gec draft safety manual

8/8/2019 Gec Draft Safety Manual

1/55

DRA

Working towards a Gruener environment

PDF Instructions

Providing a safe and healthy workplace is an integral aspect of GEC operations. Thesafety ofGEC employees is a company priority that extends to every level throughout the organization.By making awareness and prevention of occupational injuriesand illnesses a company prioritycreates a workplace that is conducive to growth andprosperity and strengthens our ability to becompetitive.

Our objective and mission is to eliminate work-related injuries and illnesses by promoting safetyand health in all tasks undertaken by employees of the company. Our Safety and HealthManagement Program includes:

Corporate safety and health policies that require employees adhere to these policies as a

condition of employment.

Establishing provisions for maintaining a comprehensive safety-training program for all newand existing employees.

Routine safety and health inspections intended to identify, evaluate and control unsafe workingconditions or work practices and prevent health hazards from affecting employee well being.

Providing mechanical and physical safeguards to prevent injuries at the source.

Maintaining a program for the prompt investigation of accidents and near misses.

Providing employee incentive programs to encourage teamwork, recognize individualachievement, and reward safe behavior.

Employee safety is of the highest priority above all else. Work that cannot safely be done willnot be done at all.

Doug Anderson, President

GRUNE ENVIRONMENTAL CONSTRUCTION SAFETY MANUAL Page 1


2/55

DRA


Table of Contents

Table of Contents ....................................................................................................... 2



3/55

DRA

Working towards a Gruener environmentBloodborne Pathogen Exposure Control Plan

PolicyThe following Exposure Control Plan (ECP) to eliminate or minimize employees occupational exposure tobloodborne pathogens.

Exposure DeterminationEmployees trained as first aid/CPR providers, may have occupational exposure when rendering emergencytreatment. Employees are designated as responsible for rendering first aid or medical assistance as part of their jobduties. A list of the tasks and procedures in which occupational exposure may occur for these individual is attachedin Appendix A. All exposure determinations were made without regard to the use of personal protective equipment.

Exposure Control Plan (ECP)Employees will use Universal Precautions when providing first aid or CPR or completing clean up duties. Universal

Precautions is an infection control method which requires employees to assume that all human blood and specifiedhuman body fluids are infectious for HIV, HBV and other bloodborne pathogens and must be treated accordingly.Universal Precautions are listed on the exposure determination form attached.Employees covered by the Bloodborne Pathogens Standard will receive an explanation of this plan during theirinitial training and will have an opportunity to review this plan or obtain a copy at any time during their work shifts.The ECP will be reviewed and updated annually or sooner if necessary to reflect any new or modified tasks andprocedures that will affect occupational exposure and to reflect new or revised employee positions with occupationalexposure.

Engineering Controls and Work PracticesEngineering controls and work practice controls will be used to prevent or minimize exposure to bloodbornepathogens.The specific engineering controls and work practice controls we will use include:

Readily accessible hand washing facilities are provided in each restroom. Employees are required to wash hands immediately or as soon as feasible after removal of gloves used to renderfirst aid and CPR. Interim hand washing measures, such as antiseptic towelettes and paper towels are provided for immediate use. Employees can later wash their hands with soap and water as soon as feasible. Employees are required to washbody parts as soon as possible after skin contact with blood or other potentially infectious materials. Red bags are provided for equipment disposal (equipment will not be decontaminated or reused).

HousekeepingEmployees will be responsible for cleaning and decontaminating work surfaces following emergency treatment, ifrequired. Some host employers or clients may have their own personnel who are responsible for clean up. Normalcustodian duties involving disposal of waste that may contain used personal products (sanitary napkins, band aides)is not covered under this program.

Decontaminate work surfaces with an appropriate disinfectant (1 part household bleach and 10 parts water) aftercompletion of procedures, after any spill of blood or other potentially infectious materials. Always use mechanical means such as tong, forceps, or a brush and a dust pan to pick up contaminated brokenglassware; never pick up\ with hands even if gloves are worn. Discard all regulated waste in the red bags provided, i.e., liquid or semi-liquid blood or other potentially infectiousmaterial; items contaminated with blood other potentially infectious materials that would release these substances ina liquid or semi-liquid state if compressed; items caked with dried blood or other potentially infectious materials andcapable of releasing these materials during handling; contaminated sharps; and pathological and microbiologicalwastes containing blood or other potentially infectious materials.



4/55

DRA


Personal Protective Equipment (PPE)Personal protective equipment must be used when rendering first aid and CPR or when doing cleanup of accidentsite. Repair and/or replacement and maintenance of PPE will be at no cost to employees.Training will be provided in the use of the appropriate personal protective equipment for employees' specific jobclassifications and tasks/procedures they will perform. Additional training will be provided, whenever necessary,such as if an employee takes a new position or if new duties are added to their current position.Appropriate personal protective equipment is required for the following tasks; the specific equipment to be used islisted after the task:

THIS SPACE RESERVED FOR TABLE

TABLE OF BBP PRECAUTIONS

TASK EQUIPMENT GENERAL PRECAUTIONS

FIRST

AID

CPR

EYE

PROTECTION

DISPOSABLE

GLOVES

DISPOSABLE

FACE MASK

EYE

PROTECTION

DISPOSABLE

GLOVES

DISPOSABLE

BARRIER

PROTECTION

Wear eye, face protection such as a mask with glasses with solid sideshields or a chin-length face shield and hand protection when it can reasonablyanticipated that you may have contact with blood or other potentially infectiousmaterials and when handling or touching contaminated items or surfaces.

Wash hands immediately or as soon as feasible after removal of gloves or otherpersonal protective equipment.

Following any contact of body areas with blood or any other infectious materials,wash hands and any other exposed skin with soap and water as soon as possible.

Flush exposed mucous membranes (eyes, mouth, etc.) with water.

Remove protective equipment before leaving the work area if the equipment

becomes contaminated.

Place used protective equipment in the red bags provided for washed,decontamination, or when being discarded.

Replace gloves if torn, punctured, contaminated, or if their ability to function as abarrier is compromised.

Utility gloves may be decontaminated (washing with bleach/water) for reuse if theirintegrity is not compromised.

Discard utility gloves when they show signs of cracking, peeling, tearing,puncturing, or deterioration.

Never wash or decontaminate disposable gloves for reuse or before disposal.

If clothing is penetrated by blood and other potentially infectious materials, removeclothing immediately or as soon as feasible and place in red bag for laundry.

TrainingAll employees who have or are reasonably anticipated to have occupational exposure to bloodborne pathogens willreceive training to cover the epidemiology and symptoms of bloodborne pathogens and modes of transmission.This training will be augmented by in-house training on the company ECP. The supervisor will provide training toemployees regarding our in-house procedure that includes the following elements:



5/55

DRA

Working towards a Gruener environment A copy and explanation of the standard

Our Exposure Control Plan and how to obtain a copy Methods to recognize exposure tasks and other activities that may involve exposure to blood Use and limitations of Engineering Controls, Work Practices, and PPE PPE - basis for selection, types, use, location, removal, handling, decontamination, and disposal Hepatitis B Vaccine - offered free of charge. Training will be given prior to vaccination on its safety, effectiveness,benefits, and method of administration. (See Appendix) Emergency procedures - for blood and other potentially infectious materials Exposure incident procedures Post-exposure evaluation and follow-up Signs and labels - and/or color coding

All training will be interactive, giving employees an opportunity to ask questions and receive answers. An EmployeeEducation and Training Record will be maintained for each employee upon completion of training.

Hepatitis B VaccinationVaccinations will be offered after exposure. Employees will be provided information on Hepatitis B vaccinationsaddressing its safety, benefits, methods of administration and availability. The employee will be sent to thecompany physician after the employee agrees to accept the vaccination. The physician will establish a medicalrecord, evaluate employee for contraindications to vaccination or prior immunity, will vaccinate employee ordiscuss contraindications will employee. The physician will provide us a copy of his written opinion (e.g., whethervaccine is indicated and whether vaccine was received). We will provide the employee a copy of this written opinionwithin 15 days. All employees are strongly encouraged to receive the Hepatitis B vaccination series. Any employeewho declines the HB vaccination is required to a declination statement to this effect (see Appendix B).Documentation of refusal of the HB vaccination will be kept with the employees other medical records.Employees who initially decline the vaccine may request and obtain the vaccination at a later date at no cost.

