

Attend weekly and monthly safety progress meetings.

Implement and champion the daily stretching program at the site. Lead by example.

Hold daily tool box safety meetings for all BP Alternative Energy and subcontractemployees.

Ensure subcontractors hold weekly tool box meetings. Obtain copies of the minutes.

Implement and enforce compliance to a project housekeeping program. (Refer to section23.A.-1 of the Zero Injury Program Training Manual).

Enforce BP Alternative Energy employee and subcontractor safety compliance, utilizingEmployee Warning Notices (found in the Project Start-up Packet) when required.

Establish and maintain access routes for vehicle, pedestrian and emergency responsecrews.

Make sure that all safety equipment is provided and used correctly.

Immediately report all incidents to BP Alternative Energy management and the OperatingGroup Safety Director following the guidelines found in Chapter 4.B of the Zero InjuryProgram Training Manual.

Assist in investigating all accidents. If a Safety Coordinator is not on site, theSuperintendent will conduct the investigation.

Investigate and correct all unsafe conditions.

Maintain safety training requirements.

Create a constantly improving safe site environment and culture.

Oversee completion of a daily audit.

Provide for the care of the injured employee. When medical attention is required,transport injured employee to the medical facility.

Follow Workers Compensation Policy.


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Maintain contact with an injured employee.

Attend the mandatory Zero Injury, OSHA 30-Hour, Mobile Crane Safety, Top Driver,Safety Pre-Task Planning & Communication, Disruption Avoidance, Accident Analysis,Forklift Safety and First Aid/CPR training courses.

Make provisions for light duty employment.

Evaluate Foremen safety performance.

Obtain MSDS sheets for all hazardous materials brought on site by BP AlternativeEnergy, Subcontractors and suppliers, as well as maintain a Haz-Com Program. Makesure MSDS location is well known by all employees.

Verify that Subcontractors have acquired insurance, as required by contract.

Insure that disposal of all waste generated by BP Alternative Energy is disposed of inaccordance with the BP Alternative Energy Environmental Program.

Complete accident/incident reports.

Assist the Project Manager in a Project Safety Committee. Membership of the ProjectSafety Committee must include Subcontractors.

Insure that Subcontractors comply with contractual safety requirements.

Assist the Project Manager in procuring Subcontractor accident reports. Complete theWeekly Safety Activity Summary and forward copy to Group Safety Director.

Safety Audits, to be performed weekly or more frequently if required by level or type ofactivity, shall be kept on site.

Insure Pre-employment/Post Accident Substance Abuse Testing policies are followed.

Ensure execution of the SSE Management Program.

Ensure fair and consistent execution of the Zero Tolerance Policy.

** See section 2.A.-7 of the Zero Injury Program Training Manual for furtherresponsibilities.

2.5 Foremen

The foremen have direct control of their crews. This means they also have the mostdirect control of the safety program in the field. The importance of the foremen's safetyefforts cannot be overstated.


Conduct work in a safe manner.

Stop work immediately to correct any unsafe condition encountered.


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Take corrective action so that work may proceed in a safe manner.

Be an example to the crew by conducting work in a safe manner.

Attend the mandatory Zero Injury, OSHA 10-Hour, Safety Pre-Task Planning &Communication, Top Driver, Forklift and First Aid/CPR courses.

Train employees to work effectively by working safely.

Conduct weekly safety meetings to address safety problems with the crews.

Maintain safe work areas that meet company and OSHA Standards.

Report and/or repair unsafe conditions.

Perform a weekly safety audit of the site.

Assist the incident investigation team in conducting accident, injury, and near-missinvestigations and submit reports of findings. Determine cause, not fault.

Assist Superintendent in transporting injured crew members to a medical facility.

Participate in and communicate the Zero Injury Philosophy to crew members.

Complete Pre-Task Planning for each phase of the work. Review with crews and updateas necessary.

Conduct daily pre-task planning sessions each morning with crews to elicit their input andexperience in determining methods and items required.

Act as Mentor in the SSE Management Program.

** See section 2.A.-3 of the Zero Injury Program Training Manual for furtherresponsibilities

2.6 Employees Safety Responsibilities

BP Alternative Energy is committed to eliminating worker injury at every projectsite and every workplace. All employees are empowered as follows:

To conduct all work in a safe manner.

To stop work immediately to correct any unsafe condition encountered.

To take corrective action so that work may proceed in a safe manner.

It is the Companys goal and expectation that no one will suffer an injury in theexecution of our work.

