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HEALTH & SAFETY POLICIES MANUAL M. Sullivan & Son Limited

Sullivan| Health and Safety Section 1 1 | P a g e

HEALTH & SAFETY POLICIES MANUAL

WE SHALL PERFORM ALL WORK AT ALL TIMES IN THE SAFEST MOST EFFICIENT MANNER POSSIBLE

CONSISTENT WITH GOOD EMPLOYMENT AND BUSINESS PRACTICES.

M. Sullivan & Son Limited



INTRODUCTION



Table of Contents RECORD OF REVISION .......................................................................................................................................................... 7

ROLES AND RESPONSIBILITIES ......................................................................................................................................... 11

SUPERVISOR RESPONSIBILITIES ...................................................................................................................................... 13

WORKER RESPONSIBILITIES ............................................................................................................................................. 15

TASK ANALYSIS ................................................................................................................................................................... 17

DAILY RE-START JOB BRIEFING ......................................................................................................................................... 22

SAFE WORK PRACTICES ..................................................................................................................................................... 29

HOUSEKEEPING ................................................................................................................................................................... 35

ASBESTOS AWARENESS ..................................................................................................................................................... 37

USE OF CLEANING SOLVENTS AND FLAMMABLES .......................................................................................................... 39

COMPRESSED GAS CYLINDERS ......................................................................................................................................... 40

USE OF EXPLOSIVE ACTUATED TOOLS ............................................................................................................................. 41

USE OF HAND TOOLS .......................................................................................................................................................... 42

USE OF POWER TOOLS ....................................................................................................................................................... 43

USE OF PNEUMATIC TOOLS AND COMPRESSED AIR ...................................................................................................... 44

USE OF MOBILE EQUIPMENT ............................................................................................................................................. 45

USE OF COMPANY VEHICLES ............................................................................................................................................. 46

INSTRUCTION FOR SIGNAL PERSON(S) policy ................................................................................................................ 48

USE OF CHAINSAWS............................................................................................................................................................ 49

POWERED ELEVATING WORK PLATFORMS ...................................................................................................................... 51

MACHINE/EQUIPMENT GUARDING ................................................................................................................................... 53

WORKING ALONE ................................................................................................................................................................ 54

SAFE WORK PROCEDURES ................................................................................................................................................. 56

WORKING AT HEIGHTS ....................................................................................................................................................... 57

CONFINED SPACE ENTRY ................................................................................................................................................... 60

SAFE WORK and RESCUE PLAN, ........................................................................................................................................ 63

WORKING IN THE VICINITY OF HIGH VOLTAGE EQUIPMENT ......................................................................................... 65

Rescue Plan for Working on Ice Policy .......................................................................................................................... 67

WATER RESCUE PLAN ......................................................................................................................................................... 68

USE OF LADDERS................................................................................................................................................................. 69

HOISTING & RIGGING ......................................................................................................................................................... 71



DISTRACTED DRIVING......................................................................................................................................................... 72

EXCAVATION AND TRENCHING .......................................................................................................................................... 73

LOCK OUT / TAG OUT / ZERO ENERGY PROCEDURES ................................................................................................... 76

Safe Work procedure for using Land sport aluminum ramps to load equipment ................................................ 79

SILICA – SAFE WORK PROCEDURES.................................................................................................................................. 80

TRAFFIC CONTROL .............................................................................................................................................................. 83

WELDING AND CUTTING PROCESSES ............................................................................................................................... 86

VEHICLE RECOVERY SAFE WORK PROCEDURE: ............................................................................................................... 88

FIRE PROTECTION PLAN ..................................................................................................................................................... 90

PROCEDURES FOR THE HANDLING, USE AND STORAGE OF PROPANE ........................................................................ 92

PROCEDURES FOR THE HANDLING AND STORAGE OF FUELS, GASOLINE & DIESEL .................................................. 93

BATTERY ROOM WORK ...................................................................................................................................................... 99

SAFE WORK PROCEDURE – DRILLING ASBESTOS-CONTAINING MATERIAL (ACM) ................................................... 104

COMPANY RULES: ............................................................................................................................................................. 107

DISCIPLINARY ACTION ..................................................................................................................................................... 109

PERSONAL PROTECTIVE EQUIPMENT ............................................................................................................................. 113

PREVENTATIVE MAINTENANCE ........................................................................................................................................ 119

TRIP INSPECTIONS/COMMERCIAL MOTOR VEHICLES: ................................................................................................. 123

FACILITY MANAGEMENT ................................................................................................................................................... 126

ORIENTATION .................................................................................................................................................................... 129

TRAINING ........................................................................................................................................................................... 138

CRISIS COMMUNICATION ................................................................................................................................................. 142

WORKPLACE SAFETY AND COMPLIANCE INSPECTION POLICY ................................................................................... 146

PREVENTATIVE MAINTENANCE ........................................................................................................................................ 148

TRIP INSPECTIONS/COMMERCIAL MOTOR VEHICLES: ................................................................................................. 151

FACILITIES MANAGEMENT ................................................................................................................................................ 154

ACCIDENT/INCIDENT/NEAR MISS/INVESTIGATIONS AND REPORTING ..................................................................... 156

EMERGENCY RESPONSE POLICY ..................................................................................................................................... 160

FIRE PROTECTION PLAN ................................................................................................................................................... 162

POWER LINE CONTACT POLICY ....................................................................................................................................... 164

SAFETY STATISTICS AND RECORDS ................................................................................................................................ 166

LEGISLATION ..................................................................................................................................................................... 170



OCCUPATIONAL HEALTH .................................................................................................................................................. 173

SILICA – SAFE WORK PROCEDURES................................................................................................................................ 175

FIRST AID ........................................................................................................................................................................... 179

HEALTH & SAFETY REPRESENTATIVE(S) ........................................................................................................................ 181

ANTI-VIOLENCE/ANTI-HARASSMENT PROCEDURES .................................................................................................... 186

RETURN TO WORK PROGRAM ......................................................................................................................................... 194

MANAGEMENT REVIEW – HEALTH & SAFETY ................................................................................................................. 201

WORKPLACE HAZARDOUS MATERIAL INFORMATION SYSTEM (WHMIS) ................................................................... 206

COMPANY DEDICATED VEHICLE POLICY ........................................................................................................................ 209

DRIVER ACKNOWLEDGEMENT ......................................................................................................................................... 211

INSURANCE CLAIMS – PROTOCOL .................................................................................................................................. 212

CELL PHONE/ENTERTAINMENT DEVICES ON MS&S CONSTRUCTION PROJECTS ..................................................... 216

WORK REFUSAL PROCESS ............................................................................................................................................... 218

OFFICE SAFETY .................................................................................................................................................................. 217



RECORD OF REVISION YEAR MANUAL REVIEWED & UPDATED DATE UPDATED ENTERED BY

1992 Page 4&5 and Preface & Recipient

Control Policy July 30/92 J. David Thom

1993 Pages 4,5 & 6 revised, Appendix “A”

Added July 22/93 J. David Thom

1994 No revisions July 29/94 J. David Thom 1995 No revisions July 21/95 J. David Thom 1996 No revisions Nov. 29/96 J. David Thom 1997 No revisions Dec. 19/97 J. David Thom 1998 No revisions Jan. 15/98 J. David Thom 1999 Occupational Illness from replaced by

WSIB Abilities form Feb. 19/1999 J. David Thom

2000 No revisions Mar. 15/00 J. David Thom 2001 Appendix “B”

(Confined Space Work Procedure) Appendix “C” Lockout (Electrical Equipment)

Mar. 29/01 J. David Thom

2002 Workplace Safety Personnel Hazard Assessment WHMIS Emergency Response (New Inserts)

Feb. 1/02 J. David Thom

2003 Fall Protection and Table of Contents

Jan. 24/03 J. David Thom

2004 Forklift Operation and Orientation


2005 Machine/Equipment Guarding Safety Program Review Task Analysis Temporary Gas Installations


2006 Excavation & Trenching Procedure Workplace Inspection Policy Traffic Control Procedure Vehicle Maintenance/Trip Inspections


2007 Revised Lock Out / Tag Out Procedure Jan. 18/07 J. David Thom 2008 Safety Policy Format Revised Into Divisions

Confined Space Procedure updated WHMIS Procedure Updated


2009 Accident Report Form Amended Daily Safe Work Plan Added




---2010

Use of Hand Held Wireless Communication Devices Jan. 29/10 J. David Thom

2010 Anti-Harassment Policy Prevention of Workplace Violence Policy

June 14/10 J. David Thom

2011 Orientation Standard – Revised Hazard Recognition and Controls Standards – Revised Return to Work Standards – Revised Management Review Standard – Revised Vehicle Recovery Safe Work Procedure – Developed


2012 Health & Safety Policy Statement – Revised Training Standard – New Communication Standard – New


2013 Company Dedicated Vehicle Policy Insurance Claims Protocol Cell Phone Use on Construction Projects Equipment Inspections


2014 Asbestos Awareness Procedure - ISNetworld Excavation & Trench Procedure - ISNetworld Fire Extinguisher Equipment – ISNetworld Forklift Operation – ISNetworld Hoisting & Rigging – ISNetworld Personal Protective Equipment – ISNetworld Subcontractor Management – ISNetworld Task Analysis – ISNetworld Welding & Cutting Process ISNetworld WHIMIS – ISNetworld Health & Safety Awareness Training

June 4/14 Wes Fenton

2015 Site Safety Inspection Report Garage Safety Inspection Report

March 2015 Wes Fenton

2016 New Policy Statements Signed Competency Confined Space Entry Lockout Workplace Safety Personnel and Committees

January 2016 March 2016

Wes Fenton Wes Fenton

2017 New Policy Statements Reviewed & Signed: - Health & Safety Policy Statement - Company Dedicated Vehicle Policy - Safety & Accident Control Policy - Prevention of Workplace Violence - Workplace Anti-Harassment Policy

January 2017

Wes Fenton



2018 New Policy Statements Signed: - Health & Safety Policy Statement - Company Dedicated Vehicle Policy - Safety & Accident Control Policy - Prevention of Workplace Violence - Workplace Anti-Harassment Policy

Change of Organizational Chart 2.2 - Insert Daily re-Start Job Briefing Template 4.19 - Remove Job Safety Plan & Replace with Propane Handling Procedure 4.20 – Adding Handling Fuels, Gasoline & Diesel Procedure 4.21 – Adding Drilling Asbestos Procedure 4.22 – Adding Battery Room Procedure 8.1 – Inserted Orientation for Salary Employees Template 8.3 – Revised Crisis Communication Procedure 12.1 – Remove 2 charts & replace with new graphs 14.1 – Revised Occupational Health Procedure 14.2 – Revised Silica Procedure 15.1 – Revised First Aid Procedure 18.3 – Revised Offer of Modified Work

February 2018

Wes Fenton



ROLES AND RESPONSIBILITIES PURPOSE: Developed to ensure that M. Sullivan & Son Limited management personnel comply with their specific requirements as per the Occupational Health and Safety Act of Ontario.

POLICY:

An employer shall ensure that:

• The equipment, materials and protective devices as prescribed are provided.

• The equipment, materials and protective devices provided by the employer are maintained in good condition.

• The measures and procedures prescribed are carried out in the workplace.

• The equipment, materials and protective devices provided by the employer are used as prescribed.

• A floor, roof, wall, pillar, support or other part of a workplace is capable of supporting all loads to which it may be subjected without causing the materials therein to be stressed beyond the allowable unit stresses.

• Information, instruction, and supervision are provided to a worker to protect his/her health and safety.

• In a medical emergency for the purpose of diagnosis or treatment, provide, upon request, information in the possession of the employer, including confidential business information, to a legally qualified medical practitioner and to such other person as may be prescribed.

• When appointing a supervisor, appoint a competent person.

• A worker or a person in authority over a worker is aware of any hazard in the work and in the handling, storage, use, disposal and transport of any article, device, equipment, or of a biological, chemical or physical agent.

• Assistance and co-operation are afforded to a committee and a health and safety representative in the carrying out by the committee and the health and safety representative of any of their functions.

• Only employ in and about the workplace a person of such age as may be prescribed.

• To take every reasonable precaution in the circumstances for the protection of a worker.

• To post in the workplace, a copy of the occupational Health and Safety Act of Ontario and any explanatory material prepared by the Ministry, outlining the rights, responsibilities and duties of workers.

• To prepare and review at least annually a written health and safety policy and develop and maintain a program to implement the policy.

• To post at a conspicuous location in the workplace a copy of the corporate Health and Safety Policy.



• To provide the committee or to a health and safety representative the results of a report respecting occupational health and safety that is in the employer’s possession and if that report is in writing, a copy of the portions of the report that concern occupational health and safety and advise workers of the results of the report and if the report is in writing, make available to them on request, copies of the portions of the report that concern occupational health and safety.

• Where so prescribed, to provide a worker with written instructions as to the measures and procedures to be taken for the protection of a worker, and carry out such training programs for workers, supervisors and committee members as may prescribed.

COMMUNICATION:

This policy will be reviewed with management personnel at a management safety meeting.



SUPERVISOR RESPONSIBILITIES PURPOSE: Developed to ensure that Sullivan supervisory personnel comply with the requirements of the Occupational Health and Safety Act, the construction regulations and the corporate Health and Safety Policy.

Note: All supervisory personnel must complete IHSA’s supervisor’s training course.

POLICY:

A supervisor shall ensure that:

• a worker works in a manner and with protective devices, measures and procedures required by the Occupational Health and Safety Act of Ontario

• a worker uses or wears the equipment, protective devices, and clothing that the worker’s employer requires to be used or worn

• a worker is advised of the existence of any potential or actual danger to the health and safety of the worker of which the supervisor is aware

• where prescribed provide the worker with written instructions as to the measures and procedures to be taken for the protection of the worker

• every reasonable precaution is taken, in the circumstances, for the protection of a worker

Ensure:

• the work in his/her workplace is supervised at all times either personally or by having an assistant, who is a competent person, do so personally

• either he/she or a competent person appointed by the supervisor inspects all machinery and equipment, including fire extinguishing equipment, magazines, electrical installations, communication systems, sanitation and medical facilities, buildings and other structures, temporary supports and means of access and egress at the project to ensure that they do not endanger any workers

• an inspection is made at least once a week or more frequently, as the supervisor determines is necessary, in order to ensure that the machinery and equipment do not endanger any worker

• a competent person performs test and observations necessary for the detection of hazardous conditions on the project

Corporate Health and safety policy responsibilities:

Ensure:

• all legislated documents and booklets are posted at the workplace

• emergency procedures are developed for the workplace, reviewed and posted



• hazard assessments are completed for the work being assigned

• orientations are completed as per company policy

• pre-start daily briefings are completed

• safety talks and meetings are conducted as per Corporate and client policies

• substandard acts or conditions are corrected

• health and safety representatives and or committees are established for the workplace as per company policy

• worker training records are available

• that accident, incident, injury and near miss reports are promptly reported to the Corporate Health and Safety Officer and assistance is provided to him/her in carrying out the investigation

• assistance is provided to anyone injured in the workplace and transportation if needed or requested, is provided

• that allegations or acts of violence and harassment are dealt with appropriately

COMMUNICATION:

This policy will be communicated to supervisors through a safety meeting



WORKER RESPONSIBILITIES PURPOSE: Developed to ensure Sullivan workers and subcontractor employees comply with their responsibilities under the Occupational Health and Safety Act, WHMIS regulations and the Corporate Health and Safety Policy.

POLICY:

Workers shall ensure that:

• they understand their right to know, their right to participate and their right to refuse

• they report all accidents, incidents, near misses, injuries, and discomforts to their manager/supervisor forthwith

• they are trained to operate the piece of equipment they are assigned to operate

• they work in compliance with the provisions of the Occupational Health and Safety Act of Ontario and the regulations

• they use or wear the equipment, protective devices or clothing that their employer requires to be used or worn

• they report to his/her supervisor the absence of or defect in any equipment or protective device of which the worker is aware and which may endanger himself, herself or another worker

• they report to his/her employer or supervisor any contravention of this Act or the regulations or the existence of any hazard of which he or she knows

• they do not remove or make ineffective any protective device without providing an adequate temporary protective device and when the need for removing or making ineffective the protective device has ceased, the protective device shall be replaced immediately

• they do not use or operate any equipment, machine, device or thing or work in a manner that may endanger themselves or any other worker

• they do not engage in any prank, contest, feat of strength, unnecessary running or rough and boisterous conduct

NOTE:

A worker is not required to participate in a prescribed medical surveillance program unless the worker consents to do so.