Reporting/Documenting &Post Exposure EvaluationShould an accident occur where the employee rendered emergency treatment, the employee is to contact thesupervisor immediately and in all cases before the end of the shift. If the accident involved the presence of blood orother potentially infectious materials, the employee will be offered the HB vaccination series and the emergencytreatment incident will be documented on an accident report whether or not the employee was involved with an"exposure incident". The supervisor will review the circumstances of the exposure incident to determine ifprocedures, protocols, and/or training need to be revised. A medical evaluation of an employee will be provided anda written opinion requested from the physician. This ensures that we are provided with documentation that a medicalassessment of the employee's ability to receive the hepatitis B vaccination was completed as well as informing usregarding the employee's hepatitis B vaccination status.We will ensure that the physician responsible for employee's HB vaccination and post-exposure evaluation andfollow-up be given a copy of the OSHA Bloodborne Standard; job description of employee; incident reportdescribing routes and circumstances of exposure; source individual's identity and HBV/HIV status if known; and

employee's HBV status.If a determination is made that the first aid provider was involved in an "exposure incident", the employee will besent for evaluation. The physician will evaluate the exposure incident; arrange for testing of employee and sourceindividual (if not already known); notify employee of results of all testing; provide counseling; provide post-exposure prophylaxis and evaluate any reported illness.

The physician will provide us a copy of his written opinion that is limited to:

To whether the employee requires or has received the HB vaccination (for HB vaccinations).



6/55

DRA

Working towards a Gruener environment To whether or not the employee has been informed of the results of the medical evaluation and any medical

conditions which may require further evaluation and treatment (for post-exposure evaluation and follow-up).We will provide the employee with a copy of the evaluating health care professional's written opinion within 15days after completion of the evaluation.

LaundryIf clothing has been contaminated with regulated waste, remove and place in a red bag. We will send thecontaminated clothing out for cleaning at no cost to the employee.

LabelingRed bags will be provided and used at our facility. Red bags will be used to dispose of non-reusable equipment orwill be used to contain contaminated clothing. Disposal will be handled by a licensed waste hauler.

Recordkeeping

Employee medical, training and accident/incident records will be maintained at our facility. Employees will beprovided these records upon request of the employee or to anyone having written consent of the employee within 15working days.

Medical RecordsMedical records are maintained for each employee with occupational exposure. These records will be maintained forthe period of employment, plus thirty years and will include: The name and social security number of employee; A copy of the employee's Hepatitis B vaccinations and any medical records relative to the employee's ability toreceive vaccination; A copy of all results of examinations, medical testing, and follow-up procedures as required by the standard; A copy of all health care professional's written opinions as required by the standardAll employee medical records are kept confidential and will not be disclosed or reported without the employee's

express written consent to any person within or outside the workplace.The training records will be maintained (see appendix). The contents or summary of the training sessions areincluded as part of the written plan. Training records will be maintained for a minimum of three years from the dateon which the training occurred.An OSHA 300 Form will be maintained and retained for five years. Events will be documented as an injury ifdocumentation is required.If we cease to do business and there is no successive employer to receive and retain the records for the prescribedperiod, the employer shall notify the OSHA Director or the National Institute for Occupational Safety and Health(NIOSH) at least three months prior to the scheduled record disposal and prepare to transmit them to the Director.

THIS SPACE RESERVED FOR TABLE

Appendix A Pathogen



7/55

DRA

Working towards a Gruener environmentStatement of Declination of Hepatitus B Vaccination

I understand that due to my occupational exposure to blood or other potentially infectious materials I may be at riskof acquiring hepatitis B virus (HBV) infection. I have been given the opportunity to be vaccinated with hepatitis Bvaccine, at no charge to myself. However, I decline hepatitis B vaccination at this time. I understand that bydeclining this vaccine, I continue to be at risk of acquiring hepatitis B, a serious disease. If in the future I continue tohave occupational exposure to blood or other potentially infectious materials and I want to be vaccinated withhepatitis B vaccine, I can receive the vaccination series at no charge to me.

Signature: _____________________________________________________________________ Date: ____________________



8/55

DRA

Working towards a Gruener environmentConfined Spaces

PrefaceGEC has developed a written policy for safe entry into confined spaces. The Company recognizes that certainenvironmental conditions within confined spaces are capable of causing death to anyone who enters the spacewithout taking precautionary measures. Therefore, each entry into a confined space must be evaluated by thesupervisor to determine the hazards involved and appropriate safety measures and controls that must be taken toensure a safe environment.Safe entry into a confined space is the responsibility of both the supervisor and the employee who performs thework. Supervisors must ensure that this procedure is followed and that all personnel understand and comply with thesafety requirements. The employee must inform the supervisor of any departure from this procedure.

Definition of a Confined SpaceA confined space is a space that is large enough and so configured that an employee can bodily enter and perform

assigned work. It has limited or restricted means for entry or exit, and is not designed for continuous employeeoccupancy.Additionally, the space may contain a potentially hazardous atmosphere, it may have limited oxygen content, and itmay contain mechanical and / or electrical equipment, which upon contact or activation may trap, crush, orelectrocute persons in the space.Some examples of confined spaces include but are not limited to: sewers, septic tanks, sewage digesters, pumpstations, wells, manure pits and tanks, silos, vats, ducts, utility vaults, process vessels, boilers, pipelines, pits,ventilation and exhaust units, storage bins, hoppers, and caves.The Company must evaluate each confined space to determine if that space is to be designated as a Permit-RequiredConfined Space or a Non-permit Confined Space. Host employers may have already identified spaces as permitrequired or non-permit space. Always confer with host employers prior to entry.A permit system is the written procedures for preparing and issuing permits for entry and for returning the permitspace to service following termination of entry.

A non-permit confined space is a confined space that does not contain or with respect to atmospheric hazards, havethe potential to contain any hazard capable of causing death or serious physical harm.A permit-required confined space is any confined space that has one or more of the following characteristics: Contains or has a potential to contain a hazardous atmosphere. Contains a material that has the potential for engulfing an entrant. Has an internal configuration such that an entrant could be trapped or asphyxia by inwardly converging walls or bya floor, which slopes downward, and tapers to a smaller cross section. Contains any other recognized serious safety or health hazard.

RequirementsThe employer shall evaluate the workplace to determine if any spaces are permit-required confined spaces.If the workplace contains permit spaces, the employer shall inform exposed requirements, and that a writtencertification that contains the date, the location of the space, and the signature of the person providing the

certification has been completed.When there are changes in the use or configuration of a non-permit confined space that might increase the hazards toentrants, the employer shall re-evaluate and if necessary reclassify it as a permit-required space.A space classified by the employer as a permit required confined space may be reclassified as a non-permit confinedspace under the following conditions: If the permit space poses no actual or potential atmospheric hazards and if all hazards within the space areeliminated without entry into the space and the permit space may be reclassified as a non-permit confined space foras long as the non atmospheric hazard remain eliminated.



9/55

DRA

Working towards a Gruener environment If it is necessary to enter the permit space to eliminate hazards, such entry shall be performed following the entry

rules for permit-required area. If testing and inspection during this time demonstrate that the hazards within thepermit space have been eliminated, the permit space may be reclassified as a non-permit confined space for as longas the hazards remain eliminated.The employer shall document the basis for determining that all hazards have been eliminated.If hazards arise within the permit space that changes the classification, the space must be reclassified.When an employer arranges for another contractor to perform work that involves permit space entry, the hostemployer shall: Inform the contractor that the workplace contains permit spaces that entry is allowed only as a permit-requiredspace. Apprise the contractor of the elements of the confined space. Co-ordinate entry operations with the contractor when both the owner and the contractor work in the same space. Debrief the contractor at the conclusion of the operations regarding any hazards created by the activities of theother.

Inform the host employer of the permit space program the contractor will follow.