BP Alternative Energy will make every attempt to insure the continued safety and healthof its employees. In return, employees are required to use good judgment and comply


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with company safety policies. Each person must accept responsibility for their own safetyby working safely and insisting that their co-workers do the same.

Specific duties include:

Arrive at work alert and ready to focus on safely performing their job. The safety of eachworker and those around the worker requires full attention.

Following safety instructions given by Supervisors.

Be on guard for unsafe conditions or activities and take action to correct and report them.If the problem can not be fixed, report it to the Foreman.

Use good judgment to provide for personal safety and for the safety of co-workers.

Use the required safety equipment.

Comply with all BP Alternative Energy policies and with state and federal OSHAregulations and good safety practices.

Wear proper clothing for the job. Basic PPE is outlined in detail in Section 4.1.

Attend BP Alternative Energy -required safety training.

Report all injuries / near misses / hazard recognitions to Supervisor immediately afteroccurrence.

Understand, support and follow the SSE Management Program.


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3. RESPONSIBILITIES OF SUBCONTRACTORS

3.1 Subcontractor Pre-Mobilization Safety Review

A clear definition of BP Alternative Energys expectations from Subcontractors must beestablished to effectively coordinate the projects overall safety plan. This section

provides an outline to be discussed with subcontractors prior to site mobilization topresent our commitment to safety as well as review conditions specific to this project.

All subcontractors of every tier are required to adhere to all HSE procedures set forth byBP Alternative Energy in the Zero Injury Program. In the event subcontractors safetyprogram is judged by BP Alternative Energy to equal or exceed the Zero Injury Program,subcontractor may be allowed to use their own program.

Present the BP Alternative Energy Zero Injury Safety PolicyExpress Management's Safety Commitment BP Alternative Energy commitment Project Staffs personal commitment

Project Overview - A brief explanation of the project's: Scope Construction type Schedule Maximum number of workers anticipated on site Owner Final intended use Unique or distinguishing features, construction methods, or hazards with your

specific work Equipment to be used on site

Project Specific Logistics Parking Work hours Entrances

3.2 Subcontractor Safety Responsibilities

All Subcontractors to BP Alternative Energy must comply with the following activities.

Pre-construction phase responsibilities:

The following submittals due prior to mobilization: Written copy of Site Specific Safety Plan with a written Hazardous

Communication Program and Emergency Plan - Area Map. A copy of all material safety data sheets (MSDS) for each chemical

anticipated to be used on the site and have a copy of it available foremployees. Name of the designated project safety coordinator. Certain subcontractors,

identified separate from this plan, will be required to designate a full timesafety coordinator.

Name of the company safety director. Emergency contacts and phone numbers. Name of person(s) First Aid/CPR certified


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A written plan for proper disposal of all chemicals in a manner prescribed bythe Resource Conservation and Recovery Act and/or other applicable lawsand regulations.

Competent persons in rigging, scaffolding, excavation, confined space, etc.Designated competent persons must have appropriate documentation.

Attend the pre-construction safety meeting with BP Alternative Energy Project Managerand Superintendent to review safety hazards specific to this project. DiscussSubcontractors role in Project Safety.

Construction phase responsibilities:The following submittals are due by 3 p.m. Friday of each week: Copies of weekly tool box meetings Copies of weekly safety audits performed Names of any competent person(s) for any construction act (i.e. scaffold,

trenching, rigging, etc.)

Provide the following submittals as described: The Contractor/Subcontractor will submit notice of an Incident or Near Miss

within 2 hours of the occurrence or first becoming aware of the occurrence.A full report describing the incident or near miss with outcome and correctiveactions will be submitted to BP Alternative Energy within 24 hours ofoccurrence or first becoming aware of occurrence.

Daily Construction Reports describing the number of workers on site andactivities performed. This report shall be submitted at the end of eachworkday.

MSDS sheets at the time of delivery of materials to the site. Any and all Crane needs along with the expected associated scope of work. Off-Hours or Weekend Work Permit 48 hours prior to date of activities.

Comply with: Applicable local, state, and federal safety standards

Safety requirements specific to project Owners project safety requirements

Actively participate in project Zero Injury safety program and attend required safetymeetings and training sessions.

Maintain first aid kits or facilities on site as required by local, state, and federal OSHAregulations.

Maintain and replace safety protection systems damaged or removed by their operations.

Install contractually required general condition safety for Subcontractors portion of thework. (i.e., handrail, fence, fall protection systems, floor opening covers, etc.)