COMMUNICATION:

This policy will be communicated to workers at time of orientation and or through safety meeting/talks.



HAZARD ASSESSMENT



TASK ANALYSIS HAZARD RECOGNITION AND CONTROLS PURPOSE: The management of Sullivan will attempt to reduce and or eliminate workplace hazards by recognizing, assessing and implementing controls, where possible.

Before starting, consider the work to be undertaken, the individual performing the work and the environment in which it will be done. The objective is to identify the “Significant risks”.

DEFINITION:

A safety hazard is an act or condition that has the potential to cause loss, injury or harm to life, health or property.

Hazards may be:

• Physical – noise, vibration and temperature • Chemical – solids, liquids, vapors, gases, dust, fumes or mists that if inhaled, ingested, injected or absorbed

could cause harm • Body Mechanics – work environments that have fixed or awkward postures and or repetitive motions • Biological – things or substances that if they enter the body can cause illness, such as bacteria, fungi, parasites,

insects, and mould • Psychosocial - stressors such as bullying, harassment and or violence • Uncontrolled Energy – electrical mechanical and gravity • Safety – poor housekeeping, inadequate machine guarding improper material handling

HAZARD CLASSIFICATION:

Major: Risk Level: 5 – 6

• A hazard having imminent danger requiring immediate corrective action, e.g.: working at height without fall protection.

Serious: Risk Level: 3 – 4

• A hazardous condition/activity – not imminently dangerous. Should be attended to as soon as possible, e.g.: no kick plate attached to a guardrail system.

Minor: Risk Level: 1 – 2

• A low risk hazard. Generally, does not involve risk of injury or property damage, e.g.: lack of appropriate signage.

RESPONSIBILITIES:

Management:



Develop procedures that provide a means for workers and supervisors to identify and document safety hazards in the workplace before work starts.

Provide training for assessing the hazards associated with a workplace or a work activity and the completion of the “Job Hazard Analysis” reports.

Provide training for the completion of the “Pre-Start Daily Safe Work Plan” Forms.

Supervisors:

Prepare with delegate workers and review a “Job Hazard Analysis Report” before work is commenced, outlining known hazards associated with the work.

Document hazards associated with known work assignments on the “Pre-Start Daily Safe Work Plan” forms and with input from workers develop and document controls and barriers to eliminate and or reduce the hazard.

Encourage workers to report safety hazards encountered in the workplace to supervisor forthwith.

Encourage health and safety committee members to report workplace hazards, known or brought forward to them, so that they are documented and through discussion a plan can be developed to eliminate or reduce the hazard risk.

Take the necessary corrective action to control and or eliminate hazards reported in their workplace and document the actions accordingly.

Workers:

Review the hazard analysis report and implement control suggested to mitigate the risk. Report to the supervisor, new hazards that develop in the workplace which may endanger him/her, other workers, or cause damage to equipment, material or the environment.

COMMUNICATION:

This policy will be communicated to the employees through safety talks/meetings.

Training:

Training will be provided to employees when and where deemed necessary.

EVALUATION:

Management along with the corporate Joint Health and Safety Committee will review this policy annually. Recommendations, if any, will be developed and implemented to ensure continuous improvement of these activities.



Site: Completed by: Date:

Identify Hazard Risk Level Action/Control to be Implemented

Mitigate Risk Level

Risk Level – Assign appropriate Risk Level based on predetermined level of common or frequently conducted task or establish Risk Level Based on Site specific evaluation.

1-2 (Low Risk) 3-4 (Moderate Risk) 5-6 (High or Imminent Risk)



PROCEDURE FOR COMPLETING A JOB HAZARD ANALYSIS REPORT

BREAKDOWN OF JOB STEPS:

• Job or task identified for analysis by supervisor. • Supervisor overseeing the job breaks the job into steps with assistance from workers to be assigned and

or the corporate health and safety officer, representative. • A job step is defined as a segment of the operation necessary to advance the work. • Steps should be kept in the correct sequence.

IDENTIFY ACTUAL/POTENTIAL HAZARDS:

Once the basic steps have been recorded, potential hazards must be identified at each step. This is based on job observation; knowledge of accident and injury causes and experience. To identify potential hazards, consider applicable risks as stipulated below, but no limited to:

• Can any body part get caught in or between object? • Do Tools, machines or equipment present any hazards? • Can the worker(s) make harmful contact with objects? • Can the worker(s) slip, trip or fall? • Can the worker(s) suffer strain from lifting, pushing or pulling? • Are the worker(s) going to be exposed to extreme hot or cold atmospheres? • Is excessive noise or vibration a problem? • Is there a danger from falling objects? • Is lighting sufficient? • Can weather conditions affect task safety? • Is harmful radiation a possibility? • Can contact be made with hot, toxic or caustic substances? • Are dusts, fumes, mists or vapours present or likely to be created?

ELIMINATE THE HAZARD:

This is the most effective measure.

Some examples are but not limited to:

• Choose a different process. • Modify an existing process. • Substitute with a less hazardous substance • Improve the environment with ventilation etc. • Modify or change tools or equipment.



CONTAIN THE HAZARD:

If the hazard cannot be eliminated, contact might be prevented by using enclosures, machine guards, work booths or similar devices.

REVISE THE WORK PROCEDURE:

Consideration might be given to modifying steps that are hazardous, changing the sequence of the steps or adding additional steps, such as locking out energy sources.

REDUCE THE EXPOSURE:

This measure is the least effective and should only be used if no other solutions are possible. One way to minimize exposure is to reduce the number of times the hazard is encountered during the work activity.



DAILY RE-START JOB BRIEFING

PURPOSE:

In interest of creating safe work environments, the management of Sullivan will promote “Pre-Start Job Briefings”. These meetings will be hands-on way to remind workers of the company’s commitment to health and safety and is an opportunity for employees to discuss the known specific task for the day and to identify associated risks/ hazards.

POLICY:

The Pre-Job Briefing should include what is being done, by whom and how it is to be done. Items for discussion may include, but are not limited to:

• Review of high risk tasks, the associated risks and the related precautions and control to do them safely.• The co-ordination of work activities, equipment being used and housekeeping.• Other related activities, previous concerns, and safety alerts, etc.• Discussion and attendance record sign in by workers.

Supervisors/Lead Hands delegating the work are responsible, or to delegate a competent person, to conduct the “Pre-Job Briefing” and complete the briefing form.

Supervisors have a responsibility to advise their workers about any known or potential hazards associated with the work being assigned. Occupational Health and Safety Act of Ontario, section 27.

EDUCATION AND TRAINING

This policy will be reviewed with employees during a safety meeting/talk

M. Sullivan & Son Limited Job Site Hazards Daily Review - Report FormJobsite: Supervisor: Date:

Hazard Prevention Hazard Prevention

Heat Stress General Awareness, Guidelines Posted Inhalation of Harmful Gases Ventilation

Cold Stress / Frostbite / Hypothermia Appropriate Clothing, Hydration Absorption of Harmful Substances Signage, Awareness

High Winds Hypothermia (Warning Signs, Clothing) Spills DSR, MSDS, Whimis

Lightning Tag Lines, secure material Training Labels

48 Hr. Look ahead Stop work, awareness, grounding protection Mitigation Measures Taken

Sunburn Skin & Eye Protection and Reviewed

Slips & trips Maintained Areas, Clear Obsturctions Electrocution Site Procedures Utilized

Falling Objects Overhead Protection Burns Record Keeping

Inadequate access & Egress Signage, Sufficient Exits, Awareness Drowning Energy Sources Identified

Lighting, Appropriate Access Inplace Locks / Tags

Collision Traffic Control Plan, Notification Provided Site Security Signage

Struck-by Signage, High Visiblity Clothing, Signalman, Trespassers Locking of Doors and Gates

Designated Route Theft Material Storage

Machine Tipping Competent person Machine Tipping Outriggers, Terrain Conditions, Loads

Overhead Power Lines Signage, Working & Clearances, Signal Person Overhead Electrical Contract Rated Capacity, Swing Area, Signalman

Electrocution Locates / Permits Falling Objects Locates, Permits

Cave-in Sloping / Shroring / Free of Water Overweight Load Inspections Completed Daily

Falls Barricades, Signage, Provide Sufficient Access/Egress Undergound Contact Barricades / Signage

Struck By P.P.E. Lighting, Awareness Fall Arrest / Trained

Falls Fall Arrest / Travel Restraing Electrical Shock Guards in Place

Slips/Trips Signage, Working & Clearances, Signal Person Flying Debris Condition

Unprotected Opeinings Openings / Holes Covered / Marked Cuts Proper Use

Inadequate Platform Scaffold Planning Equipment Inspections, Access Condition Noise GFCI, Grounding Pins

Improper Access Rescue Plan, House Keeping Vibration Eye Protection, Ear Protection

Guardrails, Toe Boards, Bracing Anti Vibration Gloves

Eye Damage Eye Protection Atomospheric Hazards Air Monitoring, Lighting

Flames, sparks & Burns Public Way Projection, Fire Watch as Req'd Access / Egress Permits, Resuce Plan

Inhalation, Fumes/Dust Ventilation, PPE Loto, Training

Electrocution Permits Acquired Crush, Struck By Rated Load, Training

Inhalation of Harmful Substances Locates, Identification, Verify Electrocution Condition, Insepctions

Falling Objects Compressed Gas Storage Lifting Limits Signal Person / Swamper

Designated Substance Report Repetative Tasks Working Clearances

Chutes, Barricades, Signage Posture Signage, PPE

Repetative Tasks Assistance & Ergonomics

#6 Demoltion Hot Work

Possible Risk Possible Risk Comments

#5 Fall Hazzards Ladder Work

Scaffolds

#7 Chemicals, Designated Substances,

Environmental Protection

#8 Loto Work

Protection

#9 Security

#10 Equipment

(Zoom Boom, Forklift, Back-hoe, Pumps)

#11 Tools

#12 Confined

Space

#13 Hoisting, Rigging Material Handling

#1 Weather, Fatigue, Physical Agents

#2 Accesses

#3 Traffic

#4 Excavation Trenching

SQF 148 rev002April 2, 2013 White‐Workplace; Yellow ‐ Client (upon request)

HEALTH & SAFETY POLICIES MANUAL M. Sullivan and Son Limited




SAFE WORK

PRACTICES



SAFE WORK PRACTICES PURPOSE “Safe Work Practices” are written methods outlining how to perform a task safely, minimizing risk to people, equipment, materials and the environment.

Policy

Safe Work Practices are developed by the Company H&S Officer in conjunction with Site Supervisors and H&S Reps. Practices are reviewed by Sr. Management and Workers via JHSC meetings prior to being implemented. Once a new Practice is implemented it will be communicated to workers via in-house training sessions or Tool-Box talks.

PRACTICES:

The management of Sullivan has developed “Safe Work Practices” for the following:

Use of Personal Protective Equipment

General Conditions / Housekeeping

Asbestos Awareness

Use of Cleaning Solvents and Flammables

Use of Compressed Gas Cylinders

Use of Explosive Actuated Tools

Use of Hand Tools

Use of Pneumatic Tools and Compressed Air

Use of Mobile Equipment

Use of Company Trucks

Use of Chainsaws

Use of Powered Elevating Work Platforms

Machine and Equipment Guards

Working Alone



Personal Protection Equipment PURPOSE:

As an employer, Sullivan is committed to ensuring the employees wear and use personal protective equipment.

POLICY:

Selection of PPE outside of that which is mandatory to be worn on all Sullivan sites at any time is to be determined after completing Hazard Assessments, Reviewing MSDS’s and relevant legislation.

PROTECTIVE HEADWEAR:

Every worker shall wear protective headwear at all times when on a construction project or as required by client/customer policy. The protective headwear shall be a CSA or ANSI certified hard hat.

PROTECTIVE FOOTWEAR:

Every worker shall wear protective footwear at all times when on a construction project or as required by management, or by a client / customer policy. The protective footwear shall be CSA certified “Grade 1” work boots, with electric shock resistant soles. If so equipped work boots shall be laced sufficiently so as to provide ankle support and be tied.

PROTECTIVE EYEWEAR:

Every worker shall use protection appropriate in the circumstances when there is a risk of eye injury or when a client policy dictates that eye protection is to be worn.

Workers and their supervisor must assess the degree of risk associated with a task and select the appropriate eye protection. Tinted safety glasses should be worn in bright atmospheres.

Low risk – due to the constantly changing risks in a workplace, it is strongly recommended that workers wear safety glasses at all times when on a project. Safety glasses should also be worn when working on or under vehicles / equipment to make repairs or carry out maintenance work.

Medium risk – safety glasses and a face shield must be worn when, grinding, chipping or drilling etc.

High risk – When there is a high risk of injury to the eyes from flying particles or a substance splash, safety glasses shall be worn. Chemical goggles should also be considered when there is a possibility of a substance splash.

Safety glasses must be CSA certified.

HEARING PROTECTION:

In general, if one is standing at arm’s length from another individual and cannot carry on a conversation in a normal tone of voice because of noise, then hearing protection shall be worn AT ALL TIMES.



Sullivan, as an employer, will take all measures reasonably necessary in the circumstances to protect employees from exposure to hazardous sound levels. The protective measures shall include the provision and use of engineering controls, work practices, and hearing protection devices.

No employee shall be exposed to a sound level greater than an equivalent sound exposure level of 85 dBA.

Employees shall wear/use hearing protection devices appropriate in the circumstances to protect them from sound levels greater than the limit if the engineering controls that are required:

• are not in existence or are not obtainable • are not reasonable or not practical to adopt, install or provide because of the duration or frequency of

the exposure or because of a temporary breakdown of the controls, or • are ineffective to prevent, control or limit exposure because of an emergency

Where practicable a clearly visible sign shall be posted at every entry to an area where the noise level regularly exceeds 85 dBA, warning of the hazard.

Employees will be trained to be diligent in selecting and using appropriate hearing protection for the sound levels exposed to and how to fit and care for it as per the manufacturer’s instructions.

Equipment with noise reduction components is to be used when available and all equipment is to be operated and maintained, as per manufacturer’s specifications, to minimize noise levels.

When employees are present on or in a client premises requiring the use of hearing protection, they shall abide by the client policies.

Hearing protection is provided to employees as follows:

- Ear Muffs which if properly fitted and worn, provide a better noise reduction factor. - Ear plugs must be fitted to provide a good seal. Foam ear plugs should not be reused. Neoprene style

ear plugs may be washed and reused. NOTE THE NOISE LEVEL CHART.



Recommended class of Hearing Protector

Table 1

MAXIMUM NOISE LEVEL (dBA)

RECOMMENDED CLASS OF HEARING PROTECTOR

Less than 85 dBA No protection required Up to 89 dBA Class C Up to 95 dBA Class B Up to 105 dBA Class A Up to 110 dBA Class A plug + Class A or Blass B muff More than 110 dBA Class A plug + Class A or Class B muff and limited

Exposure

TYPICAL NOISE LEVEL MEASUREMENTS FOR CONSTRUCTION

*EQUIPMENT NOISE LEVEL (DBA) AT OPERATOR’S POSITION Cranes 78-103 Backhoes 85-104 Loaders 77-106 Dozers 86-106 Scrapers 97-112 Trenches 95-99 +Pile drivers 119-125 Compactors 90-112 +Explosive-actuated tools 120-140 Grinder 106-110 Chainsaws 100-115 Concrete saw 97-103 Sand blasting nozzle 111-117 Jackhammers 100-115 Compressors 85-104



SKIN PROTECTION:

Workers shall use protection appropriate in the circumstances when there is a risk of injury to the workers skin from a noxious gas, liquid, fume or dust, an object that may puncture, cut or abrade the skin, a hot object, hot liquid or molten metal and radiant heat.