PERMIT REQUIRED CONFINED SPACE PROGRAMThe following procedures will be followed for permit required confined spaces: Implement the measures necessary to prevent the unauthorized entry. Identify and evaluate the hazards of permit spaces before employees enter them. Develop and implement means, procedures, and practices necessary for safe permit space entry operations,including, but not limited to the following:- Specifying acceptable entry conditions;- Isolation of the permit space;- Purging, inverting, flushing, or ventilating the permit space as necessary to eliminate or control atmospherichazards:- Providing pedestrian, vehicle, or other barriers as necessary to protect entrants from external hazards; and

- Verifying that conditions in the permit space are acceptable for entry into throughout the duration of an entry.These procedures will be followed for each space and may vary according to the environmental conditions of thespace.Provide to the employee the following equipment and ensure that the employee uses that equipment properly: Testing and monitoring equipment needed to test and monitor the atmosphere while working in the confined space. Ventilating equipment needed to obtain acceptable entry conditions. Communications equipment. Lighting equipment needed to enable employees to see well enough to work safely and to exit the space quickly incase of an emergency. Barrier and shields as needed to protect the opening. Equipment such as ladders, needed for safe ingress and egress. Rescue and emergency equipment needed to rescue the entrant from the confined space. Provide any other equipment necessary for safe entry into and rescue from the permit space.



10/55

DRA

Working towards a Gruener environmentEvaluate permit space conditions as follows when entry operations are conducted:

Test conditions in the permit space to determine if acceptable entry conditions exist before entry. Test or monitor the permit space as necessary to determine if acceptable entry conditions are being maintained forthe course of the entry operations. When testing for atmospheric hazards, test first for oxygen, then combustible gases and vapors, then for toxicgases and vapors. Provide at least one attendant outside the permit space into which entry is authorized for the duration of entryoperations. If multiple spaces are to be monitored by a single attendant, include in the permit program the means andprocedures to enable the attendant to respond to an emergency affecting one or more of the permit spaces beingmonitored without distraction from the attendants duties. Designate the persons who are to have an active role in entry operations. (for example authorized entrants,attendants, entry supervisors, or persons who test or monitor the atmosphere in a permit space). Coordinate with host employer, prior to entry, regarding procedures for summoning rescue and emergency

services, for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employeesand for preventing unauthorized personnel from attempting a rescue. Review entry operations when the employer has reason to believe that the measures taken under the permit spaceprogram may not protect employees and revise the program to correct deficiencies found to exist before subsequententries are authorized. Review the permit-required confined space program using the canceled permits retained for one year and revise theprogram as required.

PERMIT SYSTEM FOR CONFINED SPACE ENTRY Before entry is authorized, the employer shall document that the entry permit has been prepared and followed asoutlined in the program. Before entry begins, the supervisor shall sign the entry permit. The complete permit shall be made available and posted at the time of entry.

The duration of the permit may not exceed the time required to complete the task. The entry supervisor shall terminate and cancel the permit when the space and or when the activities have beencompleted. The permit shall be retained for one year.

THE ENTRY PERMIT FOR CONFINED SPACEThe entry permit that documents compliance with this section and authorizes entry to a permit space shall identifythe following: The permit space to be entered. The purpose of the entry. The date and the authorized duration of the entry permit. The authorized entrants within the permit space by name or by other means as will enable the attendant todetermine quickly and accurately for the duration of the permit which entrants are inside the permit space. The person serving as the attendant. The person by name currently serving as supervisor with a space for the signature or initials of the entry supervisorwho authorized entry. The hazards of the permit space to be entered. The measures used to isolate the permit space and to eliminate or control permit space hazards before entry.(Lockout/tagout or isolate hazardous energy). The acceptable entry conditions. The results of initial and periodic tests performed for atmosphere monitoring and accompanied by the name of thetesters and an indication of when the test were performed.



11/55

DRA

Working towards a Gruener environment The rescue and emergency services that can be summoned and the means (such as the equipment to use and the

numbers to call) for summoning aid.

TRAINING REQUIREMENTSPrior to beginning confined space entry procedures, the following training will be provided for all affectedemployees and documented.

Authorized Entrants Shall:

Become knowledgeable of the hazards that may be present during entry, including information on the mode, signsor symptoms, and consequences of the exposure. Become knowledgeable in the proper selection and use of personal protective equipment required for entry. Learn to communicate with the attendant whenever:- The entrant recognizes any warning sign or symptom of exposure to a dangerous situation.- The entrant detects a prohibited condition.

- Need to monitor the entrants status. Become knowledgeable in procedures for exiting a confined space including:- Understanding an order to evacuate when given by the attendant or the entry supervisor.- Understanding when an evacuation alarm is sounded.- Recognizing any warning sign or symptom of exposure to a dangerous situation.- Detecting a prohibited condition.

Attendants Shall:

Become knowledgeable of the hazards that may be present during entry, including information on the mode, signsor symptoms, and consequences of the exposure. Become aware of the possible behavioral effects of hazard exposure an authorized entrant may exhibit. Learn to maintain a continual accurate count of authorized entrants in the permit space and be able to accuratelyidentify who is in the permit space at all times.

Understand the importance of maintaining a constant vigil outside the permit space during entry operations untilrelieved by another attendant. Learn techniques for communicating with entrants as necessary to monitor entrant status and to alert entrants of theneed to evacuate the space. Learn to monitor activities inside and outside the space to determine if it is safe for entrants to remain in the space. Learn under what circumstances the entrant is to be ordered to evacuate the space. Such circumstances mayinclude:- If the attendant detects a prohibited condition.- If the attendant detects the behavioral effects of hazard exposure in the authorized entrant.- If the attendant detects a situation outside the space that could endanger the authorized entrants.- If the attendant cannot effectively and safely perform his duties.- Learn when to summon rescue and other emergency services.- Learn what actions to take in the event unauthorized persons approach or enter the permit space while entry isunderway.These actions may include the following: Warn unauthorized persons to stay away from the permit space. Advise unauthorized persons that they must immediately exit the permit space if they have gained entry into thespace. Inform authorized entrants and the entry supervisor of any unauthorized entrants. Learn to perform non-entry rescue procedures. Understand that the primary duty is to monitor and protect the authorized entrants and, as such, never to performduties that will interfere with this objective.



12/55

DRA


Entry Supervisors Shall: Become knowledgeable in the proper selection and use of personal protective equipment and rescue equipmentrequired for making rescues from permit spaces, and will be required to perform practice rescue drills a minimum ofonce annually. Become knowledgeable of the hazards that may be present during entry, including information on the mode, signsor symptoms, and consequences of the exposure. Gain thorough knowledge of the information required on the entry permit, and understand his/her role in verifyingthat tests, if applicable, have been conducted and that equipment is in place prior to endorsing the permit andallowing entry to begin. Understand procedures for terminating entry and canceling the permit. Understand procedures for verifying rescue services are available and means for summoning them are operable. Understand procedures for removing unauthorized individuals from the area. Become knowledgeable and take responsibility for determining that entry operations remain, at all times,

consistent with the terms of the entry permit and that acceptable entry conditions are maintained.

Rescue & Emergency Services Personnel Shall: Become knowledgeable in the proper selection and use of personal protective equipment and rescue equipmentrequired for making rescues from permit spaces. Become knowledgeable under the requirements outlined for authorized entrants above. Become knowledgeable in performing confined space rescue procedures. Perform confined space rescue drills a minimum of once every twelve months. Drills will include simulated rescueoperations using dummies, manikins, or actual persons from actual permit spaces or from representative permitspaces. Become trained in basic first-aid and CPR, and have a minimum of one member of the rescue service holdingcurrent certification in first aid and CPR be made available for rescue services. If outside services are called in, the employer will arrange to inform rescue service personnel of the hazards they

may confront in performing rescue operations. Have access to all permit spaces from which rescue may be necessary for developing rescue plans and performingdrills. Become knowledgeable in retrieval systems or methods that may be employed for non-entry rescue, andunderstand when using such equipment may increase overall risk and hinder rescue operations.

Annual ReviewThe Corporate Safety Manager or designee shall conduct an annual review of the program.Canceled permits kept on file shall be utilized to assess the effectiveness of the program. Upon completion of theannual review, the company Confined Space Program shall be updated as necessary.

Confined Spaces



13/55

DRA

Working towards a Gruener environment Control of Hazardous Energy

PrefaceThis procedure establishes the minimum requirements for the lockout of energy isolating devices whenevermaintenance or servicing is done on machines or equipment. It shall be used to ensure that the machine orequipment is stopped, isolated from all potentially hazardous energy sources and locked out before employeesperform any servicing or maintenance where the unexpected energizing or start-up of the machine or equipment orrelease of stored energy could cause injury.