Conduct weekly employee safety toolbox meetings and copy BP Alternative Energyjobsite office.

Participate in BP Alternative Energys safety talks and daily stretch and bend.

Conduct new employee orientations and assure that new employees receive BPAlternative Energys site orientation.


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Meet each and every element of the SSE management Program.

Subcontractors and their employees are subject to the Zero Tolerance Policy found inSection 10 of this Plan.

Provide required personal protective equipment (PPE) to subcontractors employees.

3.3 Subcontractors Emergency Plan - Area Map

I have read and fully understand the Subcontractors Safety Responsibilities. Irecognize my responsibility to comply with these rules in addition to all other

safety regulations enforced at the project. Unless otherwise noted, the secondwritten notice of violation with this agreement will result in a three-day layoff. Thethird written notice of violation of this agreement will result in the individual beingpermanently removed from the project site. The severity of the violation will resultin discipline increasing in severity.

COMPANY: _______________________________________

TRADE: _______________________________________

BY: _______________________________________

DATE: ________________________________________


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3.4 Subcontractors Safety Questionnaire

Name of Subcontractor: ___________________________________________________

Type of Work: ___________________________________ Date: __________________Current BP Alternative Energy Projects:_______________________________________

1. List key personnel. Please list safety responsible person and his/her experience:President ___________________________________________________________Vice President/Operations Manager_______________________________________Project Manager______________________________________________________Safety Coordinator ____________________________________________________

2. Do you have a written Safety Program? Yes___ No___

3. Do you provide site specific safety plans? Yes___ No___

4. Who is responsible for executing the site specific safety plans?_________________

5. Do you have a Drug/Alcohol Screening Program? Yes___ No___

6. Do you conduct pre-employment drug/alcohol screening? Yes___ No___

7. Do you conduct written safety inspections? Yes___ No___

8. Do you have an orientation program for new hires and areorientation program? Yes___ No___

9. Do you have a training program for newly hired orpromoted foremen? Yes___ No___

10. Have your foremen had OSHA 10-Hour or OSHA 30-Hour trainingin the past 3-5 years? Yes___ No___

11. Do you hold craft toolbox safety meetings? Yes___ No___

12. Are craft level employees empowered to stop unsafe acts or work? Yes___ No___

If not, explain why ______________________________________

13. Do you have a Crane Management Program? Yes___ No___

14. Do you have a Hazard Communication Program? Yes___ No___

15. Do you retain the services of an outside safety consultant? Yes___ No___

16. Have you ever been involved on a project that partneredwith OSHA Consultation? Yes___ No___

17. Do you perform incident analyses/accident investigation? Yes___ No___

What level of management reviews it? ___________ __________

18. Will you pre-qualify your subcontractors and providedocumentation to Mortenson? Yes___ No___

19. Do you support and understand a near miss reporting system? Yes___ No___

20. Do you have a Short Service Employee (SSE) Program? Yes___ No___


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21. List your firms workers compensation Interstate Experience Modification Rate(EMR) for the past three (3) years.200__ EMR ________ 200__ EMR ________ 200__ EMR ________

List your firms Total Recordable Incident Rate (TRIR) for the current and past threeyears.200__ ________ 200__ ________ 200__ ________ 200__ ________

List your firms Days Away, Restricted Duty, or Transfer Case Incident Rate (DART)for current and past three years:200__ ________ 200__ ________ 200__ ________ 200__ ________

List your firms Lost Day Incident Rate (LDI) for the current and past three years (losttime).200__ ________ 200__ ________ 200__ ________ 200__ ________

Please use your last years OSHA No.300 log to fil l in:A. Number of OSHA recordable accidents ______________

B. Number of lost workday cases ______________C. Number of restricted workday only cases ______________

Employee hours worked in the field last year ______________

Number of fatalities in your company over the last ten years. ______________

Comments:

_______________________________________________________________________

_______________________________________________________________________

_______________________________________________________________________

List any OSHA citations received in the past three years.Standard Cited Fines Paid Classification

1) ________________________________________________________________

2) ________________________________________________________________

3) ________________________________________________________________

This information is confidential and only used to determine the value of safety in yourcompany.