FALL ARREST EQUIPMENT:

When a worker is exposed to a fall hazard he or she shall wear a full body harness adequately secured so as to arrest a fall without the person bottoming out.

Before using a body harness for the first time the individual must be trained in “Working at Heights.” The employer must develop and review with him/her, a written rescue plan.

The full body harness must be properly fitted and adjusted so as to prevent roll out, should the wearer be subjected to a fall.

RESPIRATORY PROTECTION:

When working on sewage systems, with chemicals or substances where the Material Safety Data Sheet (MSDS) recommends or stipulates that respiratory protection be worn, the appropriate type of respirator shall be worn.

Employees required to use respiratory equipment should be deemed to be medically fit to use a respirator and fit tested by a qualified caregiver.

Supervisor(s) shall ensure that workers required to wear a respirator, know how to field test their respirators for fit and how to properly clean and maintain the respirators they are issued as per the manufacturer’s specifications.

Workers wearing respiratory protection should be clean shaven.

Cartridge Colour: General Use:

White Acid Gases

Black Organic Vapours

Purple Hepa Filter (Asbestos)

Grey Dusts, Fumes and Mists



HIGH VISIBILITY CLOTHING

Employees working in an area where they may be endangered by vehicular traffic and or operating equipment must wear a garment that provides a high level of visibility. The garment, as a minimum, should cover the upper portion of the body and may be fluorescent orange or green in colour with reflective stripes on the front and back. For night work, additional stripes or bands must be worn on the arms and legs.

Note: When the high visibility garment is a vest it must be a five-point tear away style with a flame-retardant value if working near energized electrical equipment.

ALL PERSONAL PROTECTIVE EQUIPMENT MUST BE INSPECTED BY THE USER DAILY TO ENSURE IT IS IN A SATISFACTORY CONDITION.

Employees will be responsible for, maintaining the personal protective equipment being used by them, in a good condition.

Damaged or defective equipment must be reported to a supervisor forthwith and taken out of service if warranted.

Communication and Training

This policy will be communicated to employees during “orientation training” and during safety meetings/talks.

Employees will be trained in the selection, use, and care of personal protective equipment as per company policy and manufacturers specifications.



HOUSEKEEPING PURPOSE: The management of Sullivan believe that a clean and organized workplace is a safer and more productive workplace. Accordingly, the following policy has been developed as a guideline for maintaining company workplaces.

POLICY:

• Waste material and debris shall be removed from the workplace to a disposal area and reusable material to a storage area as often as is necessary to prevent a hazardous condition arising or at least one a day.

• Rubbish, materials and other debris shall not be allowed to fall freely from one level to another but shall be lowered of through a chute through or in a container.

• Rubbish, debris and other materials from demolition on a project may be permitted to fall freely or dropped into an enclosed area to which people do not have access.

• A chute shall be adequately constructed and rigidly fastened in place. • If a formwork tie, reinforcing steel, a nail or another object is protruding from concrete or another

surface, may endanger anyone, the protrusion shall be removed, cut off at the surface or otherwise protected as soon as is practicable.

• Material and equipment shall be moved and stored in a manner that does not endanger anyone. No material that is to be moved by a crane or other hoisting device shall be stored under or near an energized overhead electrical conductor.

• Blocking, support chains, metal bands, wire rope and rigging components shall be removed from material or equipment in a manner that does not endanger a worker.

• Material and equipment shall be piled or stacked in a manner that prevents it from tipping, collapsing or rolling. No material shall be stored within 1.8 metres of an opening in a floor or roof, the open edge of a floor, roof or balcony, or the top of an excavation

Exception:

The 1.8 metre rule does not apply to materials stored in a building, or a part of building that is used solely for storing and distributing materials, or to small masonry units, including bricks, blocks and other masonry units, that can be handled by one worker and are to be used at the edge of the floor, roof or excavation and are stacked in a pile whose height is less than the distance from the face of the pile to the edge of the floor, roof, excavation or to an opening in a floor or roof.



• Combustible, corrosive, and or toxic substances shall be stored in suitable containers. • A storage cylinder for compressed gas shall be secured in an upright position and if it is not in use, the

control valve shall be covered by a protective cap that is secured in its proper position. A spent storage cylinder shall not be stored inside a building.

• No storage cylinder for propane shall be placed closer than three metres to a source of ignition or fire. • A flammable liquid or gas shall be stored in a building or storage tank that is suitable and if practicable,

not less than 100 metres from a magazine for explosives. A portable container used to store, or transport flammable liquids shall be approved for the use of the liquid it contains.

• Signs with the work “DANGER” written in legible letters that are at least 150 millimetres high, shall be posted in prominent locations and in sufficient numbers to warn workers of a hazard. They shall be posted adjacent to a hoisting area, under a boatswain’s chair, a suspended scaffold or a suspended platform, at the outlet from a chute, at a means of access to a place where there may be noxious gas, vapour dust or fume, noxious substance, or lack of oxygen and where there is a potential hazard from an energized overhead electrical conductor rated at more than 750 volts.

• The access to and egress from a work area and the work area in which workers are present shall have adequate lighting so as not to create a hazard. A light bulb used in a temporary lighting system shall be enclosed by a mechanical protection system.

• A workplace shall be adequately ventilated by a natural or mechanical means. • An internal combustion engine shall not be operated in an excavation, in a building or other enclosed

structure unless provisions are made to ensure that exhaust gases and fumes will not accumulate therein.

TRAINING:

This policy will be communicated to employees through safety meetings/talks.



ASBESTOS AWARENESS PURPOSE: Sullivan has established a policy for identifying and controlling employee exposure to asbestos containing materials in construction and or demolition activities. O. Reg. 278/05.

DEFINITIONS:

“Asbestos” - Is a natural fibrous material known for its’ strength, ability to withstand high temperatures and its resistance to many chemicals.

“Friable” – Includes asbestos containing material that is loose in texture or easily crumbled.

“Non-Friable” – Includes asbestos containing material that is very durable because it is held together by a compound such as plaster, cement, vinyl and or asphalt.

POLICY:

Whenever work is planned at a location where asbestos is present, workers must be informed about:

• The location of asbestos containing materials or materials assumed to contain asbestos • Whether the material is friable or non-friable and, • The type of asbestos, e.g. Chrysotile, Amosite, or Tremolite etc.

Possible locations of asbestos containing material includes, but is not limited to:

• Sprayed on fireproofing • Pipe and boiler insulation • Loose fill insulation • Asbestos cement products • Acoustical plaster • Vinyl asbestos • Gaskets • Roof felts • Dry-wall joint compound • Ceiling tile, and • 2”X2” porous tile

Most structures between 1930 and 1975 will contain products having substantial amounts of asbestos.

Sample testing must be completed by laboratory to establish whether asbestos is present, the type of asbestos and the amount contained in the product.



Material identified as containing asbestos or possibility containing shall not be disturbed unless workers have been trained in removal using a Type I or II operation by a competent person

A Type III asbestos removal shall be carried out by licensed abatement personnel only.

HAZARDS:

When inhaled, asbestos is known to cause the following diseases:

• Asbestosis • Lung cancer • Mesothelioma

COMMUNICATION & TRAINING

This policy will be communicated to employees through safety meeting/talk.



USE OF CLEANING SOLVENTS AND FLAMMABLES PURPOSE: The purpose of this practice is to establish the general requirements for handling solvents and flammable product.

POLICY:

Whenever possible solvents shall be used that are non-flammable, non-toxic or have a low health and fire risk.

Prior to the use of any products that has potential health or fire risk the supervisor shall ensure the Material Safety Data Sheet for the product is reviewed with all personnel involved.

Combustible, corrosive or toxic substances shall be stored in suitable containers. All toxic corrosive or flammable products shall be stored in a manner that leakage from containers would not contaminate soils or water.

Cleaning solvents shall be contained in dip tanks designed for cleaning and shall not be used from open containers that may cause spillage. Dip tanks shall have a ventilation system or be used in a well-ventilated area.

All used solvents, flammables, or toxic products shall be disposed of in accordance with statutory requirements.

Flammable products shall not be used where there is a potential for a source or ignition.

Personal protective equipment required for handling toxic or flammable products vary according to the specific nature of the hazards and conditions of use. MSDS for the product shall be reviewed for specific requirements.

TRAINING;

This policy will be reviewed with employees during safety meetings/talks.



COMPRESSED GAS CYLINDERS PURPOSE: The purpose of this practice is to establish a minimum standard for the use and handling of compressed gas cylinders.

GENERAL

Compressed gas cylinders shall:

• Be clearly identified as to their contents. • Stored, used and transported in an upright position. • Have gauges removed and protective caps in place when not in use, and during storage and

transportation. • Have cylinder valves and gauges kept clean and free from oil, grease, and other hydrocarbons? • Not be exposed to excessive heat. • Not be place in confined spaces or non-ventilated areas. Hoses from compressed gas cylinders shall be

removed from confined spaces when not in use and during all breaks. • Not be placed near electrical panels or in proximity to welding grounds.

STORAGE:

Oxygen cylinders shall be stored in racks of minimum of 6 metres (20 feet) from occupied buildings. These cylinders shall be separated from fuel gas cylinders, hydrocarbons or other combustible materials by a minimum of 6 metres (20 feet).

Cylinder storage areas shall be identified as to contents of the cylinders.

Storage racks shall be capable of supporting cylinders in an upright position and shall have sound flooring. “No smoking” signs shall be posted in the area. Fire extinguishers shall be placed in the immediate vicinity.

Flashback devices shall be installed at both the regulator and torch end of oxygen/fuel gas systems used for cutting or torch welding.

REFILLING;

Compressed gas cylinders shall only be refilled by authorized personnel in compliance with statutory requirements.



USE OF EXPLOSIVE ACTUATED TOOLS PURPOSE: The purpose of this practice is to establish the general requirements for the explosive actuated tools. POLICY:

All explosive actuated tools must be U.L. approved

All explosive actuated tools shall be operated and maintained in accordance with manufacturers’ specifications.

Manufacturers’ recommendations cover the type of color-coded cartridge for certain materials and applications. As these recommendations cannot cover every material or application, testing may be required. The general rule is to start with the weakest cartridge and increase one load number at a time to reach required penetration.

All operators of explosive actuated tools shall have documented training issued under the authority of the explosive actuated tool manufacture.

Explosive actuated tools shall be designed so that two separate actions are required, pressure against the surface of the material and action of the trigger, before it will fire.

Explosive actuated tools shall never be pointed at anyone, whether loaded or unloaded. Hands shall be kept free of the muzzle end at all times.

Explosive actuated tools shall be held firmly and at right angles to the surface being driven into. Fastening devices shall be kept in from the edge the minimum distance recommended by the manufacturer for the material being anchored to.

Explosive actuated tools shall only be loaded when required for immediate use. Tools shall not be left unattended or loaded when stored.

In the event of a misfire:

• Hold the tool against the material for at least 30 seconds in case firing is delayed. • Remove the cartridge from the tool, keeping the tool away from the body, preferably pointed towards

material such as wood. • Place the cartridge in a container of water. • Do not dispose of in garbage.

Care shall be taken when fastening attachments to floors, walls, and ceiling. If the material does not offer enough resistance the fastener may pass through to the other side.

Operators of explosive actuated tools shall wear safety glasses, and haring protection.

TRAINING:

Employees will be trained about this safe work practice through safety meetings/talks.



USE OF HAND TOOLS PURPOSE: The purpose of this practice is to establish the general requirements for the safe use of hand tools.

POLICY:

Always use the proper tool for the job.

Tools such as knives, chisels or screwdrivers shall not be carried in pockets, as a fall onto these tools could cause a serious puncture wound.

Cutting tools shall always be kept sharp. Care must be taken to work cutting tools away from the body not towards it. Hands should be kept behind the tool not in front of them.

Knives shall have retractable blades whenever possible. Handles on hand tools shall be kept in good repair. Loose handles can create a hazard if the striking or cutting attachment comes free, a hazard could also be created from the damaged handle.

Ends of metal striking tool such as chisels that are mushroomed shall be dressed to prevent fragments from flying off when struck and causing injury.

Wrenches shall not be used with “snipes” or metal tubing over the end to increase leverage. Hammer wrenches, pneumatic impacts or a nut splitter should be used in unable to free stuck nuts.

TRAINING:

Employees will receive training on this policy through safety meetings/talks.



USE OF POWER TOOLS PURPOSE: The purpose of this practice is to establish the general requirements for the safe use of power tools.

GENERAL;

All electric power tools used shall be UL or CAS approved. Electric power tool cords must be two prongs with a ground pin unless they are double insulated.

When using power tools read and follow manufacturers’ specifications.

Cutting or abrasive attachments such as blades, disks or bits shall be the proper size and rating for the power tool being affixed.

Never force or put pressure on power tools, let the tool do the work. Applying too much pressure may cause the blade, disk or bit to fail.

Always disconnect an electric tool from its power source when making adjustments or changing attachments.

Guards shall be maintained on all equipment as equipped by the manufacturer. Guards and other safety devices shall not be modified, tampered with, or removed.

Power Tools shall not be hoisted or handled by the cord. Power cords shall be removed from receptacles by holding the plug, not pulling on the cord.

When operating power tools always wear eye protection appropriate for the job. Use of power tools that may produce flying particles to the upper part of the body such as grinding and cutting, require eye and face protection.

Power tools must be held firmly, and material being worked on must be properly secured before starting work. Always use handles provided to help control the tool and avoid twisting.

Never wear loose clothing or dangling jewelry when using power tools.

Pipe or conduit threading machines and drill presses must be equipped with a foot pedal for on/off controls. In the event clothes or other material get caught in the equipment, toggle switches may not be reachable.

TRAINING;

Employees will be trained on this policy through safety meetings/talks.



USE OF PNEUMATIC TOOLS AND COMPRESSED AIR PURPOSE: The purpose of this practice is to establish the general requirements for the use of pneumatic tools and compressed air.

POLICY:

Pneumatic tools shall be operated and maintained in accordance with manufacturers specifications.

Hose couplings shall be secured with wire or pins to prevent them from coming undone and whipping around.

Hose whips shall be used to control air hoses in the event of a blow off from fittings.

Formwork and concrete slabs shall only be blown free of debris when personnel are not present in the work area. Mono goggles, face shields, and dust respirators must be worn.

Hose couplings for use with pneumatic tools shall not be compatible with those used for breathing air.

Keep hands away from the bit, cutting or discharge ends of pneumatic tools.

Compressed air shall not be used to blow off clothing.

Before using pneumatic tools check the hose, connections, and tools.

Before changing tools, the pressure shall be turned off and the hose pressure removed through use of the tool. Hoses shall not be kinked to stop air flow. Always turn off the air pressure when not in use.

Air tools often are associated with a high degree of vibration and should be equipped with anti- vibration grips.

Air compressors shall be run in well ventilated areas.

Safety glasses shall be used with pneumatic tools such as jackhammers, chippers and other tools that produce flying particles. Face shields must also be worn if flying particles are likely to contact the upper body.

Always wear hearing protection that is appropriate for the noise level of the task.

TRAINING:

Employees will be trained about this policy through safety meetings/talks.



USE OF MOBILE EQUIPMENT

PURPOSE: The purpose of this practice is to establish the general requirements for the use of mobile equipment by Sullivan employees.

POLICY All equipment shall be maintained and operated in accordance with manufacturers’ specifications.

Equipment shall be inspected daily, before use and shall not be operated if defects pose a hazard to safe operation.

Equipment shall be operated by qualified and or competent personnel or personnel under their direct supervisor.

All operators of personnel hoist such as telescopic or knuckle boom work platforms or scissor lifts shall have training in their operation. Load limits for temporary work platforms shall not be exceeded.

Mobile equipment shall be equipped with rollover protective structures as designed and required in accordance with statutory regulations.