Compliance with this ProgramAll employees are required to comply with the restrictions and limitations imposed upon them during the use oflockout. The authorized employees are required to perform the lockout in accordance with this procedure. Allemployees, upon observing a machine or piece of equipment which is locked out to perform servicing ormaintenance shall not attempt to start, energize, or use that machine or equipment.

DefinitionsLockout is the placement of a lockout device on an energy-isolating device, in accordance with an acceptedestablished procedure, that ensures the energy isolating device and the equipment being controlled cannot beoperated until the lockout device has been removed.A "lockout device" is just that - a locking device that provides a positive means for rendering a switch, valve, or anyenergy source inoperable.The device may be a padlock, restraining bar, chain, or any device that positively prevents a machine or piece ofequipment from becoming "energized" or from releasing stored energy.Tagout is the placement of a tagout device on an energy isolating device, in accordance with an accepted establishedprocedure, which effectively communicates that the energy isolating device and the equipment being controlled arenot to be operated until the tagout device is removed.A "tagout device" serves as a prominent warning that can be securely attached to an energy isolating device, which

clearly communicates that a tagout condition exists. This tag is a means of identifying who locked out themachinery; the date and time of day the tagout took place, and the department for which the person works.Additional information may be placed on the tag such as beeper number, extension number, etc. Tags shall bedurable and securely fastened to the energy-isolating device so as not to fall off. Tags are NEVER to be removed byanyone except the individual who is responsible for the lockout/tagout procedure.

Permit Issuer:An employee, familiar with the process and its hazards, who issues the Lockout/Line Break Permitand personally witnesses the field inspection steps on the Permit to ensure that it is safe to begin work. A permitissuer may be a client depending on the client's procedures.

Authorized Worker: A person(s) who locks out equipment in order to perform hands on work of thatequipment. A Permitted Issuer and Permitted Worker may be the same person.

Affected Employee: A person whose job requires him/her to operate the equipment on which servicing ormaintenance is being performed under Lockout/Tagout, or whose job requires him/her to work in the area whereLockout/Tagout is being performed.

Energy Source: Any source of energy, including but not limited to, electrical, mechanical, hydraulic, pneumatic,chemical, thermal (greater than 140 degrees), gas, springs, elevated machine members, gravity, water pressure,steam or nuclear.

Line Break: The physical opening of any line or equipment that may result in the exposure to a hazardous material.



14/55

DRA


Lockout Box:Lockout boxes are used for group lockouts when the normal procedure for locking out equipment isimpractical. An example, where a lock-out box may be used is a shutdown situation that requires several pieces ofequipment and energy sources to be locked out at time.

Lockout Device:A device that utilizes a positive means to hold an energy isolating device in the safe position andprevent the energizing of a machine, valve or other equipment.

Lockout/Line Break Permit: A written permit that is used as a checklist to ensure that all hazardous energysources have been identified and placed in a zero mechanical state. The permit will include a complete descriptionand identification of the equipment. (Appendix A)

Log:Logs are used primarily for group lockouts. Logs are used when a large number of people are working onequipment in association with lock-out boxes. Each person working on specific equipment as part of the group

lockout, is required to sign the log (in addition to placing a personal lock on the lock-out box), before beginning andat the completion of work.

Multiple Locking Device: A multiple locking device is used in situations where more than one person is workingon a piece of equipment or more than one person is working in an area covered by the lockout. The multiple lockingdevice allows a number of people to lockout the same piece of equipment at the designated energy isolating device.

Personal Lock:A lock device used in a lockout in which the person requiring lockout protection is in sole controlof the key.

Lockout Boxes/Group LockoutsSystem or group lockouts or line breaks will sometimes utilize lockout boxes. Personal locks and properlycompleted tags (individual's name and date) must be applied to the box, locking out the keys to equipment locks. A

log may be used to track employees involved in the lockout and will be maintained at the Lockout Box. Thepresence of a log will be determined by the host employer's procedure. Upon completion of the work, the leadperson will be responsible for equipment lock removal and restart.Host Employers may also be involved in locking out equipment. Depending on the host employer's procedure, HostEmployer Management may designate a knowledgeable individual who will be ultimately responsible for lockremoval and restart of equipment. The objective is to afford the employees involved in the work the same level ofprotection as that of an individual lockout.

Sequence of LockoutNotify all affected employees that servicing or maintenance is required on a machine or equipment and that themachine or equipment must be shut down and locked out to perform the servicing or maintenance.The authorized employee shall identify the type and magnitude of the energy that the machine or equipment utilizes,shall understand the hazards of the energy, and shall know the methods to control the energy.

If the machine or equipment is operating, shut it down by the normal stopping procedure (depress the stop button,open switch, close valve, etc.).De-activate the energy isolating device(s) so that the machine or equipment is isolated from the energy source(s).Lock out the energy isolating device(s) with assigned individual lock(s). Group Lockout boxes may be used.Stored or residual energy (such as that in capacitors, springs, elevated machine members, rotating flywheels,hydraulic systems, and air, gas, steam, or water pressure, etc.) must be dissipated or restrained by methods such asgrounding, repositioning, blocking, bleeding down, etc.Ensure that the equipment is disconnected from the energy source(s) by first checking that no personnel are exposed,then verify the isolation of the equipment by operating the push button or other normal operating control(s) or by



15/55

DRA

Working towards a Gruener environmenttesting to make certain the equipment will not operate. Return operating control(s) to neutral or "off" position after

verifying the isolation of the equipment.The machine or equipment is now locked out.

Sequence of a Line Break (Pipe Line) LockoutLine breaks will require close cooperation between GEC employees and the host employer. GEC employees mustreview and be familiar with the host employer's procedures before proceeding with the line break.Properly preparing a section of pipeline and/or equipment for "breaking" is particularly important when unexpectedrelease of the contents could cause personal injury. Therefore, this lockout/ line break procedure is to be used whenbreaking pipelines and equipment that contain materials which are flammable, combustible, corrosive, toxic, or atelevated temperature (>140 !F) or pressure (> 110 psig). This operation may require a permit by the host employer.Personnel thoroughly knowledgeable of the operation, which includes the pipeline/equipment, must see that theportion of line/equipment to be worked on is completely and properly isolated.Isolation valves must be secured in the "OFF" position and bleeder devices/valves in the "OPEN" position.

Personal lock and/or tag device must be secured to the valves. The tag must have the name of the person attachingthe tag and date.Automatic valves may never be used as a means of isolation for Confined Spaces.Automatic valves may only be used under the following conditions for line break; Air-operated valves (air to open, fail-close) may be used if the air has been removed from the controller, properlyisolated and there is confirmation of the valve closure. Air-operated valves (air to close, fail-open) may be used only if there is a mechanical mechanism forsecuring/locking the valve in the closed position, the valve tagged, and the valve can be tested (try-out) to ensurepositive closure. Automatic valves being used as manual valves must not be used for isolation during any line break situation.Isolate the line ahead of the automatic valve. All valves used for isolation are to be locked before work begins. However, in situations where hazardousmaterials lines/equipment are being prepared for Confined Space Entry, an additional measure of safety must be

provided such as blinding, double block and bleed, misalignment of pipe, etc.For line breaks involving thermal hazards (above 140 degrees), Hot Liquids PPE must be worn at all times duringthe initial line break and until the contents of the pipe/vessel have been confirmed empty. Required PPE forthermal line breaks include at a minimum face shield,rubber or waterproof gloves and rubber orwaterproof coat orrubber or waterproof jacketand pants.For line breaks involving chemical hazards, all appropriate PPE required by the MSDS (Material Safety Data Sheet)must be worn by the employee(s) for the duration of the exposure potential.GEC employees must request a copy of the MSDS and review the listed hazards prior to beginning work.The authorizing person should review the job scope, how the equipment / piping was isolated, potential hazards, andappropriate PPE with the employee(s) assigned to perform the work.The employee(s) assigned to perform the work must attach a personal lock and/or tag to the lockout device, reviewthe scope of the work with the authorizing employee, and sign the permit.After personally witnessing all field inspection steps listed on the permit and filling in date, time and location, theauthorizing person signs the permit.