________________________________________Signature and Date


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3.5 Subcontractor Safety Hazard Notification

Project Name: _______________________________

Address: ___________________________________

Phone # ____________________________________

TO SUBCONTRACTOR:_________________________ Date:_____________________

Supervisor____________________________________ Project____________________

Main Office Address_____________________________ Phone____________________

IN REGARDS TO:CONTRACTOR________________________________ Phone____________________

Supervisor______________________________________________________________Main Office Address ______________________________________________________

The following unsafe actions or conditions are noted_____________________________

______________________________________________________________________

______________________________________________________________________

SUBCONTRACTOR BPAE COMPANYReceived by:_________________________ By:_____________________________

Title:________________________________ Title:____________________________

Date:________________________________ Date:____________________________

Corrective action is to be taken immediately. Note below the action taken and return toBPAlternative Energy.

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

Signed_______________________________ Date____________________________

The report of the above item is not intended to indicate that other unsafe conditions do not exist nor is itintended to imply that other violations and/or hazards not observed or reported there on are safe and undercontrol at the time of this survey. THIS DOES NOT in any way relieve you of your complete responsibility forsafety compliance with safety standards.


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4. ORIENTATION / TRAININGHSSE Orientation

All personnel will be required to complete the First Day First Hour Orientation beforegaining admittance and conducting work. The First Day First Hour Orientation shouldinclude a review of the facility layout that includes the location of life saving and

emergency equipment and everyones responsibilities in an emergency. Additionally it isintended to increase HSSE awareness by: communicating expectations, providinginformation, increasing hazard awareness, elaborating on hazard mitigations,empowering all personnel to Stop the Job and sharing lessons learned. Thisrequirement will allow for the opportunity to identify and account for all personnel,including Short Service Employees (SSE) that will be conducting work on the location.

The HSSE Orientation will include at a minimum:

Individual actions to be taken in an emergency Incident notification The site emergency response organization Muster locations and evacuation routes

These HSSE general safety rules This HSSE drug, alcohol and weapons policy SSE-Short Service Employees Control of work process Simultaneous Operations (SIMOPS) Permit to Work (PTW)

Confined Space Entry (CSE) Lock Out Tag Out (LOTO) Job Hazard Analysis (JHA) Emergency alarms/communications in the event of an emergency Elements of BPs Golden Rules of Safety Applicable BP Safety Immersions

HSSE Training

Specific HSSE training will be required for specific positions within the Project team,based on the individuals job description, roles and responsibilities and level of oversightof Contractors and/or Subcontractors. The training may include any of the following:

Safety ImmersionsAdvanced Safety AuditingHSSE Observation CardsConfined Space Entrant/AttendantConfined Space SupervisorConfined Space Competent PersonPTW OverviewPTW Performing AuthorityPTW Issuing AuthorityPTW Approving AuthorityLO/TO Overview

LO/TO Performing AuthorityLO/TO Issuing AuthorityLO/TO Approving AuthorityEnvironmental Management SystemIncident InvestigationField Industrial Hygiene MonitoringAnd various industry or OSHA approved safety courses


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4.1 Orientation #1

1. Zero Injury Safety Program

BP Alternative Energy is committed to constructing this project under safe workingconditions and doing so without any accidents. In order to assure meeting this objective,

ALL employees are required to actively participate in our program. The 9 High ImpactTechniques to our Zero Injuries Program are: (a) Pre-plan safety into all work; (b)Provide orientation and training; (c) Perform thorough accident investigations; (d) Strictlyenforce our substance abuse program; and (e) Recognize and reward safe behaviorthrough the use of incentives; (f) Near miss reporting; (g) Project Safety leadership Team Site Safety Committee; (h) Daily stretching project wide including subcontractors; (i)Job Hazard Analysis process in use. Drugs and alcohol are strictly PROHIBITED. If youare aware of these items on the job-site or of someone under the influence, pleaseprotect yourself and others by reporting them. Prescription drugs should be reported toyour supervisor so that he is aware you are using them.

Weekly safety meetings will be held on site and each employee is encouraged to offer hisor her suggestions on running a safer project, as well as pointing out any

possibility/potential safety problems he or she may have noticed in the past week.

Each employee is expected to immediately take care of any safety problems that he orshe can. If unable to take care of it themselves, employees must contact their supervisorimmediately to get the appropriate help to do so. Non-compliance with safety regulationsis grounds for immediate dismissal!

If we all work together, we can and will work accident free.

2. Zero Injuries

Review Zero Injury policy.

3. Safety & Personal Protective Equipment (PPE)

All personnel (including visitors) will adhere to these HSSE requirements while workingon this project. This requires (at a minimum) that all Contractors and Subcontractorsprovide the following items of PPE for their own use:

ANSI Z89 Hard hat with company logo front center and name immediately below.