Care must be taken around pinch points and swing areas of large equipment. Personnel shall not walk under suspended loads, or equipment components. Make eye contact with operator before getting near operating equipment. Buckets, blades, forks or material shall not be left suspended while the equipment is unattended. Equipment with poor visibility or oversized loads shall be moved or “spotted” with the assistance of a signal person. Signal persons shall be identified with high visibility clothing, or a fluorescent vest/sash belt that covers his or her upper body. A walk-around shall be done prior to moving. Personnel shall not ride on or in equipment, unless in a seat designed for the purpose and equipped with a seat belt. Personnel working in areas where vehicles and equipment are operating shall wear high visibility clothing or high visibility vest/sash belt that covers the upper part of his or her body. Safety devices on equipment shall not be tampered with. Personnel shall stay away from cables or chains, etc. being used to pull other equipment. Personnel shall not work on equipment or equipment components suspended by hydraulic pressure. Work shall only be done on equipment or components that are solidly blocked with lock out in effect.

Such action, as may be necessary, shall be taken to prevent unattended mobile equipment from being started and set in motion. Unattended mobile equipment shall have its brakes applied and wheels blocked when parked on sloping ground or adjacent to an excavation.

TRAINING:

Employees will be trained about this policy through safety meetings/talks.



USE OF COMPANY VEHICLES PURPOSE: The purpose of this practice is to establish the general requirements for the use of company vehicles.

POLICY:

All personnel operating company vehicles shall be in possession of a valid driver’s license appropriate for the size and weight of the vehicle they are driving.

All vehicles one tonne and over shall have back up alarm in good working order. Operators of vehicles not requiring back up alarms, if their view is unobstructed, shall sound the horn before reversing.

Vehicles with obstructed views due to loads, body configuration etc., or that are backing into areas where personnel are working, where excavations exist, or materials are stored such as gas cylinders, etc., shall be directed by a signal person.

Vehicles must be turned off when refueling. Smoking or hot work is prohibited in the vicinity of refueling.

Personnel operating a vehicle for the first time shall familiarize themselves with the operation of the motor vehicle prior to use.

Vehicles shall be inspected at the start of each shift for the following:

• Gauges, temperature controls • Signal, brake and tail lights • Horn, back-up alarms • Emergency brake function • Condition of windows and mirrors • External inspection – tires, damage to body • Fluid check – oil, windshield wash fluid and engine coolant.

In the winter conditions, vehicles shall be given time to warm up and shall be clear of ice and condensation on driver cab windows before moving.

Personnel traveling in vehicles must be in a seat designed for the purpose equipped with a seat belt. Personnel shall wear seat belts at all times. It is prohibited to ride in the bed of trucks or cargo vans.

Such action as may be necessary, to prevent an unattended vehicle from being started or set in motion by an unauthorized person, shall be taken. An unattended vehicle shall have its brakes applied and wheels blocked to prevent movement when parked on sloping ground or adjacent to an excavation.

Tools and material shall be transported in a secure manner. Material extending 1.5m (5 ft) or more beyond the tailgate or end of the trailer shall be equipped with a flag or at night or in reduced visibility, or red light.



Any problems or damage to vehicles shall be reported immediately. Vehicles shall not be operated if a mechanical condition poses a potential hazard to safe operation.

Personnel signaling or escorting vehicles shall be identified by a high visibility fluorescent vest or harness.

Drivers must obey roadway regulatory signs as well as signs posted on private property including speed limits, stop, yield and parting, etc.

TRAINING:




INSTRUCTION FOR SIGNAL PERSON(S) policy

VEHICLE & EQUIPMENT OPERATION

- A signal person shall wear a hard hat, safety footwear, a shirt, and pants, as well as a garment vest, blaze orange in colour with yellow fluorescent striping front and back while acting as a signaler.

- A signal person shall not engage in any other activity while acting as a signaler.

- A signaler shall remain in view of the operator of the vehicle/equipment he/she is directing and have a clear view of the intended path of travel being taken.

- Keep clear of the intended path of travel.

- A signaler must be aware of the terrain on which he is walking so as to prevent tripping or falling.

- A signal person must be aware of the terrain over which he/she is directing the vehicle or equipment, so as to prevent sinking, side slope failures, excavations, holes or vehicle/equipment upset.

- The signaler shall use hand signals common to construction for Traffic Control as depicted on this form unless another form of signaling or communication direction to the vehicle/equipment operator is agreed to.

Reviewed with Signal Person ______________________________________________________

On _____________________at _______________________________________a.m./p.m.

Signed _________________________________________________________



USE OF CHAINSAWS PURPOSE: Sullivan has established general safe rules for the handling and use of chainsaws for employees.

POLICY:

Chainsaws are to be operated and maintained in accordance with the Manufacturers’ Specification’s. User’s shall be familiar with these guidelines and abide by them.

Only trained personnel shall be allowed to operate chainsaws.

Chainsaws shall be equipped with an “inertia” chain brake and anti – kickback cutting chains.

The Chain brake shall be tested to ensure it is functioning properly, prior to the saw being used for the first time in a day. If the chain brake does not function properly, DO NOT USE THE SAW.

A chainsaw should be started while resting on a level surface with the cutting bar pointing away from the operator and clear of any obstructions. A Chainsaw should not be “drop started” as this leaves only one hand to control the saw movement, which could allow the running saw blade chain to come in contact with the operator’s feet or legs, resulting in serious injury.

Hold the chainsaw firmly with two hands when cutting and keep the material being cut as close as possible to the back of the cutting bar. Never use the tip of the bar to perform a cut.

Cutting chains shall be kept sharp, well lubricated and maintained with the proper amount of tension.

The rpm of the chainsaw should not exceed the rpm rating for the cutting bar.

When carrying a chainsaw for a distance, or transporting it, the chainsaw should be shut off. The chain bar guard installed, and the chain brake engaged.

Chainsaws shall only be fuelled in well ventilated areas, with the engine stopped.

Chainsaws shall not be used to cut above the operator’s shoulder height. Scaffold or power elevated work platforms etc. Shall be used for access to chainsaw work in elevated areas.

TRAINING:

Training in the use and handling of chainsaws shall be provided by a competent person and should include a demonstration of proficiency by the trainee.

On satisfactory completion of the training and proficiency demonstration, the trainer shall provide the individual with a certificate of training.

Personal Protective Equipment for Chainsaw Operation:



Employees assigned to operate chainsaws shall be provided with and instructed in the use of the following personal protective equipment:

- A hard hat equipped with a wire mesh face shield, - CSA approved safety glasses,

- Hearing protection. Ear Muffs recommended. - Leggings or chaps made of ballistic material, - Footwear designed to protect the top of the feet and lower shins of the operator from being cut.

Leather gloves. It is recommended that the back of the gloves have ballistic material sewn into them, to prevent cuts to the back of the hand, in the event of saw kickback.

COMMUNICATION:

This policy will be communicated to the employees through safety meetings/talks.



POWERED ELEVATING WORK PLATFORMS PURPOSE: Sullivan has developed a policy promoting the safe operation of powered elevating work platforms in its’ workplaces.

POLICY:

A powered elevating work platform, a scissor lift and or a telescopic boom lift, shall only be operated by a person who has been given oral and written instruction on the operation of the elevating device.

The training and instruction shall include:

• a review of the manufacturers operating manual • instruction and hands on demonstration of operating controls and the location of emergency

controls, • how to establish the maximum load rating of the equipment, and • equipment inspection requirements and operators’ manual availability.

In the raised position, and elevating work platform shall only be used on surfaces as specified by the manufacturer.

In the raised position, and elevating platform shall not be driven close to holes in the surface, depressions, trenches etc.

Before elevating the work platform or when traveling in an elevated position, establish the safe limits of approach for energized electrical conductors.

A scissor lift or telescopic boom lift should not be elevated during very windy conditions.

Do not place makeshift platforms, such as boxes, planks, ladders or scaffolds on an elevating work platform in order to gain access to a work area above.

An elevating platform must not be used for pulling, pushing, dragging or hoisting materials.

An elevating platform must not be loaded in excess of its rated working load limit and where possible the load should be distributed over the length of the platform.

All individuals on an elevated platform, must wear a full body harness with a lanyard, and be tied off to a designated tie point when the platform is being moved.

TRAINING:




MACHINE/EQUIPMENT GUARDING PURPOSE: The purpose of this procedure is to establish a standard for guarding an apparatus.

DEFINITION:

“Apparatus” means equipment, a machine or device.

“Protective elements” means a shield or guard.

POLICY:

Every gear, pulley, belt, chain, shaft, flywheel, saw and other mechanically – operated part of a machine to which a worker has access shall be guarded or fenced so that is will not endanger a worker.

• If an apparatus has an exposed moving part that may endanger the safety of a work, it shall be equipped with a protective element.

• An in-running nip hazard that may endanger the safety of a worker shall be equipped with a device that prevents access to the pinch point.

• The protective element or device shall be maintained in good working condition.

If the protective element must be removed to allow for adjustment or servicing, the apparatus must be locked out of service and or the power source disconnected until the adjustment, servicing is complete, and the shield or guard are replaced.

TRAINING:

Employees will be trained on this policy through a safety meeting/talk.



WORKING ALONE PURPOSE: The management of Sullivan has developed a policy for the safety of individuals who may be required to work alone.

POLICY:

Planning is important in allowing for an employee to work alone. Common sense can help determine whether a job should be done by someone working alone or not. In some situations, “confined spaces” for instance regulations prohibit entry without another person being present.

Always use the “Buddy System” to avoid working alone.

Communication is crucial in accounting for personnel working alone. A means of communicating between the worker and another individual must be established and clearly understood before the work is commenced. It could be a personal check on the alone individual, or by having phones or radios readily accessible for communication between designated person(s) at regular intervals. If the worker fails to report at a designated interval the failure must be investigated immediately.

CHECKLIST:

Before delegating a person to work alone the employer or supervisor must ensure that:

- a method of checking in with the worker has been established, - check-in intervals are clearly understood, - the designated contact person is aware of the work schedule, - any communication equipment to be used is tested and in good working order.

TRAINING:




SAFE WORK

PROCEDURES



SAFE WORK PROCEDURES PURPOSE: “Safe Work” Procedures” are designed to reduce risk by minimizing potential exposure of worker’s, to hazards in the workplace.

Policy:

Safe Work Procedures are developed by the Company H&S Officer in conjunction with Site Supervisors and H&S Reps. Practices are reviewed by Sr. Management and Workers via JHSC Meetings prior to being implemented. Once a new Procedure is implemented it will be communicated to workers via in-house training sessions or Tool-Box talks.

PROCEDURE’S:

Sullivan has developed “Safe Work Procedures” to assist workers in the safe performance of the following tasks.

Risk Assessment Corporate Risk Threshold

Fall Protection 6 1 Confined Space Entry 6 0 Use of Suspended Access Equipment

6 1

Working in the vicinity of High Voltage Equipment

6 1

Rescue Plan for working on ice 6 1 Water Rescue Plan 6 1 Use of Ladders 5 2 Hoisting and Rigging 5 1 Use of Hand Held Wireless Communications

5 0

Excavation and Trenching 4 2 Tagging and Lockout 4 1 Using Land Sport Aluminum Ramps to load Equipment

4 1

Silica Dust 4 2 Traffic Control 4 2 Welding and Cutting Processes 3 1 Vehicle Recovery 2 1 Use of Fire Extinguishers 1 1



WORKING AT HEIGHTS PURPOSE: The purpose of this standard is to establish requirements for fall protection on Sullivan Work sites, where a worker could fall.

• A distance of more than 3 metres (ten feet). • A distance of 2.4 metres (eight feet) or more from a floor, the surface of a bridge • A roof while the formwork is in place, and a scaffold platform or other work • Platform, runway or ramp, • A distance of more than 1.2 metres (four feet) if the work area is used as path for wheel barrow

or similar equipment, • Into operating machinery or equipment, • Into or onto hazardous substances or objects, • Through an opening on a work surface.

The components of a fall arrest system shall meet the requirements of the Nation Standards of Canada standards that are applicable.

POLICY:

Workers required to use a fall arrest system shall be trained in its use and given adequate oral and written instruction by a competent person.

Safety harnesses and lanyards with locking snap hooks and shock absorbers, when warranted, are mandatory as personal fall protection components.

Lanyards, attached to a body harness, shall only be attached to secure anchor points, vertical or horizontal lifelines, with care being taken to avoid damage from heat, corrosives or sharp objects.

Only one person at a time can use a lanyard.

If a permanent anchor system cannot be used, a temporary fixed support shall be used that does not exceed the allowable unit stress for each material used in a fall arrest, fall restricting or travel restraint system.

A permanent anchor system shall be used as a fixed support in a fall arrest system, fall restricting system or travel restraint system, if the system has been installed according to the building code, or if it is practical to use as an anchor system.

Vertical life lines and components must be an engineered system used in accordance with the manufacturers’ specifications.



Only one person at a time can use a vertical lifeline.

Horizontal lines used for all arrest shall be designed, installed and used in accordance with the specifications of a professional engineer. The design drawings for the horizontal lifeline shall be kept at the worksite and shall stipulate the number of persons who can safely be attached to it at one time.

Fall arrest systems or equipment shall be used only for the purpose intended.

Any components of a fall arrest system found to be defective, or that has been subjected to a fall incident, shall be taken out of service immediately and not re-used until certified by the manufacturer thereof that it meets the applicable CSA standards.

Before any use of a fall arrest system by an employee, a written procedure for the rescue of the individual must be developed and reviewed with the employee.

INSPECTION

Fall arrest components shall be inspected by a competent person daily before use for:

• Damaged stitching, rivets, etc. The condition of buckles, d-rings and snap hooks. • Cuts, burns and tearing and • Damage to the shock absorber component.

Horizontal and vertical lifelines and components shall be inspected by a competent person for:

• Fibre rope or cable damage. • Condition of anchorage hardware, and • Function and wear of components such as rope or cable grabs.

COMMUNICATION:




CONFINED SPACE ENTRY PURPOSE: Sullivan has developed a policy and program to be followed by employees encountering work in “Confined spaces.”

DEFINITIONS:

“Confined Space” means a fully or partially enclosed space that is not primarily designed or intended for human occupancy and to which, because of it construction, location, restricted access and or egress, contents or work activity therein, the accumulation of hazardous gas, vapour, dust, fume or the creation of an oxygen – deficient atmosphere may occur.

“Adequate” in relation to a procedure, material, device, object or thing, means:

• Sufficient for both its intended and its actual use, and • Sufficient to protect a worker from injury or death.

“Purging” means displacing contaminants.

“Safe Atmosphere” means that:

The oxygen content of the atmosphere is at least 19.5 % but not more than 23% by volume and the atmospheric concentration of any explosive or flammable gas or vapour does not exceed 10% of the lower explosive limit or 10% of the lower flammable limit of the gas or vapour.

“Tending worker” means worker(s) who are outside the confined space, in close proximity to the point of entry, who are able to provide assistance to the worker(s) occupying the confined space and summon assistance in order to initiate a rescue of worker(s) if necessary.

POLICY:

The Company shall ensure the written “Confined Space Program” is developed, implemented and maintained in accordance with this policy.

Before a worker enters a “confined space”, the Supervisor or a Manager shall ensure that a qualified person conducts an assessment of the hazards to which worker(s) may be exposed to in the confined space.

The “assessment” shall be in writing and shall consider”

- The hazards that existst due to the design, location, or use of the confined space. - The hazards that may develop during the work activity in the confined space, such as



o – oxygen enrichment or deficiency, o – a flammable/combustible gas, vapour or mist, o – a combustible dust, o – a hazardous energy, o – engulfment and or entrapment.

The qualified person shall sign, enter the date and time of the assessment, on the assessment from and provide it to the Supervisor or Manager, who shall review the plan and ensure the hazards, if any, are eliminated or controlled.

The “Confined Space Entry Plan” shall include methods, procedures, and practices for controlling all hazards identified in the assessment.

The Plan shall address as many of the following as are applicable:

- atmospheric testing of the confined space, - the isolation, lockout, and tagging of hazards, - the control of sources of ignition, - ventilation and purging of the confined space, - explosive and flammable atmospheres, - lighting, - methods of communication with a worker in a confined space, - emergency response procedures and equipment, - the number of “tending workers” and the frequency of checks on the worker(s) in the confined

space. O. Reg. 632/05

CONFINED SPACES WITH MULTI-EMPLOYER INVOLVEMENT:

If the workers of more than one employer are going to perform work in the same confined space or related work with respect to the same confined space, the lead employer, or in the case of a project, the constructor, shall prepare a co-ordination document to ensure that the duties imposed on employers protect the health and safety of all workers.