Restoring Equipment to ServiceWhen the servicing or maintenance is completed and the machine or equipment is ready to return to normaloperating condition, the following steps shall be taken. Check the machine or equipment and the immediate area around the machine to ensure that nonessential itemshave been removed and that the machine or equipment components are operationally intact. Check the work area to ensure that all employees have been safely positioned or removed from the area. Verify that the controls are in neutral.



16/55

DRA

Working towards a Gruener environment Remove the lockout devices and reenergize the machine or equipment. The person who installed the

Lockout/Tagout device must remove it. Notify affected employees that the servicing or maintenance is completed and the machine or equipment is readyfor use.In the event that an employee has forgotten to remove their lock, the Supervisor must:- Verify that the employee who applied the locking device has left the facility.- Ensure that the work area is secure and that the employee has left work incomplete causing a hazardousenvironment.- Make all reasonable efforts to contact the employee to inform him that the lockout/tagout device is being removed.- Ensure that the employee is aware that the lock was removed prior to resuming work.

Periodic Program Review & InspectionPeriodic inspections will be performed at least annually to ensure effectiveness of this program.The inspections will be performed by the Corporate Safety Manager or assigned designee.

The inspection will include: A review between the inspector and the authorized employee's responsibility under this program; The procedure involving de-energizing of machinery or equipment; Lockout equipment use, and; Procedures for releasing equipment from Lockout/Tagout.Periodic inspections will be documented on Appendix A.

TrainingTraining on this procedure will be conducted during new hire training and annually.Retraining will be performed if deviations from this procedure are identified.

This space reserved for Appendix A FORM



17/55

DRA

Working towards a Gruener environment Drug, Alcohol and Contraband

Purpose and ScopeThe goal of this policy is to establish a drug free workplace and to comply with various regulatory drug and alcoholtesting policies to include the guidance provided in accordance with Texas Med Clinic Inc. Program Standards.To achieve this goal, this policy establishes: Prohibited conduct regarding drugs and alcohol in the workplace. Pre-employment drug and alcohol testing. Drug and/or alcohol testing upon reasonable suspicion for non-DOT and DOT regulated employees. Random drug and alcohol testing procedures. Post accident drug and alcohol testing procedures for DOT regulated employees and non-DOT regulatedemployees. Employee assistance. Employee training.

Disciplinary action.The purposes of a drug and alcohol free workplace is: Decreased accident/incident and injury rates. Reduced liability and insurance costs. Improved productivity. Decreased absenteeism. Decreased employee turnover. Deter illegal activities related to drug abuse.

Related Rules & RegulationsDOT Regulation 49 CFR Part 40 Procedures for transportation Workplace Drug and Alcohol Testing Programs.DOT Regulation (FMCSA) 49 CFR Part 382Controlled Substance and Alcohol use and testing.

DOT Regulations 49 CFR Part 119.113 and 49CFR Part 199.241 requiring a minimum of 1- hour drug training and alcohol training for supervisory personnel.

Pre-Employment Drug ScreensPotential new hire employees will be required to submit a urine sample for drug screening prior to offer ofemployment.Employees who do not pass the urine drug screen will not be offered employment. Refusal will be considered apositive result.Upon passing the urine drug test, a potential employee will be required to submit a hair sample drug test and proceedwith the physical.Positive drug tests using hair as the sample media will be cause to place the employee in a probationary status for noless than ninety days.Employees with positive hair sample drug tests will be required to submit another hair sample for testing ninety days

after the initial positive test sample was submitted.Failure of the second hair sample drug test will result in termination.Sample MediaSample media used for drug and/or alcohol testing may include, but is not limited to, hair, finger or toenails, saliva,blood, breath and urine.

Alcohol (DOT Regulated Employees)Employees will not perform safety-sensitive functions with alcohol concentration of 0.04 or greater.



18/55

DRA

Working towards a Gruener environmentNo driver shall be on duty or operate a commercial motor vehicle while the driver possesses alcohol.

No driver shall use alcohol while performing safety - sensitive functions.No driver shall perform safety-sensitive functions within four hours after using alcohol.No driver required to take a post-accident alcohol test shall use alcohol for eight hours following that accident, oruntil the driver undergoes a post-accident alcohol test.The refusal to submit to an alcohol test for pre-employment, random, post-accident, reasonable suspicion or afollow-up alcohol test will be considered a positive.

Drug Use (DOT Regulated Employees)No driver shall report for duty or remain on duty when the driver uses anycontrolled substances, unless a physician for medical reasons prescribes the use and the substance does not adverselyaffect the drivers ability.Drivers shall report the use of any therapeutic drug use. In accordance with Part 392.4, no driver shall be on duty,possess, be under the influence of, or use, any of the following or other substances: Any 21 CFR 1308.11 Schedule 1 substances

An amphetamine or any formulation thereof (including, but not limited to, pep pills and bennies). A narcotic drug or any derivative thereof Any other substance, to the degree, which renders the driver incapable of safely operating a motor vehicle.The restrictions listed above 18.6.2 do not apply to the possession or use of a substance administered to a driver by alicensed medical practitioner who has advised the driver that the substance will not affect the driver's ability tosafely operate a motor vehicle.No driver shall report for duty, remain on duty or perform a safety-sensitive function, if the driver tests positive for acontrolled substance.The refusal to submit to a controlled substance test for pre-employment, random, post-accident, reasonable suspicionor a follow-up controlled substance test will be considered to be a positive test.Drivers controlled substances test will be a 5- panel drug test that will screen for: Marijuana Cocaine

Opiates Amphetamines Phencyclidine (PCP)

Drug Use (Non-DOT regulated employees)No employee shall report for duty or remain on duty when the employee uses any controlled substances, unless aphysician for medical reasons prescribes the use and the substance does not adversely affect the employee's abilityto perform work.Employees shall report the use of any therapeutic drug use.Employees shall not report for duty, remain on duty or perform work, if the employee tests positive for a controlledsubstance.The refusal to submit to a controlled substance test pre-employment, random, post-accident, reasonable suspicion ora follow-up controlled substance test will be considered to be a positive test.The employee's controlled substance test will be a 5-panel drug test that will screen for: Marijuana Cocaine Opiates Amphetamines Phencyclidine (PCP)

Alcohol Use (Non-DOT Regulated Employees)Employees are prohibited from working while under the influence alcohol.



19/55

DRA

Working towards a Gruener environmentAlcohol consumption while at work is prohibited.

Working while under the influence of or consuming alcohol while working will lead to disciplinary action up to andincluding termination.

Possession of ContrabandEmployees are prohibited from using, possessing, selling, manufacturing, distributing, concealing, or transportingany of the following items: Any Prohibited Substance Contraband, including firearms, ammunition, explosives, and weapons Illicit drug equipment or paraphernalia.Possessing or using prescription drugs or over the counter medication that may cause impairment are prohibitedexcept when all of the following conditions have been met: Prescription drugs have been prescribed by a licensed physician for the person in possession of the drugs. A licensed pharmacist for the person possessing the drugs filled the prescription.

The individual notifies his supervisor, if he will be in possession of, or using, impairment causing prescriptiondrugs or over-the counter medication. Appropriate steps are taken to accommodate the possibility of impairment, including but not limited to, removalfrom work for the period of possible impairment.

Switching of samples or any other form of adulteration to the sample is strictly prohibited and may lead todisciplinary action up to and including termination of employment.Individuals are prohibited from being under the influence or prohibited substances while performing any work forour host employers.While on GECs host employer(s) property, host representatives and/or the company may, at any time, havesupervisors and/or authorized search and inspection specialists, including scent-trained animals, conductunannounced searches and inspections of GEC personnel and their property; that property may include, but is notlimited to, the following: wallets, purses, lockers, baggage, offices, desks, tool boxes, clothing and vehicles.