ANSI Z 87.1 Approved Safety glasses with side shields.

Note: The use of contact lenses is discouraged in work situations where personnel areexposed to dust, chemicals or spray operations where particles may enter eyes. Contactlenses are prohibited to be worn with respirators. If medical reasons require use ofcontact lenses, special attention should be paid to additional eye protection and

supervisor approval must be given.

ANSI Z41 Approved Safety boots; all Safety Boots must have a minimum 4 upperthat is constructed of either leather or rubber that extends above the anklenosynthetic materials such as nylon or rayon are permitted. Boots must have a solethat is constructed from a slip resistant material with a defined heel; wedge solesare not permitted. Soles must have enough tread to minimize the potential for slips(under normal conditions) through maintaining sufficient friction (ANSI Z41 terms this,


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coefficient of friction) . All safety boots will be steel toed and the steel toe or cap,as it is commonly referred to, must be completely contained beneath the leather orrubber lower. Tears or holes in the material or sole are not permitted. If a tear orhole appears, the boot must be repaired or replaced before the worker reports forduty on his/her next shift. Half-measure or makeshift repairs such as the wrappingthe hole or tear with tape are not permitted.

Suitable work clothing for the environmental/meteorological conditions. Clothingmust fit closely to the wearers body. Shirts must have a 4 inch minimum sleeve .When long-sleeved clothing is worn it must be buttoned or zippered to minimize thechances of it becoming caught on objects or inside moving equipment. Wheneverslickers, coveralls or insulated clothing is worn, the legs must be buttoned or zippedand (if so equipped) the shoulder straps must be over the shoulders with the snap orbutton properly secured. Pants must be full length (no shorts).

Hearing protection with a minimum HRR of 21 shall be worn in all areas of highnoise.

Protective gloves; Gloves must be built for purpose, e.g. Nitrile for handlingchemicals, leather gloves when working with materials such as metal or steel, etc.These must be free of holes, tears or other defects that would defeat or minimize the

gloves effectiveness in offering the hand and finger protection for which it wasdesigned.

ANSI Class 2 Level 2 high visibility vest or shirt when working outside the office.

All personnel are expected to maintain and properly utilize their personnel protectiveequipment. Subcontractors will be responsible for the proper issuance, maintenance,training and utilization of personal protective equipment and other specialty safetyequipment for their employees. Subcontractor shall submit monthly, updated traininglogs for all site employees. Site management will assure through daily assessments thatall employees on Cape Vincent have the proper safety equipment available. BPAlternative Energy Employees will be issued certain items for their protection. Theseitems will be replaced at no cost if the initial item is turned in.

Replacement of lost items will be paid for by the employee at cost. Abuse andmishandling of these items could result in termination. These items consist of, but are notlimited to, rubber boots, hard hats, ear plugs, safety glasses, dust masks, faceshields, safety belts, safety vests, etc.

4. Special Safety

Training for any special safety equipment will be provided to BP Alternative Energyemployees by BP Alternative Energy, if required. Training for subcontractor employeeswill be provided by subcontractor. Make sure you are physically capable of using suchequipment. If you feel that you are not properly trained it is your duty to notify yoursupervisor. Also, explain any special safety concerns you may need to know about (i.e.gas exposure, special fire procedures, emergency evacuation, etc.)

5. Right to Know Training

Please review the Right-to-Know regulations. HAZCOM information is found in Section5.2 of this Plan. The MSDS sheets are kept at the BP Alternative Energy project office orHazard Communication location.


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6. Programs/Statements

Please review the following programs and statements: FALL PROTECTION EMERGENCY RESPONSE PLAN

EMPLOYEE SAFETY RESPONSIBILITIES HARASSMENT FREE WORKPLACE POLICY POLICY STATEMENT (EEO) EMPLOYEE ASSISTANCE PROGRAM (Lifeworks)

7. Start and Quit Times and Fatigue Program

Normal work hours are: 7:00 a.m. to 5:30 p.m. At approximately 10 minutes beforequitting time, all tools and materials should be picked up and put in their proper places.

Lunch is from 12:00 to 12:30. Work hours are subject to change at any time.