TRAINING:

Every worker involved with an entry into a confined space shall be trained by a qualified organization, to recognize the hazards associated with the confined space, how to safely perform an entry and carry out the work therein.



ENTRY PERMIT SYSTEM:

For each confined space, the Company shall establish and “Entry Permit System” that specifies:

• the date and time the permit was issued, • the location of the confined space, • the identity of each worker entering the confined space and their training, • the identity of “tending workers”, including their training, • the results of the atmospheric testing of the confined space, • special precautions to protect the worker(s) in the confined space, as deemed necessary • emergency and recovery equipment that has been put in place and tested.

Before anyone enters the confined space, the competent worker who completed the “Confined Space Permit”, shall review the contents with a supervisor or Manger, after which if they agree that the content is adequate to authorize and entry, they shall sign it.

Entry is made, the time of which is recorded, and the work performed. All access and egress times of entry-level workers shall be recorded. On completion of the confined space work, the competent worker shall record the time of completion and confirm that all worker(s) are out of the confined space.

ON-SITE RESCUE:

Before a worker enters a confined space, the employer shall prepare, in accordance with the relevant plan, an adequate written on-site rescue procedure for the confined space and is ready to immediate implementation.

The employer shall ensure that an adequate number of people trained in on-site rescue procedures, trained in first aid and cardio-pulmonary resuscitation and in the use of the rescue equipment required, are available for the immediate implementation of the on-site rescue.

The employer shall ensure that the rescue equipment named in the plan is readily available and is adequate to perform a rescue from the described confined space.

Communication:

This policy will be reviewed with employees during safety meetings/talks.



SAFE WORK and RESCUE PLAN, Swing Stage work, N/E end of power plant,

Otto – Holden Generating Station,

Mattawa, Ontario. 10 August 2012.

The Swing Stage” has been assembled by supplier “Skyway Canada”, on the roof of the Power House.

Workers delegated to work from the swing stage will be given instruction on how to operate the electric devices to raise and lower the stage from the roof level, prior to getting on to it.

Workers will also be instructed as follows:

- The proper donning and wearing of a full body harness while on the stage, - The requirement for attaching their body harness to a securely anchored life line at least two

metres in from the roof edge, prior to approaching and getting into the swing stage, - The requirement to maintain 100% tie off while on the swing stage and to keep their rope grab

and lanyard properly adjusted on the lifeline while raising or lowering the stage, so as to minimize their fall distance.

- In the event of a power failure, personal injury or other emergency, the swing stage can manually be lowered to an opening at the bottom centre of the window where workers remaining secured to their life lines could exit from the swing stage, by climbing or being assisted through the opening and onto the plant floor.

NOTE:

The work being carried out from the swing stage, removing and reinstating caulking around the window panes, is being conducted above water and thus the stage must be accessed and egressed from the roof level under normal conditions.

The swing stage must be inspected daily prior to being used, by a competent person (a person who has been trained on swing stage use) and a report of his inspection has been completed.

The swing stage as setting up, must not be altered in any way without the consent of the supplier.

PLAN “B”

If the stage fails, or workers fall out of it and are suspended on their lifeline, three workers from the work area, equipped with body harnesses, lifelines, and rope grabs, must react to pull the individual up onto the roof or lower him or her to the window opening for assisted rescue.

Air horn canisters must be available on the stage and with an observer to signal if an emergency exists by emitting a five-second horn blast.

Workers must respond and act under the direction of the project supervisor to take care of the situation.



RESCUE PLAN – SWING STAGE FAILURE

Workers operating a swing stage shall be trained in its operation.

Swing stage set up shall be completed by the supplier, Access Mast Climbers and shall be inspected by an engineer or his written designate before first use and after each setup.

Workers using a swing stage shall be secured to a dedicated lifeline at all times and shall keep their fall arrest equipment adjusted so as to minimize their fall distance. It is recommended that only a five-foot lanyard with a shock absorber be used as part of personal fall arrest equipment and that the anchor point (rope grab) on the life line be kept adjusted at head height or above.

In the event of a stage failure and a person is left suspended, conscious, by his lifeline, he may be able to perform a self-rescue by coiling his foot in the life line to relieve harness pressure and lower the rope grab in small increments allowing him to come down to the scaffold level.

If scaffolds are positioned end to end a pike pole may be utilized to pull the life line of a suspended worker into an adjacent stage allowing suspension relief and using the stage to lower him to the scaffold deck.

If a single scaffold is being used, two life lines will be lowered to an adjacent stage, with rope grabs attached and harnesses positioned nearby for use to access the area of the suspended worker(s) should the scaffold fail.

If, as the result of a scaffold failure, workers are injured or lose consciousness, 9-1-1 must be called immediately and a request made to summons the high angle rescue team from the Cornwall Fire Department to the scene at 2500 Second Street West.

The control room at the R.H. Saunders Gen. St. Shall also be notified at 613-932-3072, ext. 3300, so that first responder will have unobstructed access to the site.

Per Sullivan, emergency policy, site supervision shall immediately be notified of any Emergency situation and shall take charge of the scene in an effort to preserve life and property.

REMEMBER A PERSON SHOULD NOT REMAIN SUSPENDED IN A HARNESS FOR AN EXTENDED PERIOD OF TIME. (More than 20 minutes).



WORKING IN THE VICINITY OF HIGH VOLTAGE EQUIPMENT PURPOSE: To develop procedures for Sullivan employees to work safely around energized high voltage equipment.

POLICY:

Sullivan employees shall not under any circumstance be allowed to carry out work on any energized high voltage electrical component. Only qualified electrical workers may perform work on high voltage electrical equipment.

Supervisors and workers who may be assigned to work in the vicinity of energized high voltage equipment must receive safety awareness training in maintaining safe clearance distances, lock out / tag out procedures and the requirements for the use and wearing of Arc Flash Protection equipment and clothing.

A hazard assessment must be completed before entering areas containing high voltage electricity. The hazard assessment shall identify and evaluate the hazards associated with the work to be performed and stipulate the safe work practices to be followed to prevent electrical shock and or injury from direct or indirect contact with high voltage electricity.

Employees and their tools and or equipment shall not be allowed beyond the safe limit of approach to high voltage equipment unless the owner or the authority over the equipment has provided a statement in writing that the equipment has been de-energized.

Sullivan employees are prohibited from working closer than the safe limits of approach dictate, to high voltage equipment and or conductors that have not been de-energized, protected and or locked and tagged out of service.

Where tools or equipment could encroach on the minimum safe limits of approach the constructor shall prepare and implement safe work procedures for the completion of the work.

Signage warning of “High Voltage Danger” shall be prominently displayed in the vicinity of energized high voltage equipment and conductors.

SAFE LIMITS OF APPROACH:

• Normal phase-to-phase voltage rating: Minimum distance: • 750 or more volts, but less than 150,000 volts: 3 metres • More than 150,000 volts, but no more than 250,000 volts: 4.5 metres • More than 250,000 volts: 6 metres

COMMUNICATION:




SAFE WORK PROCEDURE

Work in proximity of energized overhead power line carrying __________volts of Electricity.

Pursuant to Ontario Regulation 627/05 the following work procedure shall be adhered to while working at this project.

Signs shall be posted sufficient to warn workers of all overhead wire hazards in the work area.

Where possible, it is recommended that these signs be positioned _______metres into the work area from the nearest energized conductor. Thus, the signage will act as a marker as well as a warning, to ensure that no part of a vehicle, equipment, or its load encroaches on the minimum distance of ________metres as stipulated.

A legible sign, visible to the operator shall be positioned at the operator’s station, warning of the electrical hazards if any part of the crane, similar hoisting device, backhoe, power shovel or other vehicle or equipment is operated near an energized overhead electrical conductor and it is possible for a part of the vehicle or equipment or its load to encroach on the minimum distance of _______ as permitted.

Whenever any part of a vehicle or equipment or its load may approach the ________metre minimum distance, a competent person designated as a signal person shall be stationed in full view of the electrical conductor and of the vehicle or equipment and shall warn the driver/operator of the approach limitation.

Employers, drivers, and operators shall be provided with a copy of this procedure before starting work and shall abide by the Terms.

Wes Fenton

Safety Co-Coordinator

Sullivan



Rescue Plan for Working on Ice Policy The written procedure has been developed as a form of Rescue Plan White the workers are performing a task on the ice at Chats Falls.

1. A physical barrier will be installed at the pedestrian bridge prior to work starting. This will be in place to allow NO WORKERS access beyond this point.

2. All workers on the ice will be 100% tied-off. This will be used as a restraint system to help avoid any potential contact with open water.

3. There will always be a minimum of 2 works available for rescue. 4. Throw rings will be available for rescue personnel. 5. Rescue workers will be stationed either on the access stairs along the building or on the pedestrian

bridge. 6. Workers performing work do have swift water rescue training.

Prepared by: Wes Fenton

M. Sullivan and Son Limited



WATER RESCUE PLAN Recover a person overboard

Know and practice the following procedures with your crew before you need to use these skills.

1. If someone does fall overboard, stop the boat immediately and then; throw something buoyant to assist the person (this will also mark the spot if the person submerges).

2. Try to keep the overboard person in sight or assign one person and have him or her continuously point to the victim’s location.

3. Carefully maneuver to recover the overboard person. 4. Establish contact with the person in the water using a buoyant heaving line or lifebuoy secured to the

boat. 5. Consider how to get someone into the boat if they could not assist in their own recovery. Can you lift

them in if you are alone? 6. Contact Controlling Authority and Supervisor. Inform both that a worker has fallen overboard and

requested medical help if needed. 7. Supervisor will assemble personnel on shore for assistance and if an ambulance has been requested

follow ERP procedures.

Rescue of capsized boat

1. If your boat capsizes, try to hold up on to your boat as it is visible and has flotation. 2. Stay on the upstream (upwind) side of a capsized boat. This will prevent the boat from crushing you

against an obstacle (or banging into you). 3. Distribute your weight in such a way that is keeps the capsized boat steady. 4. Rescue crew to communicate to applicable authority that a work boat has capsized, and crew members

are in the water. 5. If applicable, Controlling Authority shall take necessary action to minimize risk to persons in the water,

i.e. adjust generator or spillway output to reduce water currents. 6. Rescue crew to notify applicable work crew supervisor of the incident and request additional assistance

is required. 7. Rescue boat will circle capsized boat and retrieve workers from water using a predetermined and

documented rescue plan. 8. Supervisor will assemble available personnel on shore, coordinate rescue efforts, and implement ERP

procedures if medical assistance is required.

Wes Fenton

Safety Co-Ordinator

Reviewed with: _______________________________________________________________________

________________________________________________________________________

________________________________________________________________________

By: ____________________________________ Date: ______________________________________



USE OF LADDERS PURPOSE:

The purpose of this practice is to establish the general requirements for the safe use of ladders

POLICY:

Working from a ladder should be discouraged and only allowed if no other means is available to access the elevated work.

Ladders shall be inspected prior to each use. Damaged ladders shall be taken out of service.

Fiberglass ladders, which are not good conductors, shall be used when there is requirement for work in close proximity to electrical equipment. Wooden ladders are not recommended as they are usually reinforced with wire on the rails and can be conductive when wet. Aluminum ladders shall not be used in close proximity to electrical equipment.

All ladders shall be tied off at or near the top or held by another worker if the tie-off cannot be completed.

Workers, working off ladders 3m (10ft) or more above the base, shall wear a full body harness secured to an adequate anchor system. When working off of the ladder the body shall not be extended in a manner that allows the worker’s belt buckle to pass beyond the side rails.

Ladders shall be placed on a solid base. Ladders shall extend a minimum of 1 m (3 ft) above the top of a platform or landing.

Ladders being used for regular access to elevated work areas shall be secured at both the top and bottom.

Always maintain 3-point contact and face the ladder when climbing up or down. Do not carry large tools, equipment or materials in your hands when climbing. Use a rope or other suitable device for hoisting or lowering tools and or materials.

It is recommended that CSA Grade 1 ladders be used on construction projects.

A worker shall not stand on the top two rungs of any ladder. On a step ladder the cap is not considered a rung.

Ladders shall not be placed near doorways, within the door’s swing radius, unless the door is made temporarily inoperative and signs are posted.

Materials shall not be placed in close proximity of the base of the ladder.

Keep boots clean of mud, grease or other slippery materials which could cause loss of footing.



EXTENSION LADDERS:

Extension ladders shall be placed at an angle ratio of 1:4, base to height.

Extension ladders shall have a minimum overlap of 1m (3ft) on the sections at all times.

Do not place ladders against flexible or moveable surfaces.

When erecting long, awkward heavy ladders get help to avoid over exertion. One worker should secure the base of the ladder while the others walk it into position.

STEP LADDERS:

Step ladders should only be set up on a clean, level and solid base.

Step ladders should only be used in the fully open position with the spreader bars locked.

TRAINING:




HOISTING & RIGGING PURPOSE: To develop safe work procedures for hoisting activities carried out by Sullivan employees.

POLICY

Hoisting operations will be conducted by competent qualified personnel.

Hoisting equipment will be maintained and utilized in accordance with the manufacturer’s instructions. Load charts will be maintained in good, legible condition, visible from the operator’s platform. Equipment and rigging materials shall be inspected each day before use.

Hoisting equipment will be inspected annually for cracks, alignment, loose or worn components. A certificate of inspection shall be obtained and carried with the equipment.

When rigging loads, avoid sharp bends, pinching and kinks in rigging components.

Never wrap a wire rope sling completely around a hook. The tight radius will damage the sling.

Make sure the load is balanced on the hook. Over loading can reduce capacity dangerously.

Attach the load to the hook by slings or other rigging devices adequate for the load.

Avoid bending the eye section of wire rope slings around corners as the bend will weaken the splice or swaging. Avoid bending wire rope slings near any attached fitting.

Understand the effect of sling angle on the sling load and the pull angle on the beam load.

Rig a load with its centre of gravity directly below the hoisting hook to ensure stability. The crane hook should be brought over the loads centre of gravity before the lift is started. The crane hook and rigging components should be vertical before the lift is started.

When using nylon slings around loads with sharp edges, install softeners at the corners to prevent damage, such as cutting or rearing, of the sling fabric.

All slings must have a legible load rating specification attached to them and shall not be subjected to an overload situation.

Hooks used in hoisting operations shall have their load rating legibly marked on them and be equipped with safety latches in good condition. Use tag lines to control hoisted loads in turbulent and or tight conditions, with signal persons.

COMMUNICATIONS:

This policy will be communicated to employees at safety meetings/talks.



DISTRACTED DRIVING USE OF HAND HELD WIRELESS COMMUNICATION DEVICES PURPOSE: The purpose of this procedure is to develop a standard restricting the use of hand-held communication devices or hand-held electric entertainment devices while driving a motor vehicle on a highway.

A “roadway” means the part of a highway that is improved, designed or ordinarily used for vehicular traffic, but does not include the shoulder.

POLICY:

Unless vehicles are pulled off the roadway and legally parked, drivers are prohibited from:

• Using hand-held wireless communication devices such as cell phones and smart phones • Using any hand-held electronic entertainment devices such as IPods, MP3 players and other portable

games • Viewing display screens of devices not required for driving, such as a computer screen or a DVD player

EXCEPTIONS:

Nothing prevents a person who is not a “novice driver” to use a cell phone or a vehicle mounted phone to report an emergency, a traffic accident, an unlawful act or unsafe road conditions to the appropriate authorities or use communication equipment with a hands-free feature to operate the equipment and does not use a listening device that covers or provides sound to both ears.

A “Novice Driver” is a new or probationary driver.

PENALTY:

As a Highway Traffic Act offence, a fine of up to one thousand dollars and three license demerit points may be incurred.

COMMUNICATION:

This policy will be communicated to employees by copy and or through safety meetings/talks.



EXCAVATION AND TRENCHING PURPOSE: Sullivan has established procedures to safely carry out excavation, trenching and auguring operations.

DEFINITIONS:

A “competent person” is a person who is qualified because of knowledge, training, and experience to organize the work and its performance.