Post-Incident TestingIf a GEC company representative or host employer determines from the information available immediately after awork-related incident that performance of one or more of GEC personnel contributed to the incident, or cannot becompletely discounted as a contributing factor to the incident, GEC shall remove that/those individual(s) from thehost employer's property and surrender his/her/their site credentials to the host employer. For purposes of this partincident means an incident that caused personal injury requiring medical treatment beyond first aid administeredat the work site, or property damage of more than $1000, or an incident that carried the potential for serious personalinjury or significant property damage.An individual so removed will be allowed to return to work on the host employer's property only after a GECRepresentative conducts alcohol and drug testing on the individual as soon as possible following the individual'sremoval from the site, and a GEC Representative certifies in writing the test identification number, the individual'ssocial security number, the test date and time, and a negative test result. On the written certification GEC willinclude a consent signed by the individual permitting disclosure to the host employer of the test results.Commercial Motor Vehicle (CMV) drivers are required to submit a drug and alcohol test when involved in a motorvehicle accident causing property damage or bodily injury.The CMV driver may not operate a motor vehicle until the drug and alcohol tests are performed and the results arefound to be negative.Reasonable Suspicion TestingUpon reasonable suspicion by GEC or the host employer(s) that personnel is under the influence of a prohibitedsubstance while on duty and/or on the host employer's property, a GEC Representative shall remove the individualfrom the property and surrender his/her site credentials to the host employer.



20/55

DRA

Working towards a Gruener environmentAn individual removed from the host employer's property for reasonable suspicion will be allowed to return to work

on the host employer property only after GEC conducts alcohol and drug testing on the individual as soon aspossible following the individual's removal from the site, and a GEC Representative certifies in writing the testidentification number, the individual's social security number, the test date and time, and a negative test result. Onthat written certification GEC will include a consent signed by the individual permitting disclosure to the hostemployer(s) of the test result.For testing purposes, substances and threshold levels will comply, at a minimum, with the Department ofTransportation (DOT) alcohol and drug regulations. Collection, chain-of-custody and other related procedures willbe consistent with sound industry practice. Alcohol will be included in any test panel regardless of any lesser DOTrequirement.GEC will use only testing laboratories that are properly certified under a recognized state and national program.

Host Employer RequestsHost employers may request, without notice, drug and/or alcohol testing. These requests may require a variety of

sample media. GEC employees are required to comply with these requests. Employees who refuse to submit to theserequests will be considered non-compliant and subject to disciplinary action up to and including termination ofemployment.Negative test results will require no further action.If the urine quick test is positive, the employee will be suspended without pay pending further evaluation of thesample. If further analysis determines the sample to be negative, the employee will be returned to work the nextworking day.If further analysis determines the sample to be positive, the employee will be suspended and must follow proceduresoutlined in the Disciplinary Procedures section to regain employment status.

Non-ComplianceAny personnel found in violation of this policy or whom refuses to cooperate with the searches and tests included inthis policy shall be permanently removed by a GEC Representative from the host employer(s) property and from

performing work for that employer. A GEC Representative will immediately notify the host employer that theindividual has become disqualified under the Drug, Alcohol and Contraband Policy Requirements. A GECRepresentative will immediately review with the host employer(s) the nature of the work previously performed bythe individual. At the host employer(s) request GEC shall, at its sole cost and risk, inspect all work in which theindividual may have participated, and submit a written report to the host employer that documents the inspection,any findings, and the actions taken to assure all deficiencies have been corrected.

Random TestingDOT regulated employees will be randomly selected for an alcohol and drug screen on a monthly basis. Alcohol test will be based on annual employment percentage rate of 25%. Drug screens will be based on annual percentage rate of 50%.Non-Dot regulated employees will be randomly selected for a drug screen on a monthly basis.The annual percentage rate will be 50 percent of employees.The random selection of employees will be a computer-based program that will randomly select employees permonth by their Social Security number.

Test ResultsNegative controlled substances test results will be reported from the collection sites Medical Review Officer (MRO)to the Safety Manager.The Safety Manager will contact the employee and inform the employee that the results were negative.



21/55

DRA

Working towards a Gruener environmentPositive test results; the MRO will contact the employee and give the individual an opportunity to discuss the test

results prior to verifying those test results as positive.In the event the MRO was unable to make contact with the employee; the MRO will contact the GEC SafetyManager, who shall direct the employee to contact the MRO as soon as possible. The GEC Safety Manager will holdthis in the utmost confidence.After making all reasonable efforts to contact the employee, the GEC Safety Manager may place the employee ontemporary medically non-eligible status or medical leave.The MRO may verify a test as positive without having communicated those test results directly with the employeeif: The employee expressly declines the opportunity to discuss the test. The Safety Manager has successfully made contact with the employee and instructed the employee to contact theMRO, and more than 5 days have passed since the date the employee was contacted by the Safety Manager. The employee will be immediately removed from work once the employee is notified of the positive result.Following the verification of a positive test result, the MRO will review and may contact the Safety Manager to

make a recommendation that the employee enters an employee assistance or rehabilitation program.Random, post-accident, and reasonable suspicion drug and/or alcohol tests that are negative will be paid for byGEC, any positive test results will be paid for by the employee through payroll deduction.

Employee Assistance ProgramAny employee who feels that he or she has developed an addiction to, dependence upon or problem with legal drugs,illegal drugs, or alcohol is encouraged to seek assistance before the problem leads to disciplinary action.A list of community resources that offer assistance is available through the GEC Safety Manager. It is theemployee's responsibility to seek assistance. These resources operate independently from GEC. As such, anemployee's decision to seek prior assistance from one of the resources will not be used as the basis for disciplinaryaction and will not be used against the employee in any disciplinary proceedings. On the other hand, using one ormore of the resources listed will not be a defense to avoid disciplinary action where facts proving a violation of thispolicy are obtained outside these resources.

The company, at its sole discretion, may grant an employee rehabilitation leave.The cost for rehabilitation is at the employee's expense.Reinstatement of an employee is dependent upon successful completion of the rehabilitation program as evidence bywritten documentation from the program provider that the employee was continuously enrolled in the treatmentprogram, actively participated in the program, and was properly discharged. Participating in any recommendedfollow-up treatment and/or counseling is the responsibility of the employee.Any employee suffering from an alcohol or drug problem who rejects treatment or who leaves a treatment programprior to being properly discharged there will not be eligible for re-employment with the company.No employee will be eligible for the employee assistance program more than one time. The recurrence of an alcoholor drug problem will be cause for dismissal. Employees that undergo voluntary counseling or treatment and continueto work must meet all established standards of conduct and job performance.All eligible employees returning to employment from rehabilitation will be required to sign a "Return to WorkAgreement", providing: For unannounced testing for a period of up to 60 months to insure that the employee has freed himself or herselffrom the alcohol or drug problem. That failure of such a test during this period or employee's refusal to submit to testing shall be grounds forimmediate dismissal. That the employee must maintain acceptable attendance and performance record and comply with all othercompany policies upon their return to work. That the employee will participate in any follow-up treatment and/or counseling recommended by the treatmentprogram.



22/55

DRA

Working towards a Gruener environmentEmployee Training

All employees will receive training and have a opportunity to read a copy of the drug, alcohol and contraband policyprior to the implementation of the policy.New employees will receive training and have a opportunity to read a copy of the drug, alcohol and contrabandpolicy.The training will include: Drug and Alcohol Policy. Films: Drugs at Work, Getting Help, Drug Testing, Finding Solutions. Signed receipt of training regarding this policyEach employee will be required to sign a statement certifying that they have read and/or have had an opportunity toread a copy of the drug, alcohol and contraband policy.

Record KeepingGEC will retain in the employees' file the following:

The signed statement certifying that the employee received training and an opportunity to read a copy of thepolicy. The copy of the signed certificate that the employee submitted to a drug and/or alcohol test. The date of such test. The location of such test. The identity of the person or entity performing the test. Whether the test finding was positive or negative.GEC will maintain an annual summary of the records related to the administration and results of the drug and/oralcohol testing. The records for DOT regulated employees and non-DOT employees will be separately maintained.The summary will include, at a minimum: Total number of drug and alcohol tests. The total number of employees who tested positive for drugs and/or alcohol. The disposition of each employee who was positive for a drug and/or alcohol test.

Total number of drug and alcohol tests administered in each category:- Pre-employment- Reasonable suspicion- Random

Discrimination and HarassmentSexual harassment and racial discrimination is unlawful under Title VII of the Civil Rights Act of1964. All employees have the right to be free from sexual harassment and racial discrimination in the workplacewhether from coworkers, supervisors or managers. This policy also applies to any of the GEC Customer Sites.