To identify and manage fatigue and its potential to impact on worker and work place

safety, BP Alternative Energy has implemented the following steps:

Whenever work occurs for 6 continuous full days, the 7th

day will be a day of rest Workers will be sent home by supervision when their work is complete not when all

others work is complete Management, safety professionals, superintendents and foremen will monitor the

status of crews during the course of the day looking for signs of fatigue and when it isfound act appropriately

Superintendents will monitor hot and cold temperatures and provide relief as isappropriate for the condition

Weather forecasting services will be employed to assist in decision making for workfor the following day. Whenever possible the decision to not work will be made at theend of the work day prior rather than the morning of the day not worked

Management, safety professionals, superintendents and foremen will observe crewsand rotate task assignments as is appropriate Management and safety professionals will ensure and facilitate openness between

craft and supervision to allow for sound decision making when craft practiceempowerment related to fatigue

8. Absent/Tardy

BP Alternative Energy Employees: Absences and tardiness are not permitted. However,in the case of one or the other a call is required, preferably by the employee personally.Excessiveness of one or the other will result in the issuance of a Warning Slip and/ortermination. In all cases, the employee should call in. The telephone number is[XXX.XXX.XXXX]

Excused absences and tardiness should be discussed and cleared with your immediatesupervisor, at least 24 hours in advance whenever possible, for scheduling purposes.

When an employee has missed work for two (2) consecutive days, without contacting hissupervisor, it will be considered a voluntary termination.

9. Telephone Messages


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No personal telephone calls except for emergencies. Emergency calls will be handledappropriately.

10. Your Personal Tools

Your foreman or supervisor will provide you with a list of tools required to perform thework expected of you. You should have a means of carrying these tools with you at alltimes.

11. Fighting

Fighting is strictly prohibited and an immediate termination will result from it. Also, anyemployee acting in a manner that seriously jeopardizes the safety of themselves oranother employee, will be subject to immediate dismissal.

12. Insubordination

All personnel shall respect the rank of Subcontractor, Foreman, and Supervisors as wellas his co-workers and other supervisors within the company.

13. Written Ticket Violations

As part of our program to insure a safe working area for each employee, we haveinstituted a written Violation/Warning Notice system. All management personnel,including foreman, are authorized to issue these warning notices. Please note that anyinfraction is cause for immediate dismissal. Reference the Zero Tolerance Policy inSection 10 of this Plan.

Disciplinary action for violation of safety or other project rules not found in the ZeroTolerance Policy: 1st Offense: Written warning

2nd Offense: Written warning and 3 day lay-off 3rd Offense: Permanent dismissal

Zero tolerance for environmental or archeological violations. This may result inimmediate termination.

** Life threatening violations may result in immediate termination.

14. Machinery and Equipment

Repairs should be made by authorized personnel only. No temporary repairs will betolerated. This includes small and large equipment. Starting and operating proceduresare different for all equipment. Check with your supervisor for instructions. Do not operate

any machinery, equipment or power tools unless you have had instructions/training andare qualified.

15. Accidents

ALL injuries, no matter how small, must be reported to your supervisor fordocumentation purposes. They must also be noted on your time card. All near misses


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are likewise to be reported and fixed immediately. BP Alternative Energy employees mustalso report near misses and injuries on your time card.

All accidents will be immediately investigated by a team of management personnel. Thiswill be done to ascertain the root cause of the accident so that similar incidents can beprevented from happening in the future.

16. First Aid

First Aid Kits are available at the BP Alternative Energy construction trailer and in all BPAlternative Energy site trucks. Other first aid kits are available at various locations on theproject. Check with your supervisor for the locations nearest you. The site safetyprofessional will prepare and publish a listing of all persons on the project that holdcurrent certification(s) for CPR / First Aid / Blood Born Pathogen Safety / AED use as wellas primary and secondary response assignments and contact means.

17. Payday

For your protection, employees must pick up their own paychecks. If unable to do so,employees may designate someone else to pick it up for them provided the employee

has signed a note requesting that another named party be given their paycheck.

18. Check List

BP Alternative Energy employees must double check to make sure that you havecompleted the following forms:

o New Employee Form (BP Alternative Energy)o W-4 Form (IRS Withholding)o I -9 Form (Eligibility Verification)o Zero Injury Booklet Formo Insurance Enrollment

19. Zero Tolerance Policy

BP Alternative Energy and subcontractor employees of every tier are subject to the ZeroTolerance Policy. This policy is reviewed in the First Day First Hour orientation. Eachemployee must indicate their understanding and acceptance of this policy by signing theZero Tolerance Policy form. Employees may keep a photo copy of the form.

20. Short Service (SSE) Policy

BP Alternative Energy and subcontractor employees of every tier are subject to the SSEPolicy (see section 1.3). This policy is reviewed in this orientation.