An “excavation” is an area dug out of earth, rock, sand or gravel below surface grade other than a trench, tunnel, underground shaft or open pit mine.

A “spoil pile” means a pile of material excavated from an excavation, trench, tunnel or underground shaft.

A “temporary protective structure” means a structure or device designed to provide protection from cave-ins, collapse, and sliding / shifting material in an excavation, trench tunnel or underground shaft and includes shoring and bracing equipment, piles, planking and trench boxes.

A “trench” means an elongated area dug out of the earth, rock, and or sand or gravel whose depth exceeds its width at the bottom thereof.

POLICY

Before any excavation, trenching or auger work begins, the area must be examined for underground services including but not limited to gas lines, telephone lines, hydro cables, etc. Call “ON 1 Call” 1-800-400-2255 for locates of services. Sewer and water pipe locates should be completed by the owner.

The buried utility, if present, shall be identified and its location marked and or flagged.

A current survey report shall be reviewed by the excavating contractor prior to the start of any excavation / auger work.

Prior to breaking ground, the supervisor/ lead hand shall, in conjunction with employees involved in the excavation / auger work, prepare a “Pre – Job Safety Meeting” form. The completed “form” shall describe the nature of the work, define the known hazards identified with the work and the precautions to be implemented to safeguard underground utilities and the workers involved. The completed form shall double as the “safe work excavation permit.”

Equipment operators must be “competent” and be provide with a copy of the “survey report” before starting any excavation or auger work.



No excavating or auger equipment shall be operated within one metre of an underground service until the service has been exposed by a “competent person” by hand digging.

If an underground service may pose a hazard as the result of an excavation, the owner of the service shall be contacted and requested to shut it off or disconnect it. If the service cannot be shut off, the owner of the service shall be requested to supervise the excavation work adjacent to the service.

Underground services that are undermined as the result of excavation work shall be adequately supported to prevent their failure or breakage.

If an excavation may affect the stability of an adjacent building or structure, the constructor shall take precautions as written by a professional engineer, to protect the building or structure.

A level area extending at least one metre from the upper edge of each wall of the excavation shall be kept clear of equipment, excavated soil, and rock and construction material.

Unless the walls of the excavation are of solid rock, never enter a trench that is more than 1.2 metres deep unless it is properly sloped, shored or protected by a trench box or other engineered support system. Every prefabricated, hydraulic or engineered support system shall be constructed, installed, used and maintained in accordance with its design drawings and specifications. The design drawings and specifications for a prefabricated, hydraulic or engineered support system, shall be kept at the work site while the system is there.

Every prefabricated, hydraulic or engineered support system shall be designed by a professional engineer. The design drawing and specifications for a prefabricated, hydraulic or an engineered support system shall be kept on the project, by the constructor, while the system is there.

No one shall work in a trench unless someone is working above ground in close proximity thereto. A ladder extending one metre above the ground level shall be positioned in the trench close to where the worker(s) are situated. If a support system is used for the walls of the excavation, a ladder to access or to egress from the excavation shall be placed within the area protected by the support system.

An excavation into which a worker may be required to enter shall be kept reasonably free of water.

Before an excavation or trench is backfilled, the owner or representative of any utility therein should be contacted and requested to examine the service.

This policy will be reviewed on a regular basis and revised as necessary to meet regulatory and or company policy changes.



SOIL TYPES Type 1 soils include “hardpan,” consolidated clay and some glacial tills.

Type 2 soils are silty clay and less dense tills.

Type 3 soils are commonly backfilled materials, previously disturbed materials and salty wet clays.

Type 4 soils are silty clays with a high moisture content, leda clays and sandy soils.

TRENCH SLOPING

For type 1 and 2 soils, cut trench walls back at an angle of one metre back for each metre up. Walls should be sloped to within 1.2 metres of the trench bottom.

For type 3 soil, cut the trench walls back at a gradient of one to one from the trench bottom.

Type 4 soil cut the trench walls back at a gradient of three metres back for one metre up. If the area where the trench or excavation work is being carried out does not allow for proper sloping, a written opinion as to the stability of the walls of the trench or excavation, should be obtained from a professional engineer.

If the walls of a trench or excavation are not properly sloped and the depth is more than 2.4 metres, the open area must be fenced. Excavations and or trenches that pose a hazard shall be marked by high visibility barriers.

NOTIFICATIONS

Any contact with a damage to a service shall be reported to Sullivan management immediately. Management will be responsible for notifying the appropriate owner / authority.

The following incidents must be reported to the Ministry of Labour, in writing, within two days of their occurrence:

- Accidental contact by a worker or by a worker’s tool or equipment with energized electrical equipment, installations or conductors, and or,

- Accidental contact by a crane, similar hoisting device, backhoe, power shovel or other vehicle or equipment or its load with an energized electrical conductor rated at more than 750 volts.

Contact with a natural gas line must be reported to the owner representative and the Technical Standards and Safety Authority.

Contact with other services, communication lines, sewer and water services etc., must be reported to the owner representative.

COMMUNICATION AND TRAINING

This policy will be reviewed with employees through safety meetings / talks.



LOCK OUT / TAG OUT / ZERO ENERGY PROCEDURES PURPOSE Sullivan has developed procedure for ensuring that electrical, pneumatic and or hydraulic energy is transformed to a zero-energy state, before working on a conductor or piece of equipment.

POLICY

In order to ensure that the maintenance and operation of electrical equipment is conducted safely, many of the clients and industries we serve will have formal lockout procedures. It will be our policy to understand the lockout procedure of these clients and follow any instruction they provide regarding their procedures.

If a machine or piece of equipment is to be serviced, adjusted, or repaired, any motion or unexpected energization that could have the potential to injure must be stopped. Power sources must be brought to a “zero energy state,” “locked and tagged out of service.” Some energy sources may also require “blocking” and or “grounding”

Energy sources may include, but are not limited to: electrical, compressed air, gravity, mechanical, hydraulic and chemical, etc.

ZERO ENERGY STATE:

Equipment and machinery requiring change over, maintenance or servicing must be isolated from potential energy sources before work is started.

LOCKOUT:

A worker who is going to be working on a piece of equipment or machinery must have a lock or approved method utilized so as to prevent the component from becoming energized. When more than one person is working on the same piece of equipment requiring lockout, a multiple lock adapter must be used that will accommodate a lock from each individual and their lockout tag. The “lockout log” must be maintained while work is ongoing.

A worker affixing a lock as part of a lockout exercise should affix a lock with only one key which should be kept with him/her while the lock is in place.

TAG:

Each individual placing a lock should also affix a “Lockout” tag to his lock with his/her name printed on the tag as well as the date and time of placement.

TRY:



All sources of kinetic or stored energy should be reduced to the lowest level possible before work is started. In cases where it is impossible to remove all of the stored energy, adequate provisions for blocking movement must be provided.

After lockout is completed and before personnel begin work, the equipment start switches should be engaged to ensure the equipment is inoperative.

Ensure all personnel are clear of any danger before checking the start mechanism.

RE-STARTING:

When an individual has completed work on the equipment, he/she shall remove his/her lock and tag from the lockout mechanism and sign off in the “lockout logbook.”

If a worker has failed to remove their lock from a lockout mechanism and has left the work area, the supervisor/lead hand shall attempt to contact the individual to ascertain why the lock was not removed. If unable to contact the person and it is necessary to re-energize the equipment, the supervisor/lead hand may cut the lock off the lockout mechanism to allow for start-up.

On completion of lockout work and before applying energy to the equipment, a final review should be made to ensure parts, tools and other loose items have been removed, that guards have been properly replaced and that all personnel are clear of danger.

An investigation must be carried out to determine the reason the lock was left in place after the worker who affixed it finished work and an explanation noted in the “lockout log booklet.”

COMMUNICATION:

This policy will be communicated through safety meetings/talks.


Client: Contract Number: Project:

LOCK-OUT LOG

Lock No. Location Lock Installed for (Crafts)

Craft Foremen Supervisor

Client Operations Signature

Date ON

Date Off Sign Off Comments



Safe Work procedure for using Land Sport aluminum ramps to load equipment

Ramp Description: When the aluminum ramps are assembled they will be 20 inches wide and 16 feet in length. Each ramp has the loading capacity of 25,000 lbs.

Stabilizer pads: There will be 3 pieces of ¾ inch plywood laminated together with a piece of 1/8 inch stainless steel. Total size of the pads will be 2’X2”.

1. Accurate weights for equipment must be determined prior to any loading procedures to start. The ramp system is designed for 25,000lb maximum axle capacity and 25,000lb total capacity for equipment with wheel basis less than 100 inches.

2. Ensure barge is stabilized laterally (spuds down and seated, tie-off to shore if required). If barge moves during loading the hook pins holding the ramps may fall resulting in collapse of one or both ramp sections.

3. When loading track equipment cover ramps with rock crusher belts. Ensure belt extends up and over the top of the ramp by at least 12 inches. Failure to do so will result in damage to the cleats on the ramp and may cause failure to the hook pins securing the ramps to the barge.

4. 100 percent supervision is required for loading and offloading of equipment. Do not attempt to turn track equipment on the ramp. If the tracks are not aligned with the ramps back up and re-align equipment.

5. Stabilize the barge against vertical movement when loading and unloading. When loading the barge, beach or block under the barge to prevent the barge from sinking during loading. Prior to off-loading the barge, shift the weight on the barge to the side of the barge opposite of the ramps, block under the ramp side of the barge to prevent the barge from floating up during off-loading. The centre ramp supports will be pulled towards the barge by 1 inch for every 14 inches when the barge floats up or pull away when it sinks down. As a secondary mitigating measure stainless steel plates should be placed directly under the aluminum centre ramp supports and on top of either wood or concrete blocking. Failure to do so may result in ramp failures.

6. The aluminum ramps need to be set up so there is a constant slope from bottom to top. This slope should not exceed 40 inches.

7. When loading or off-loading equipment all personal must be sure to stand clear from operation. There should only be one signalman providing direction.

Prepared by: Wes Fenton (CHSO)

July 10, 2013



SILICA – SAFE WORK PROCEDURES PURPOSE: Sullivan, in the interest of the health and safety of its employees and the public, has developed a policy outlining safe work procedures for the control silica dust in it work places.

Silica dust and particles are generated from;

- Cutting, chipping, grinding and drilling concrete rock, - Sandblasting concrete, - Cutting, chipping, grinding and drilling masonry products, - Crushing, hauling and dumping stone aggregate, - Milling asphalt containing stone, and - Charging mixers and hoppers with sand, having a 95 per cent or more, and silica content.

The prolonged inhalation of respirable dust containing crystalline silica may result in silicosis, a disease characterized by progressive “fibrosis” (excess fibrous tissue or scar tissue) of the lungs.

Workers must not be exposed to more than 0.05 milligrams per cubic metre of air by volume of respirable crystalline silica dust, during an eight-hour day or forty-hour weekly time-weighted average limit.

The average concentrations silica dust to which a worker is exposed shall be determined from the analysis of air samples taken in the immediate area of the dust source during work operations.

Controls:

Three basic ways to control silica dust, include:

- Prevent silica dust from getting in the air, - Remove silica dust from the air, and - Prevent workers from inhaling silica dust.

POLICY:

During the cutting, grinding or drilling operation, if safe to do so, wet the area that is being worked on continuously with water to suppress the dust.

If water cannot be used to suppress the dust, if possible, select equipment with a vacuum attachment that will collect the dust.



An N 95 filtering face piece respirator is only appropriate for short – duration tasks when local exhaust ventilation is available, or a “HEPA VACUUM” system is available on the tools.

A full-face piece air-purifying respirator equipped with a 100 series particulate filter, properly fitted, shall be worn by all workers exposed to a dust suspect of containing silica particles in a concentration greater than 0.05 milligrams in a cubic metre of air.

A properly fitted hood with a fresh breathing air supply may also be used, to protect workers, during sandblasting operations.

The manufacturer’s instruction in the general use, care and maintenance of respirators must be followed whenever they are required.

Whenever possible operate vehicles and equipment with pressurised cabs in dusty conditions, keeping windows and doors closed and air intake filters clean.

In outdoor environments, set up the work area so that the wind blows from behind you and carries the dust cloud away from your breathing area. Notify other workers that the work will generate silica dust and suggest that they keep at least 10 metres away or use respiratory protection while the work is being carried out. Post signage warning of the hazard.

Set up an enclosure around the cutting, grinding and blasting operations if unable to prevent the spread of dust to other workers or the public who are not protected.

After finishing the cutting, grinding, drilling or blasting operation, remove the dust from the tools, equipment and clothing with a damp cloth or vacuum equipped with a HEPA filter.

Clean the work area to prevent the buildup of silica by wet sweeping or the use of a HEPA vacuum. Never use compressed air to blow the dust away or clean the dust from your clothing.

Wash your hands and face with soap and water before smoking, eating, drinking or chewing in an uncontaminated area.

TRAINING:

Workers will receive training on the hazards of silica exposure, chronic, accelerated and acute. The methods to be implemented to minimize or eliminate the risk, through a safety meeting or talk presentation.

MEDICAL SURVEILLANCE PROGRAM :

Sullivan employees exposed to air born silica dust on a regular basis will be requested to participate in a medical surveillance program.



The objective of the program is to protect the health of employees by:

- Ensuring their absorption of silica is within legislated guidelines, - Enabling remedial action to be taken when necessary, and - Providing health education

The medical surveillance program will include pre-employment and pre-placement medical examinations, periodic medical examinations and clinical test, health education and record keeping.



TRAFFIC CONTROL PURPOSE: To establish procedures for Sullivan employees to understand and comply with the standards set out in the Ontario Traffic Manual (Book 7) while working on roadways in Ontario.

DEFINITIONS:

- “Barricade” means a device that provides a visual indicator of the path a motorist is supposed to take. - “Barrier” means a device that provides a physical limitation through which a vehicle would not normally

pass and includes a concrete barrier. - “Mobile Operation” means work, including a paving operation that is done on a highway or the shoulder

of a highway and moves along to speeds of less than 30 kilometres an hour.

POLICY:

If a worker at a project on a highway may be endangered by vehicular traffic not related to the project, the work site shall make use of as many of the protective measures as is necessary to adequately protect the worker(s):

• Barriers, • Barricades, • Delineators, • Lane control devices, • Warning signs, • Flashing lights, • Flares, • Traffic control devices, • Blocker trucks, • Crash trucks, • Sign trucks, • Speed control devices, and • Longitudinal buffer areas.

In addition to the measures listed above, a competent worker may be used to direct traffic where there is only one lane in each direction and the speed limit is 90 kilometres or less.

A traffic control person shall not do other work, while directing traffic, shall be positioned in such a way that he/she is endangered as little as possible by vehicular traffic and shall be given oral and written instruction with respect to directing traffic that includes a description of the signs and signals to be used in directing the traffic.



If a worker may be endangered by vehicular traffic he/she shall wear reflective clothing. If the reflective clothing consists of a vest, it shall have an adjustable fit and have side and front tear-away features.

TRAFFIC PROTECTION PLAN:

Sullivan, as an employer, shall develop and implement a traffic protection plan for its workers at a project if any of them may be exposed to a hazard from vehicular traffic.

The Ontario Traffic Manual (Book 7 as amended) shall be referenced in developing the traffic control plan.

COMMUNICATION:




INSTRUCTION FOR TRAFFIC CONTROL PERSONS

A hard hat, safety footwear, shirt and pants with a garment that covers at least the upper part of his or her body, being fluorescent blaze or international orange in colour with retro-reflective stripes front and back.

A stop/slow hand-held sign must be used in conjunction with hand signals to direct traffic.

Stand at the right side of the traffic lane that you will be directing traffic on facing across the roadway, so that you can see traffic approaching from either direction, as well as the other traffic control person.

Place yourself in an area that will allow you to escape from the roadway, due to erratic driving or an accident etc.

Traffic Control Person(s) working without the benefit of radio communication must signal each other prior to a control status change from stop to slow or slow to stop etc.

It is suggested that pumping the sign-up and down would be a suitable indicator of such intention.

On learning of the approach of emergency vehicles, traffic must be stopped in both directions, allowing a clear path for the emergency vehicle(s) to pass through.