Definitions of BehaviorSexual harassment in the workplace exists where an individual must submit to unwelcome conduct of a sexualnature in order to be a beneficiary of employment opportunities. It is discriminatory to base an employment decision

such as whether to hire, promote or terminate an individual on that individual's submission to or rejection of,unwelcome sexual advances, requests of sexual favors, or any verbal or physical conduct of a sexual nature.Sexual harassment also exists where the conduct of a coworker or supervisor unreasonably interferes with anemployee's work performance or creates a hostile or offensive work environment.Gender or sexual orientations are irrelevant.Racial discrimination exists where an employee is referred to in a derogatory manner due to race. Racialdiscrimination also exists when employees are denied employment, promotion or other job opportunities because ofrace.Behavior that can be indicative of sexual harassment and racial discrimination can include:



23/55

DRA

Working towards a Gruener environment Comments, jokes of a sexual or racial manner

Leering or ogling Unwelcome invitations to engage in sexual activity Physical touches of a sexual nature Pressure to engage in sexual activity as a condition of employment or promotion Sexual assault Racial slander, name calling or insinuation

Complaint ProcedureAn individual that believes he or she is being sexually or racially harassed should notify theSafety Manager. If the complaint happens to be against the Safety Manager, the complaint should then be directed tothe President of the company.All complaints will be taken seriously and investigated. The Safety Manager will investigate each complaint byinterviewing the complaining party, the accused individual, and other personnel such as witnesses to obtain

sufficient, factual information upon which to make a determination.The investigation may include additional items if deemed appropriate.If at the conclusion of the investigation, it is found that sexual harassment or racial discrimination/ harassment hasoccurred, the Safety Manager will report his findings to the President.Personnel who engaged in sexual or racial harassment or discrimination will be terminated.The complaining party will be advised as to the final disposition of the complaint.

ConfidentialityComplaints and investigations will be handled in a confidential manner whenever possible.Employees interviewed during an investigation will be required to maintain confidentially.

RetaliationRetaliation against personnel making a claim of sexual or racial harassment or discrimination is prohibited.

Individuals who believe they are being retaliated against because of their complaint should notify the SafetyManager or President as outlined in the proceeding paragraphs.Personnel who retaliate against a claimant will be terminated.By signing the below acknowledgement, I confirm that I understand and agree to comply with GEC's Sexual andRacial Harassment or Discrimination Policy including possible termination for violation of the policy.NameDate



24/55

DRA

Working towards a Gruener environmentEmergency Action Plan

PrefaceThe purpose of this procedure is to inform employees of the appropriate actions to be taken in the event of chemical,fire, storm, or other type emergencies. This program applies to all employees.

Emergency EvacuationIn the event of an emergency requiring an evacuation, an announcement will go over the internal intercom systemalerting every one of the emergency and orders to evacuate.Proceed to the nearest exit away from danger.Assemble in the front of the building at least two hundred feet away from the building. Do not assemble indriveways or streets where there is potential to block emergency vehicles.Relocate assigned staging area if smoke or fumes are present.Report directly to your supervisor and notify him/her of any injuries if necessary. Do not go to your vehicles. Do not

leave the property until given permission to do so. Do not enter the building until given clearance by the firedepartment.Planned practice evacuation will be held without notice to anyone except the Safety Managers and CorporateOfficers.

Tornado ProceduresIn the event a tornado strike is eminent, personnel will be instructed by office intercom, if available, of the danger. Personnel must assemble in interior office areas and seek shelter under desks. If time permits, personnel should evacuate shop and garage areas and go to the nearest office sheltered from thedanger of flying equipment, chemical containers or tools.The Safety Manager shall designate these areas at each facility.In the event that time does not allow for personnel to evacuate to their designated tornado shelter; Close all doors and windows, including overhead doors.

Stay at least twenty feet away from all outside walls. Seek shelter under workbenches.Personnel shall not be assembled in large open areas such as the auditorium or cafeteria.Do not allow personnel to leave the building until the tornado has passed and high winds have subsided. Due topossible flying debris, they will be safer inside than outside.Do not go near downed wires. There may be a possibility for electrocution. Notify the Safety Manager if downedpower lines are found and avoid the area.

Reporting A FireThere are four basic classifications of fires: Class A fires involve combustible material such as paper, wood, cloth and some plastic and rubber material. Class B fires involve flammable and combustible liquids, grease and gas. Class C fires involve energized electrical equipment Class D fires involve combustible metals such as magnesium or phosphorus.Trained personnel may use a fire extinguisher on small fires. The fire extinguishers installed at GEC facilities areapproved for Class A, B and C fires.In the event the fire extinguisher is not capable of extinguishing the fire or the fire is uncontrollable, close all doorsand proceed to the nearest telephone out of the affected area and dial 9-911 to call the fire department. Notify theswitch board operator by any means necessary to ensure the evacuation of the building.The switchboard operator will announce the evacuation over the internal intercom system.The switchboard operator must also contact the Safety Manager.



25/55

DRA

Working towards a Gruener environmentIf conditions and time permits, the Safety Manager will take the MSDS binder during the evacuation to assist the

fire department in identifying chemical involvement and potential hazards and extinguishing media.If fire is located outside of the building, personnel must remain inside with all doors closed and turn allheating/cooling units off at the thermostat.

Emergency Action PlanChemical ReleaseIf a chemical release emergency should occur, the Safety Manager must be immediately notified.They must be informed of the emergency type, location, quantity, and type chemicals involved. If the release is afternormal working hours, the individual observing the release shall contact the Safety Manager so that the appropriateresponse personnel can be notified.The Safety Manager will determine whether the release constitutes an actual emergency response situation, orwhether it is merely an incidental workplace release that can safely be absorbed, neutralized, or otherwise controlledat the time of release by employees in the immediate release area, or by maintenance personnel.If the release is determined to be an actual emergency response situation: Evacuate the area. Contact GEC emergency response personnel listed in the on-call rotation.If the release is determined to be incidental and can be safely controlled: Check the MSDS to determine the proper personal protective equipment to be worn. Stop the source of the leak by closing valves, pumps, ventilation ports, etc. Cover or plug drains and other escape routes. Patch holes with patch kits, valve plugs or whatever is appropriate for the leak. Contain the spill; method depends upon the chemical and type of container. Rotate and/or shift storage containers to relocate the leaking area to the top, if possible. Repair the container or place in over-sized container that will contain leaking material. Channel spill, open a trench, make a simple dike from absorbent material, pump spill to chemical sewer, or takewhatever other steps that may be necessary to prevent spread. Use appropriate material to soak up spill, put in appropriate containers for disposal.

When spill has been contained and placed in appropriate container, insure that protective equipment is thoroughlydecontaminated before removal.

Medical EmergencyIf a medical emergency arises, dial 911 and notify the switchboard operator.Most GEC personnel are trained in First Aid and CPR. Trained personnel will determine if the local emergencyservice needs be notified.Trained personnel will provide emergency services until emergency services arrive.Emergency services will determine if further care is required upon arrival. If the victim refuses further treatment, thevictim must sign a statement refusing the offered treatment and transport.

Earthquake Procedures Personnel should take cover were they are.

Stay away from windows and heavy equipment that may fall over. Drop down to the floor and take cover under a sturdy desk or workbench. Hold onto the desk or workbench and be prepared to move with it. Remain under the desk or workbench until the earthquake is over. Evacuate the building.

Training & DocumentationInitial training in the Emergency Action Plan will be conducted during the orientation of all new employees.Retraining will occur annually and whenever a change to the Emergency Action Plan is enacted.



26/55

DRA

Working towards a Gruener environmentAll training shall be documented.

Documentation records shall be maintained in the Corporate Safety Office.



27/55

DRA

Working towards a Gruener environmentFall Protection

PrefaceThis policy is designed to provide a standard operating procedure for the recognition of a fall hazard and the use ofprotective equipment.Although GEC is not directly involved in the construction or erection of buildings or sites, personnel may berequired to work elevated areas where fall hazards exist.

EquipmentAll personnel who may work in elevated areas will be issued harnesses and lanyards. Upon hiring and annuallythereafter, personnel will receive training on the use, operation and inspection. Body belts will not be issued orpermitted for use.Other fall protection equipment may include self retracting life lines, beam anchors, pass through tie off adapters,tripods, carabiners and in some cases winches.