21. Special Driving Standard

In addition to driver training under the BP Alternative Energy Top Driver program andthe provisions of the Zero Tolerance Program, the following standards are established:

Use of cell phones while any vehicle is in operation is prohibited. Vehicles must beplaced in park before cell phone use is permitted.

Use of radios while any vehicle with the exception of cranes is in operation isprohibited. Vehicles must be placed in park before radio use is permitted.


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4.2 Orientation #2

General

1. Hold 14 days after employee starts work.2. Maximum 10 employees in a meeting. Schedule multiple sessions if necessary.

3. Chaired by key management personnel. Doesnt need to be employees directsupervisor.

4. Have signature sheet signed by all attending session. Keep on file to make sureeveryone gets orientation/training.

5. Three-week rotating schedule of attendees and trainer to be posted in conferenceroom at all times. If no employee is due for training on a specific day, session will becancelled and so noted on the schedule.

Topics:


A. Responsibility

Ask employee who is responsible for safety? Emphasize that everyone isresponsible for safety.

B. BP Alternative Energy ConcernElaborate on Zero Injury Safety Program, emphasizing that BP AlternativeEnergy is very concerned about the personal well being of each and everyemployee.

C. Employee EmpowermentExplain again that every employee is empowered to stop working if someone orsomething around him or her is unsafe. Each employee is required toimmediately fix any unsafe condition they can and to notify a supervisor to fixthings they cant. If an employee sees another employee doing something in anunsafe manner, he must express his/her concern to the other employee (keepcomments positive and constructive - avoid criticizing in a negative or demeaningmanner.)

D. Safety CultureExplain that safe people develop a mind set that when combined with otherpeople of the same mindset produces a safety culture THAT WORKS!Employees not willing to adopt the necessary safety mind set will be terminated.


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4.3 Orientation #3

General

1. Hold 14 days after orientation session #22. Maximum 6 employees in a meeting. Schedule multiple sessions if necessary.

3. Chaired by project management / supervisory personnel, does not need to beemployees direct supervisor.

4. Use sign-in sheet and keep on file.5. Three-week rotating schedule of attendees and trainer to be posted in conference

room at all times. If no employee is due for training on a specific day, session will becancelled and so noted on the schedule.

Topics


A. MotivationExplaining that the biggest motivator for the Zero Injury program is the

humanitarian concern we should all have for each other. NO ONE WANTS TOGET HURT OR TO SEE OTHERS GET HURT. If we look out for each other weCAN work with no injuries.

B. ResponsibilityExplain again that each employee is responsible for assuring that he/she worksin a safe manner. Each is also responsible to notify someone else of theirconcerns when they feel someone else is working unsafe. Remind them againthat they are empowered to stop work if any conditions are unsafe and that theyare RESPONSIBLE to fix any unsafe conditions they can, and to notify asupervisor to fix any unsafe conditions they cant.

C. IncentivesGo through incentive program thoroughly with employees.

4. Review

Briefly review New Hire Orientation/Training Session #2 and ask if there are anyquestions. Make sure everyone understands completely.

5. Employee Feedback

A. LeadershipAsk employees how well they feel their crew is following our ZERO INJURYPROGRAM. Is pre-planning being done by the crew each morning? Areemployees comfortable with this program?

B. Open DiscussionIs there anything anyone wants to add? Suggestions? Thoughts? Ideas? Orjust questions about ANYTHING?


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4.4 Landowner Orientation

BP Alternative Energys commitment to Zero Injuries starts the first day, first hour anyemployee, vendor, customer, owner, landowner, et al, joins the project. One of the keysto obtaining a Zero Injury jobsite is the orientation process. This is a requirement ofanyone wishing to be on site at any time during the duration of the project. All owners

personnel / landowners will be asked to attend an orientation session that will lay out thejobsite safety requirements, rules of safe activity, list of hazards, and HazardCommunication requirements (MSDS) prior to entering areas of construction.

BP Alternative Energy will supply all landowners with a hard hat, safety glasses, and highvisibility vest to be worn while outside their vehicles while on the project upon completionof the required orientation. It is the customer / owners responsibility to enforce the sitesafety requirements on landowners.

Prior to anyone wishing to drive out to, visit, deliver any materials, etc. it is a requirementthat the individual(s) stop in at the BP Alternative Energy trailer and check in. If anyowner / landowner wish to bring a visitor on site, it is also a requirement that they checkin at the BP Alternative Energy trailer and that visitor receive their orientation as well.