Traffic control Person(s) shall not engage in other work while directing traffic and must conduct themselves in a courteous professional manner.

Vehicles being operated in a reckless manner or disregarding the direction of a Traffic Control Person(s) should be reported as soon as possible to the Supervisor with a description and license plate number if it can be obtained.

Reviewed with Traffic Control Person _______________________________________________

On __________at ___________________________________a.m./p.m.

Signed ________________________________________________________________________



WELDING AND CUTTING PROCESSES PURPOSE: To establish a policy for the handling, transportation, and use of gas cylinders, other welding components in Sullivan, workplaces. To recognize the hazards from welding fumes and gases.

POLICY:

Cylinders, piping, and fittings used in welding and cutting operations shall be protected against damage.

No cylinder of compressed gas shall be dropped, hoisted by slings or transported in a horizontal position. Cylinders shall be secured in an upright position always.

The valve of the cylinder must be closed, with the protective cap secured on it, when it is not being used or when the cylinder is spent.

Precautions must be taken to prevent a fire from cutting, welding, and grinding operations. The area must be clear of flammable/combustible materials. If possible provide barriers such as fire blankets or metal sheeting to prevent the spread of sparks and slag from the work area.

Have fire extinguishers that are in good order, in close proximity to where the cutting, welding and or grinding work is taking place.

Do not hang an electrode or ground lead over a compressed gas cylinder.

In an area where electric welding is being carried out, keep electrodes and metal scrap cleaned up and placed in appropriate receptacles.

Welding fumes and gases must be recognized, assessed and controlled to protect the workers. Remove paint and coatings from an area to be welded to help reduce the amount of toxins to be created.

If possible use welding rods or electrodes made of material that releases the least amount of toxic substances. Use only the current, rod size and arc length that is necessary for the job. Take special precautions when welding in confined spaces.

Adjust posture and technique to keep the face away from the welding plume and toxins. Whenever possible use a charcoal filter to reduce the inhalation of fumes and gases.

Never cut or weld drums, barrels, tanks that have not been cleaned or purged.



HEALTH EFFECTS:

Health effects from the inhalation of welding fumes and gases can include but are not limited to; kidney damage, lung cancer, destruction of red blood cells bronchitis and respiratory irritation.

COMMUNICATION:




VEHICLE RECOVERY SAFE WORK PROCEDURE: PURPOSE: This “Safe Work Procedure” specifies the requirements for vehicle recovery at Sullivan workplaces as well as calculations to be used for the selection of proper rigging components.

HAZARD AND RISK ASSESSMENT;

Before attempting to recover any vehicle or equipment mired in mud or snow a hazard risk assessment must be conducted.

The Gross Registered Weight of the vehicle being recovered must be established along with the amount of gradient/surface resistance involved, i.e. tire depth, wheel depth, etc.

Tire Depth When a vehicle is mired at a depth covering the lower part of the sidewall of a tire.

Wheel Depth: When a vehicle is mired at a depth above the bottom of the wheel rim up to the centre of the rim.

Body Depth: When a vehicle is mired above the wheels.

RIGGING: (for vehicle recovery)

Rigging including rope, wire rope, cable, chain (grade 8), slings, shackles and associated fittings. All rigging is to be rated at a 2 to 1 safety factor twice the GVW (gross vehicle weight, including load if applicable) of the vehicle being recovered.

Rated attachment points shall be used for vehicle recovery and where two attachment points are available, both shall be used.

Vehicles not retrofitted with engineered attachment points for recovery rigging, shall have rigging attached by the vehicle owner or his driver.

When stuck with a trailer attached, when possible the trailer should be disconnected and recovered separately.

A vehicle hauling a pintle hitch trailer shall unhitch the trailer prior to extrication if possible.

POLICY

When a vehicle is mired, avoid making the situation worse by continuing to attempt to extricate the vehicle without adequate assistance.



Vehicle recovery shall be supervised to ensure all personnel, including contractors, are informed of the hazards.

Consider reducing the total vehicle resistance by shovelling, lifting etc. to install traction aids.

Ensure that all personnel (employees and the public) stay clear of the recovery area, to avoid pinch pints and the possibility of the rigging slipping or ricocheting if it should fail.

Identify and maintain communication methods to be used by personnel during recovery operations, i.e.: hand signals, radios, spotters etc.

Ensure the recovery vehicle takes up the rigging slack slowly to preload the recovery system before applying recovery power. Sling shooting is strictly prohibited under any circumstances. Do not shock load the recovery system.

Whenever possible an in-line pull shall be used in a vehicle recovery operation.

Recovery systems shall be inspected prior to and after use.

Damaged rigging shall be removed immediately from service.

COMMUNICATION:




FIRE PROTECTION PLAN PURPOSE: Sullivan values its employees, their health and safety, as well as company assets, including buildings and equipment, etc. The risk and cost of fire can be extremely high in economic and human terms and accordingly a fire protection plan has been developed as a guideline for all managers and supervisors to follow.

POLICY:

The company will initiate and implement, monitor and verify that all management, supervisory and employee personnel are aware of the fire protection plan developed for their workplace.

New workers will receive training regarding the fire protection plan at the time of his/her orientation.

The posted plan will include exit routes, the location of fire extinguishing equipment and first aid kits.

Construction project will have fire extinguishers whose contents are discharges under pressure and shall have an Underwriters Laboratories of Canada 4A40BC rating. O. Reg. 213/91, sections 52 – 58.

Every Fire extinguisher shall be inspected for defects or deterioration at least once a month by a competent person who shall record the date of the inspection on a tag attached to it.

After a fire extinguisher is used it shall be refilled or replaced immediately.

Before hot work is performed, employees must check for fire hazards such as but not limited to: wooden forms, scrap lumber, packing materials, cardboard and paper, flammable liquids and oily rags.

Gasoline, oil, grease and other flammable materials must be stored in safe locations, clear of work areas and not in any building or location where workers are likely to gather. “NO SMOKING” and “FLAMMABLE MATERIALS” signs should be posted outside the storage area. Gasoline and other flammables should be transported in closed metal containers with flame arrestors. Safety cans with spring loaded caps.

All fire prevention regulations established by customers and site owners must be observed. Employees must report fire damage to company property and or equipment to their supervisor/manager.

Employees will be trained in the use of fire extinguishing equipment and specifically in the use of fire extinguishers using the acronym “PASS”.

• P (pull the pin) • A (aim the discharge hose at the base of fire) • S (squeeze the handle)



• S (spray the contents of the extinguisher from side to side at the base of the fire) If an employee decides to try and extinguish a small fire, he/she shall establish his/her evacuation route and never allow the fire to spread to an area between them and their evaluation point. If in doubt as to the magnitude of the fire, leave the area promptly and notify the supervisor/manager. EVACUATION PLAN: An evacuation plan will be designed for each workplace to assist all employees and visitors to leave the work location in the case of an emergency. The supervisor/manager shall develop for his/her workplace, a method of implementing an alarm, that will alert people of the need to evacuate the area and gather at a pre-determined “muster point” for a head count. Should it be determined that someone is missing, no one should go back into the evacuated area. Await the arrival of emergency personnel, alert them that someone is missing and offer assistance that may help to locate the individual. COMMUNICATION: This policy will be communicated to employees through safety meetings/talks and during orientation.



PROCEDURES FOR THE HANDLING, USE AND STORAGE OF PROPANE PURPOSE: The purpose of this procedure is to ensure that the propane is handled, used and stored safely in all Sullivan workplaces. POLICY: Supervisors, lead hands, shall ensure that all employees handling propane are trained and certified to carry out the task assigned. Packaged under pressure, propane gas presents serious hazards if misused:

- High flammability and explosive potential - Displacement of breathable air in confined spaces and being heavier than air propane will collect in low

areas - Contact injury from accidental exposure to a substance under high pressure.

In construction, most propane applications dispense the fuel in a vapour form. For this reason, portable cylinders must be transported, stored and used in a secure upright position. Only cylinders that are in use should be kept in an enclosed area such as a building or other structure. All other cylinders, full or empty, should be stored in a well-ventilated area identified as a “Propane Storage” area, with the location of “full” and “empty” cylinders indicated. The storage area should be away from traffic areas, inaccessible to the public and out of areas where falling material may occur. When moving cylinders, keep them upright. Never roll cylinders. When moving cylinders from one level to another, use a hoisting cradle. Never hoist cylinders using a sling or by hooking onto the protective collar around the valve. Only trained and certified people will be allowed to attach propane cylinders to heaters, using proper tools and with materials to check for leaks. Safety glasses must be worn along with gloves, preferably rubber or neoprene, when connecting propane cylinders to appliances or equipment. Propane heaters must never be placed within three metres (ten feet) of propane cylinders, nor should they be placed in stairwells or doorway openings that may block an escape route in the event of a fire or explosion. If bulk tanks are installed for use in a workplace they must be protected against being damaged by vehicles and/or equipment. Store industrial type cylinders horizontally, with the safety relief valve beneath the liquid propane level of the tank. TRAINING: This policy will be communicated to employees through a safety meeting.



PROCEDURES FOR THE HANDLING AND STORAGE OF FUELS, GASOLINE & DIESEL PURPOSE: The purpose of this policy is to ensure that vehicles, equipment and vessels are fueled safely and to ensure that fuel is stored safely at Sullivan properties and worksites and to protect the environment from spills an associated hazards. POLICY: DELIVERING & DISPENSING FUEL:

- Delivery of fuel will be by approved highway tanks or mobile refuelling tanks. - Delivery may be into on-site mobile refuelling tanks or directly into the equipment - Transferring fuel from the supplying highway tank to an on-site highway tank will only be allowed if the

on-site highway tank meets the requirements of the B620 standard and the refilling of the on-site highway tank is done in accordance with section 5.6.2 of the Liquid Fuels Handling Code, 2007, which governs the loading and unloading of highway tanks and requires the use of a down spout to the bottom of the compartment for open dome loading, as well as bonding of the highway tank

- Highway tanks shall be operated by a competent person DISPENSING FUEL:

- All dispensing or transferring of fuel will be attended for the duration of the operation. The attendant must be aware of proper fuel handling procedures to minimize the risk of a spill and shall continuously scan the area adjacent to the fuelling operation for possible leaks or spills

- The transferring and dispensing of fuel will be done with pumping equipment and approved hose, and top-filled nozzle

- When fuelling under the conditions of Section 6.1.7.1 (a), (b), (c), (d), or (e) of the Liquid Fuels Handling Code, 2007 (see Reference section in this document), absorbent pads are to be placed around the fuel inlet prior to dispensing

- Ensure that a site-appropriate spill containment kit is readily available - When unreeling the fuel transfer hose and nozzle, the nozzle must be in the upright position. The nozzle

shall be kept clear of the ground when returned to the reel or storage position - Verify that this is a proper connection between the fuel fill hose and the fill; pipe of the highway tank,

mobile refuelling tank, or the equipment being filled. Verify that the fill valve is open - The transfer of fuel must be stopped prior to overflowing, leaving room for expansion. Mobile refuelling

tanks and fuel tanks on vehicles and equipment are not to be overfilled



- The operation of moving equipment in the immediate area of fuelling operation shall be suspended - Welding and/or burning operations within 3 metres must be stopped while fuelling is in progress - Maintain regular inspections of fuel systems and their components. Check for leakage deterioration, or

damage, in accordance with the Construction Regulation - Wear gloves when dispensing fuel, preferably rubber or neoprene

ADDITIONAL DISPENSING REQUIREMENTS FOR MARINE OPERATIONS: Section 6.1.5 of the Liquid Fuels Handling Code, 2007: Dispensing operations – Marinas 6.1.5.1 – At a marina, product shall not be dispensed to fuel a watercraft while: a) Its engine is running b) Any source of ignition is present within 3 m of the dispensing nozzle where it enters the tank to be refueled; and c) There is a source of ignition on board the watercraft being refueled 6.1.5.2 – Portable containers shall not be filled while located on a watercraft CAUTION: This section is intended for the mobile fueling of equipment on a watercraft not for the mobile fuelling of a watercraft. The Liquid Fuels Handling Code, 2007 prohibits the mobile fuelling of all watercraft.

- Secure barge or marine vessel on which the equipment to be fuelled is mounted to the work platform or wharf with proper marine lines

- Prior to transferring fuel to a mobile refuelling tank on a barge or to barge-mounted equipment, establish direct communication between the highway tank operator or mobile fuelling attendant and the marine operator. This shall be maintained until fuelling complete

- Where it is necessary to transfer a mobile fuelling tank from the wharf or work platform to a barge, or from one barge to another, the tank shall be engineered for lifting and equipped with proper lifting points and lifting tackle. The transfer shall be done with hoisting equipment in accordance with normal safety procedures

- During marine fuelling operations, the attendant shall be particularly vigilant in scanning the water area adjacent to the fuelling operation for possible leaks or spills

HEALTH HAZARD: Ingestion: Gasolines are unlikely to cause systemic toxicity following accidental ingestion. The main potential health hazard, however, is the possibility of severe, potentially fatal, damage to lung tissue, which can occur following aspiration of even small amounts of gasoline into the lungs. Never siphon gasoline by mouth nor put gasoline in your mouth for any reason. If gasoline is ingested do not induce vomiting but obtain medical advice immediately.



GUIDELINES FOR FUELING VEHICLES:

- Turn off your engine. Disable or turn off any auxiliary sources of ignition such as a camper or trailer heater, cooking units or pilot lights

- Put your vehicle in park and/or set the emergency brake - Do not smoke, light matches or use lighters while refueling - Use only the refueling latch provided on the dispenser. Never jam the refueling latch on the nozzle with

any object (i.e. gas cap, etc.) - Never leave the nozzle unattended - Do not overfill or top-off your vehicle tank – it can cause spillage - Do not allow children to fuel and/or assist fueling vehicle - Never use a cell phone or other personal electronic device while refueling for example, laptops, PDAs

and electronic games). These items should be left in your vehicle STATIC ELECTRICITY AT THE GAS PUMPS: Static electricity-related incidents at retail gasoline outlets can be avoided. In the unlikely even a fire occurs when refueling, leave the nozzle in the fill pipe and back away from the vehicle. Notify the station attendant immediately so that all dispensing devices and pumps can be shut off with emergency controls. Use the emergency shutdown button to shut off the pump. SAFETY TIPS TO AVOID STATIC ELECTRICITY BUILD-UP:

- Upon exiting vehicle and before handling the nozzle or fuel door, always touch a metal part of the vehicle such as the door or hood

- To avoid a build-up of static electricity, do not get back into your vehicle during refueling - If you cannot avoid getting back into the vehicle, upon exiting always touch a metal part of the vehicle

away from the fill point before handling the nozzle GUIDELINES FOR USE OF PORTABLE CONTAINERS:

- Use only an approved portable container (1 to 5 gallons, metal or UL approved plastic, coloured red, with vapour-tight cap). The container must be in good condition with vapor-tight cap. Never store gasoline in glass or unapproved containers

- When filling container, follow same rules as when fueling car; turn off engine; extinguish smoking materials, leave electronic devices in the vehicle

- Place portable fuel containers on the ground during filling and keep the metal nozzle spout in contact with the container to prevent build up and discharge of static electricity. Never fill a container in the bed of a pickup, in the back of a station wagon, or in the trunk of a car



- Keep container five feet away from cars to prevent ignition of fumes by hot engines or mufflers. Ask others, particularly children, to stand back during filling

- Manually control the nozzle valve throughout the filling process. Fill a portable container slowly to decrease the change of static electricity buildup and minimize spilling or splattering. Back off the trigger to slow fuel flow as the container becomes full. Fill container no more than 95 percent full to allow for expansion. When filling is complete, tightly cap container. Wipe off any gasoline that spilled on the outside of the container. Ask the station attendant to properly dispose of the material used to wipe off the gasoline.

GUIDELINES FOR TRANSPORTING GASOLINE IN PORTABLE CONTAINERS:

- Make sure the cap is on tightly before you put the container in your vehicle. Spills pose a fire hazard and gasoline odors are hard to remove from carpeting.