All employees are responsible for the condition of their equipment. Equipment misuse or abuse may significantlyreduce or eliminate its effectiveness. Altering or abusing equipment will result in disciplinary action up to andincluding termination.GEC will only purchase fall protection equipment from manufacturers who ensure compliance with currentstandards and regulations.

Mandatory Equipment Specifications Lanyards will have a minimum breaking strength of 5000 pounds. Self-retracting lifelines and lanyards which automatically limit free fall distance to two feet or less shall be capableof sustaining a minimum static tensile load of 300 pounds. Anchorages to which personal fall arrest equipment is attached shall be capable of supporting at least 500 poundsper employee attached.

Equipment InspectionPrior to use, all fall protection must be inspected.Any component with any significant defect such as cuts, tears, abrasions, mold, undue stretching, alterations,damage due to deterioration, contact with fire, acids, or other corrosives, distorted hooks or faulty hook springs,tongues unfitted to the shoulder of buckles, loose or damaged mountings or non functioning parts must be removedfrom service and disposed of or destroyed.All equipment defects or damage must be reported to the Safety Manager immediately for replacement.

UsePrior to working at elevated heights, the work area must be evaluated for fall hazards so that the proper equipmentrequirements, other than the lanyard and harness, can be determined to ensure the safest possible operation.Tie-offs must be at such a height to limit free fall to no more than two feet. If work requires the use of a motorizedlift or scaffolding, every attempt should be made to secure to a tie off point at least two feet overhead.Floor and wall openings, which are not normally exposed, shall be covered or properly barricaded at all times.Host employers or construction contractors are required to have fall prevention plans in place. They are required toinform all other personnel or sub contractors of the requirements of the plan. GEC personnel are required to followsuch plans to ensure compliance and personal safety.Failure or neglect to use fall protection equipment when it is required will result in disciplinary action up to andincluding termination.

Fire Safety



28/55

DRA

Working towards a Gruener environmentPreface

The purpose of this procedure is to provide guidelines to minimize or eliminate fire hazards in the workplace.

Fire ExtinguishersExtinguishers approved for extinguishing Class A, B and C fires are located in every vehicle.Extinguishers must be posted within a travel distance not to exceed 50 feet.If a vendor is performing monthly inspections of fire extinguishers, the vendor must provide documentationidentifying each extinguisher and the functional status of each extinguisher.If a vendor is not used, the Safety Manager must inspect fire extinguishers monthly. Monthly inspections willinclude: Ensuring full charge. Cylinder and hose integrity are intact. Hanging at least 48 inches off of the ground. Signs indicating location are visible.

Obstructions are not blocking access. The annual certification is current.Fire extinguisher must be taken out of service or replaced if found to be defective or damaged in any way. Onlyvendors approved to service fire extinguishers will perform maintenance or repairs.An approved vender must certify extinguishers annually. Fire extinguishers found to be past due for annualcertification must be taken out of service immediately and reported to the Safety Manager

Fire Extinguisher UseFire extinguisher training is provided during orientation and annually thereafter. The P.A.S.S. method should beused when operating a fire extinguisher. PULL the pin on the fire extinguisher. AIM the hose at the base of the fire. SQUEEZE the trigger on the extinguisher.

SWEEP the base of the fire with the extinguishing media.If the fire is not extinguished, leave the area, close the door to the area, notify the switchboard operator and dial 911.

HousekeepingTo reduce the risk of a fire or prevent a fire from spreading, good housekeeping is vital in minimizing this risk.Good housekeeping is everyone's responsibility.To control the accumulation of combustible material, such as paper, cardboard or wood, refuse must be emptied atleast three times per week.Aisle ways must be kept clear of obstructions and combustible material.Flammable chemicals must be kept in flammable storage cabinets when not in use. Smoking is not permitted in thepresence of flammable material. Never place flammable material near sources of heat or ignition.

Electrical Fire HazardsFrayed or damaged electrical cords may produce a current or spark that may ignite combustible or flammablematerial. Equipment with frayed or damaged electrical cords or exposed wires must be taken out of service andrepaired or replaced.Electrical fires often occur during fueling operations caused by static discharge. Portable gas cans must never befilled in the back of a truck bed. They must always be placed on the ground to prevent a spark from igniting the fuelduring filling.Prior fueling vehicles, it is good practice to touch the metal on the vehicle for grounding and static discharge prior tofueling the vehicle.



29/55

DRA

Working towards a Gruener environmentNever leave the fuel nozzle unattended while fueling. If your hand leaves the fuel nozzle for any reason, always

touch the metal of the vehicle, away from the fuel tank opening, before handling the fuel nozzle. This practice willgreatly reduce the chance of a static spark near fuel vapor.

Forklifts

PrefaceThe purpose of this procedure is to ensure that only trained personnel operate forklifts in a safe manner.

OperationThe following rules must be followed at all times while operating a forklift: Trucks shall not be driven up to anyone standing in front of a bench or other fixed object. No person shall be allowed to stand or pass under the elevated portion of any truck, whether loaded or empty.

Unauthorized personnel shall not be permitted to ride on or operate powered industrial trucks. It is prohibited to extend arms or legs outside the past the width or height of the truck. Riders, other than the operator, are prohibited from getting onto the forklift. When a powered industrial truck is left unattended, load engaging means shall be fully lowered, controls shall beneutralized, power shall be shut off, and brakes set. Wheels shall be blocked if the truck is parked on an incline. A powered industrial truck is unattended when the operator is 25 ft. or more away from the vehicle which remainsin his view, or whenever the operator leaves the vehicle and it is not in his view. When the operator of an industrial truck is dismounted and within 25 ft. of the truck still in his view, the loadengaging means shall be fully lowered, controls neutralized, and the brakes set to prevent movement. A safe distance shall be maintained from the edge of ramps or platforms while on any elevated dock, or platform orfreight car. Trucks shall not be used for opening or closing freight doors. Brakes shall be set and wheel blocks shall be in place to prevent movement of trucks, trailers, or railroad carswhile loading or\ unloading. Fixed jacks may be necessary to support a semi-trailer during loading or unloading when the trailer is not coupledto a tractor. The flooring of trucks, trailers, and railroad cars shall be checked for breaks and weakness before they are drivenonto. There shall be sufficient headroom under overhead installations, lights, pipes, sprinkler system, etc. An overhead guard shall be used as protection against falling objects. It should be noted that an overhead guard is intended to offer protection from the impact of small packages, boxes,bagged material, etc., representative of the job application, but not to withstand the impact of a falling capacity load. A load backrest extension shall be used whenever necessary to minimize the possibility of the load or part of itfrom falling rearward.

TravelingOther trucks traveling in the same direction at intersections, blind spots, or other dangerous locations shall not bepassed.

The driver shall be required to slow down and sound the horn at cross aisles and other locations where vision isobstructed. If the load being carried obstructs forward view, the driver shall be required to travel with the loadtrailing.The driver shall be required to look in the direction of, and keep a clear view of the path of travel.When ascending or descending grades in excess of 10 percent, loaded trucks shall be driven with the load upgrade.On all grades the load and load engaging means shall be tilted back if applicable, and raised only as far as necessaryto clear the road surface.Stunt driving and horseplay shall not be permitted.Running over loose objects on the roadway surface shall be avoided.



30/55

DRA

Working towards a Gruener environmentWhile negotiating turns, speed shall be reduced to a safe level by means of turning the hand steering wheel in a

smooth, sweeping motion. Except when maneuvering at a very low speed, the hand steering wheel shall be turned ata moderate and even rate.

LoadingOnly stable or safely arranged loads shall be handled. Caution shall be exercised when handling off-center loadswhich cannot be centered.Only loads within the rated capacity of the truck shall be handled.The long or high (including multiple-tiered) loads which may affect capacity shall be adjusted.Trucks equipped with attachments shall be operated as partially loaded trucks when not handling a load.A load engaging means shall be placed under the load as far as possible; the mast shall be carefully tilted backwardto stabilize the load.Extreme care shall be used when tilting the load forward or backward, particularly when high tiering. Tiltingforward with load engaging means elevated shall be prohibited except to pick up a load. An elevated load shall not

be tilted forward except when the load is in a deposit position over a rack or stack. When stacking or tiering, onlyenough backward tilt to stabilize the load shall be used.

Forklift InspectionsPrior to use, forklifts must be inspected to ensur

gec draft safety manual

Documents