4.5 New Employee/Subcontractor Orientation Log

1 2 3 Other(Circle One)

PRINT NAME SIGNATURE COMPANY DATE


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5. SAFE WORK PROGRAMS

5. 1 Substance Abuse Policy (Non-DOT)

BP Wind Energy North America Inc. (Company) has a strong commitment to provide a

safe work place for its employees and other persons working or visiting on its premises.In order to assist in maintaining a safe working environment and to protect Companyproperty, this policy concerning substance abuse (Substance Abuse Policy) isestablished.

Contractors, subcontractors, and vendors who perform labor or services on Companypremises and projects , hereinafter referred to as Contractors, shall have andadminister a formal substance abuse interdiction policy.

The failure of a Contractor to comply with the provisions of this policy may constitutecause for cancellation of its contract.

ARTICLE I POLICY STATEMENT

a) The use, possession, concealment, transportation, promotion, manufacture,distribution, or sale of the following Prohibited Substances is strictly prohibited onCompany premises and projects, including all property owned, operated, leasedby, or under the control of Company.

b) No Contractors shall report to work, be on the job, or be on Company premisesunder the influence of Prohibited Substances.

c) No Contractors shall test positive for the presence of Prohibited Substances inamounts exceeding the cut-off levels adapted by the Company, as identified inthis Substance Abuse Policy or a Service Order.

d) No Contractors shall refuse to undergo a Prohibited Substance test required bythis policy.

e) Prohibited Substances are defined as: (a) any alcoholic beverage, the use ofwhich is not authorized by the Company, (b) any substance that an individualmay not manufacture, dispense, sell, possess, use, or distribute under the lawsof the state in which the individual is employed or is working, and (c) any otherIntoxicating Substance. Intoxicating Substance means a drug(s) or alcohol orany substance in which its use impairs work behavior or performance in amanner determined by the Company to be unsafe. Drug paraphernalia andsimilar items used for substance abuse are likewise prohibited from Companypremises and projects.

f) The Company reserves the right to report known illegal activity to law enforcementauthorities.

Contractors will submit a copy of their policy and program to the Company employeedesignated to administer contracts or to a party as otherwise designated by Company.Such policy must provide for substance testing of employees and must meet the

minimum standards as set forth in Article II below. Company reserves the right to denyentry to Company premises and projects of any Contractor who fails to present a writtenpolicy that meets the standards of this Substance Abuse Policy, or who fails to administeran acceptable policy.

A violation of this Substance Abuse Policy will subject a Contractor's employee to denialof entry to Company premises and projects. Reinstatement of the access privilege may


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be made after one year upon request of the employing contractor. Such requests will beevaluated on the merits of each case. A request will be granted only upon receipt ofevidence that the employee has successfully passed a substance screen within thirty (30)days of the request and has successfully completed an assessment by a SubstanceAbuse Professional ("SAP") and has complied with all recommended treatment orrehabilitation prescribed by the SAP.

ARTICLE II TESTING

A. DEFINITIONS

For the purpose of this policy:

1. "Substance testing" means the analysis of urine, saliva, or breath;however, at times circumstances may warrant additional testing methods.

2. "Chain of custody" means the combination of procedures anddocumentation which provides a faithful and accurate written record of thecustody of a biological specimen from time of initial collection of aspecimen to final laboratory analysis.

3. "Negative test result" means a laboratory conclusion that the presence of asubstance was not detected in a specimen at or above the screening andconfirmation levels utilized.

4. "Screened positive result" means that an EMIT analysis has revealed oneor more substances present at or above screening cut-off level.

5. "Positive result" means a laboratory conclusion that a specimen was foundto contain the presence of a substance based on one or more analyticalprocedures which did include gas chromatography/mass spectrometry(GC/MS), as reviewed and confirmed when necessary by qualifiedlaboratory or medical personnel.

B. LABORATORY AND SAMPLING STANDARDS

1. Testing for the following substances, at the indicated screening andconfirmation cutoffs, are recommended:

Drug EMIT ScreenGC/MS

Confirmation Levels

Amphetamines 1000 ng 500 ng

Cannabinoids 50 ng 15 ng

Cocaine

Metabolites

300 ng 150 ng

Opiates 2000 ng 2000 ngPhencyclidine 25 ng 25 ng

Alcohol .02 BAC .02 BAC

Contractors subject to DOT testing shall abide by appropriate levels.


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2. Specimens will be t

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