- Put container in trunk of car or in bed of pickup. Do not put container in passenger area of your vehicle - Restrain the container so it cannot tip over or slide around while you are driving. - Never leave a vehicle with a portable gasoline container in direct sunlight.

GUIDELINES FOR STORING GASOLINE SAFELY:

- Store a gasoline container in a well-ventilated place out of reach of children and pets. Do not store gasoline in the living area of a house

- Store containers away from ignition sources (gas pilot lights or flames, electric motors, stoves, heaters) within 50 feet

- Before refueling, turn off the engine or appliance. Allow hot surfaces to cool enough so they cannot ignite gasoline vapor

- Avoid getting gasoline on your skin or clothes. Use a funnel to avoid spills. Do not breath gasoline vapors GUIDELINES FOR DISPOSAL:

- Do not discard gasoline on the ground - Do not put a container containing gasoline in garbage can or trash container - Do not discard gasoline into a sewer, street drain, stream or river. Such actions are illegal - For old or dirty gasoline, find a recycling organization that will accept it. Locate such an organization by

contacting your community’s fire department, recycling centre or hazardous waste disposal center For more guidelines on proper handling of motor fuel, visit the American Petroleum Institute Web site at www.api.org, or the Petroleum Equipment Institute at www.pei.org. SPILLS:

http://www.api.org/

http://www.pei.org/



Preventative measures are the best means of avoiding an accidental release of petroleum products. However, in the event of an accidental release, the following will occur:

- The person in charge of the workplace will have appropriate spill response equipment available for all phases of the project area. See Appendix A for a list of such equipment

- Cleanup action will follow the spill contingency plan. See Appendix B for a sample spill contingency plan - All spills or suspected spills of petroleum products, on land or into water, regardless of size, will be

reported immediately to the Supervisor. The Supervisor will report the spill immediately to the Project Manager, or his delegate, who shall ensure notification of the appropriate authorities

POSTING OF PROCEDURE: This procedure shall be posted or available on site and a copy shall be incorporated in the company safety policies and procedures. All records of employee training must be kept. PROCEDURE FOR STORING FUEL ON CONSTRUCTION SITES:

- Where the circumstances require, fuel may be stored in an approved mobile refuelling tank - Mobile fuelling tanks must be stored in an area where it cannot be hit by vehicles or other equipment.

The fuel storage area also must be located away from drainage channels - Where a mobile refuelling tank is in use and there is a danger of spillage contaminating a stream,

waterway, or sewer, the refuelling tank shall be at a location that complies with the diking requirements of Section 3.3.1 of the Liquid Fuels Handling Code, 2007, unless double wall tanks are used. Refer to Appendix C for diking requirements

- All highway tanks and mobile refuelling tanks are to be properly labelled in accordance with the Transportation of Dangerous Goods Regulation

- Fire extinguishers shall be located near the fuel storage areas and be of a suitable type and size to permit the evacuation of workers during a fire. (4A, 40BC, minimum rating).

- Any worker who may be required to use a fire extinguishers shall be trained in its use - Smoking will not be permitted in the area of the fuel storage facility and “No Smoking” signs will be

posted. Smoking will not be permitted during any fuelling operation. “No Smoking” signs are to be maintained in good condition

- Waste oils, lubricates, greasy and oily rags or other materials subject to spontaneous combustion will be retained in a labelled container used for that purpose exclusively and will be properly disposed of at frequent intervals

- Appropriate emergency spill equipment will be available in the fuel storage area. See Appendix A for a list of such equipment

- No “hot work” shall take place within 3 metres of a storage zone POSTING OF PROCEDURE:



In cases where fuel is being stored on site, this procedure shall be posted or available on site and a copy shall be incorporated in the company safety policies and procedures. All records of employee training must be kept.



BATTERY ROOM WORK PURPOSE: The purpose of this procedure is to define known hazards and detail the appropriate control measures for work on batteries or in battery rooms. SCOPE: This safe work procedure applies to all workers employed or engaged by M. Sullivan & Son to work on batteries or in battery rooms. This procedure is intended to supplement OPG Safety and Environmental Instructions for Contractors, Instruction 39. PROCEDURE: HAZARDS OF BATTERIES AND BATTERY ROOMS: Some hazards of batteries or battery rooms are:

• Explosion – while batteries are begin charged they can discharge hydrogen gases (H2) from the cells. This gas is explosive when high enough concentrations are allowed to accumulate. When an accumulation of hydrogen gas mixes with the air and meets, an ignition source, such as a spark, an explosion can occur

• Acid Burns – the batteries normally contain Sulphuric Acid. Contact with the skin and eyes can result in serious chemical burns (acid) resulting in personal injury

• Short-circuiting – Metal objects near batteries or in a battery room can present significant hazards should the objects come in contact with exposed live electrical terminals which can result in arcing and rapid discharging of the battery. This could cause the battery to explode, resulting in serious injury to the worker(s)

• Electric Shock – Batteries and battery banks retain their charge even when disconnected and will induce an electric shock if contact is made with live terminals

CONTROL OF HAZARDS OF BATTERY BANKS AND BATTERY ROOMS: The following controls may be required when working on battery banks or in battery rooms:

• Work on battery banks is regarded as “Live Electrical Wiring Work” and can only be performed by qualified electrical workers



• A detailed Job Safety Analysis (JSA) should be prepared and thoroughly reviewed prior to any work being performed

• Prior to working in battery rooms, the atmosphere in which the batteries are housed should be tested to ensure that high levels of H2 gas are not present. This can be confirmed with the gas monitoring installed in the room or by use of an approved or suitable gas measure device

• If possible, nonconductive guards should be placed/erected over and around the battery bank to protect workers from accidental contact with the energized equipment

• Hot work and/or confined space procedures may apply • Never work directly over the vent caps installed on the batteries

VENTILATION:

• Ensure the area around each battery/bank is well ventilated • Prior to working in battery rooms, ensure that positive ventilation is present and that fans have been

running for a minimum of 30 minutes • Periodic gas monitoring can be performed, if needed

TOOLS AND EQUIPMENT:

• Only approved insulated tools are to be used while working on or near batteries or in battery rooms • Steel tape measures are not permitted in battery rooms • Workers entering or work at or near batteries should remove any metal articles (i.e. jewellery), which

may cause short-circuiting of the batteries EMERGENCY EYEWASH:

• An approved Emergency Eye Wash must be on site and located in close proximity to the work area prior to commencing any work on the batteries or in the battery room

PERSONNEL PROTECTIVE EQUIPMENT:

• Only personnel wearing the correct PPE as determined by the JSA will be allowed to work on or near the batteries or in the battery room

• Protective clothing may include splash-proof goggles, gloves, and aprons. A full-face shield with safety goggles, gloves and aprons. A full-face shield with safety goggles may also be necessary

• Workers should wear electrically insulated gloves when disconnecting or connecting cables to the terminals on a battery bank



HOT WORK: Work near battery banks or in battery rooms which could produce ignition sources such as sparks, and flames will require review for special conditions or controls. These specific conditions and controls can include where applicable:

• An approved hot work permit or access permit

• At least 12 hours prior to the ignition source being introduced, the batteries or battery bank should be off charge (equalize). All other nearby batteries shall be set at a charging rate that will prevent rapid generation of gas

• The work space shall be adequately ventilated for a minimum of 30 minutes prior to entering the work space to introduce the ignition source

• The atmosphere in the battery room shall be tested with an approved device to ensure there are no explosive gas concentrations

• A suitably rated fire extinguisher shall be present in the immediate vicinity of the work area TRANSPORTING BATTERIES: Prior to transporting batteries, it is necessary to consider the following:

• Do not move or work on batteries with electrolyte or filler caps removed • Ensure battery terminals are placed or insulated such that they cannot short together or make contact

during transportation • Batteries can be heavy, care is required when moving or lifting. Use of suitable lifting devices is

recommended • Ensure the combined weight of the batteries to be moved or transported has been considered • Ensure the batteries are secured or fastened to prevent tipping or spills. Use a non-conductive material

to secure the batteries • Wet batteries should be transported in a suitable container and an approved spill kit suitable for battery

acid should be readily available during transport FIRST AID MEASURES: When administering first aid to someone who has come in contact with sulphuric acid, always avoid direct contact. If possible, wear chemical-resistant protective clothing. Follow any first aid treatment and have the victim transported to the closest emergency care facility.



CONTACT WITH SKIN:

• Flush the contaminated area, as quickly as possible, with gently flowing lukewarm water for at least 30 minutes

• If irritation persists, repeat flushing • Do not interrupt flushing, keep emergency transport waiting until flushing has been completed • Be careful not to rinse contaminated water into the unaffected eye or face • If irritation persists, repeat flushing

CONNECTION WORK ON BATTERIES: Any work required to interconnect battery cells or wiring connections between battery banks and electrical equipment (e.g.: chargers, rectifiers or switches) that includes physical contact with the battery terminals shall be considered Live Work. All work associated with the installation of inter-cell and row jumpers as well as all battery bank testing should be completed prior to terminating the system circuit conductors (positive and negative cables). Additional precautions, procedures, tooling and personnel protective equipment will be required to safely perform the work. OHSA Section 191, OPG Contractor Safety Instructions 22 and 26 may require additional barriers or procedures to supplement those outlined below. INTER-CELL LINK CONNECTIONS:

• Only competent workers shall be permitted to perform work at or near live electrical equipment to attach and connect the jumpers between battery cells

• Workers must be accompanied by a safety person whom is certified in Emergency First Aid (including CPR) stationed so they can clearly see the worker performing the work

• If possible, only insulated tools shall be used • Workers shall wear approved rubber gloves which meet the requirements of OHSA 193 • Workers shall wear approved flame retardant protective clothing • Workers shall wear safety glasses and utilize an approved Arc Flash rated face shield • Only one row of batteries per bank to be worked on at a time

BATTERY TERMINAL CABLE CONNECTS:

• Only competent workers shall be permitted to perform work at or near live electrical equipment required to make final connections to batteries or to terminate cable jumpers between battery rows



• Workers shall ensure that opposite end of the cable being connected is properly terminated in a safe, guarded and isolated state. (OPG Work Protection may be required)

• Workers must be accompanied by a Safety Person whom is certified in Emergency First Aid (including CPR) stationed so they can clearly see the worker performing the work

• If possible, only insulated tools shall be used • Workers shall wear approved rubber gloves which meet the requirements of OHSA 193 • Workers shall wear approved flame retardant protective clothing • Workers shall wear safety glasses and utilize an approved arc flash face shield



SAFE WORK PROCEDURE – DRILLING ASBESTOS-CONTAINING MATERIAL (ACM) PURPOSE: The purpose of this procedure is to define known hazards and detail the appropriate control measures for work associated with drilling into Asbestos Containing Materials (ACM). SCOPE: This safe work procedure applies to all workers employed or engaged by M. Sullivan & Son where drilling into asbestos-containing material may be required. This procedure is intended to supplement OPG Safety and Environmental Instructions for Contractors, Instruction 44. The first choice for drilling into or removal of asbestos containing materials shall be the use of third party agencies who specialize in the removal and abatement of asbestos. This procedure is focused solely on drilling small diameter holes (less than 5/8” diameter) for equipment anchors. The designed substances report (DSR) should clearly outline all areas known to contain asbestos or other hazardous products. PROCEDURES: MODERATE-RISK WORK ACTIVITIES:

• The activities associated with this procedure are those that are being performed in proximity to asbestos containing materials that are required to be cut, sanded, drilled, broke, ground down or otherwise fragmented or disturbed.

• It is necessary to use PPE or other controls to prevent workers from exposure or airborne asbestos fibres • Drilling of small diameter anchor holes into asbestos containing materials shall be treated in similar

fashion to Type 2 Asbestos removal procedures. Glove bag removals are not practical for this type of work. Abatement prior to drilling is also not practical

• At all opportunities, plan the work to minimize the number of holes that require drilling • Larger diameter holes or holes that require core drilling shall first have asbestos abatement performed

prior to drilling



CONTROL OF HAZARDS ASSOCIATED WITH DRILLING ACM: The following controls may be required when drilling into surfaces known to contain ACM:

• Clearly mark the designated work area with caution tape and signs warning other workers not to enter the work area while drilling is in progress

• Workers performing the drilling are to wear appropriate protective clothing: o Clothing material must resist penetration by asbestos fibres o Clothing must be impervious to penetration by asbestos if street clothing is worn underneath o Clothing must cover the body and fit snugly at the neck, wrists and ankles o Clothing must include head covering and foot coverings (such as booties) o Torn clothing must be immediately repaired or replaced

• Workers are required to wear a properly fitted respirator equipped with a P100 (HEPA) filter • Strong adhesive tape (duct tape) should be placed on the wall at the location of the hole to be drilled,

transfer drill mark to the tape. The tape should help contain edge crumbling and loose pieces. Carefully remove the tape after drilling and fold over to contain the debris within the tape

• Additional precautions and consideration shall be used for holes being drilled completely through the wall as the opposite side of the wall may also contain ACM. Containment such as a box or bag sealed to the wall may be used for through penetrations. If possible, locate penetration and apply adhesive tape. HEPA Vacuum to be used to capture debris when removing the containment method used.

TOOLS AND EQUIPMENT:

• Vacuum type shrouds specifically manufactured for containing dust particles during drilling. These can be either those attached directly to a drill (Hilti systems) or separate units through which the drilling occurs (similar or equal to Bit Buddy 9018 by Dustless Technologies)

• HEPA Type Vacuum cleaners to be used. Connect dust shroud to vacuum cleaner • Plastic drop sheets to be placed on the floor directly below area being drilled • Strong adhesive tape (duct tape) • Vacuum filter bags and drop sheets to be placed into sealed containers upon completion drilling activities



COMPANY RULES



COMPANY RULES: PURPOSE: The purpose of this procedure is to establish rules of conduct that are necessary for efficient and safe operations on Sullivan premises and worksites. EQUAL OPPORTUNITY OR NATIONALITY: We are committed to providing equal employment opportunity regardless of race, colour, sex, age and religion. WORKING LANGUAGE: In order to ensure clear communication and protect the health and wellbeing of personnel, they should have a working knowledge of the English language. GENERAL: Adherence to company rules, including safe practices and procedures is a condition of employment for all personnel. Failure to comply with company rules is considered a violation of conditions of employment that could result in disciplinary action including termination. The following are considered violations of conditions of employment:

• Failure to comply with Sullivan or client safety policies and procedures and/or statutory safety laws and regulations

• Being absent from work without notification to supervisor or authorization from supervisor • Unsatisfactory job performance • Failure to follow direction from supervisor • Smoking in prohibited area • Consumption, possession or apparent impairment from alcohol or illegal drugs on company premises is

prohibited • Failure to advise supervision of the use of prescription medicine that may cause impairment • Fighting, horseplay, disorderly conduct, practical jokes or interference with other workers • Possession of prohibited, dangerous or concealed weapons • Providing or maintaining improper or false records or other fraudulent activities • Failure to immediately report to your supervisor unsafe conditions or incidents that could result in

property damage or injury



• Failure to report to supervisor, accidents, incidents, injuries and or discomforts experienced during the work period of a given day

• Using company vehicles without proper license, or while license is suspended • Misuse or willful damage of company or client supplied tools, equipment or property • Gambling, soliciting, or distributing unauthorized literature on company property during work hours • Theft or unauthorized possession of company, client or another employees’ property

COMMUNICATION: These rules will be communicated to workers during orientation and posted in a prominent location in the workplace.



DISCIPLINARY ACTION

PURPOSE:

The management of Sullivan has developed this procedure as a guideline to assist in applying consistent disciplinary action. It is not considered all-inclusive and disciplinary action must be determined based on the circumstances of each situation. GENERAL: Consistent disciplinary action should be applied for violations of job rules or safety policies and procedures. Disciplinary action shall not be applied only when people get “caught” through their involvement in accidents involving near misses, property damage or injuries. Disciplinary action taken due to violation of job rules, safety procedures or negligence that has resulted in an accident, shall be determined after the investigation is complete to ensure all facts are established. Written notices of violations, often viewed as a negative enforcement tool, can work in a positive manner. Written notices indicating that compliance with safety policies as expected often saves much time and repeated verbalization of the issues. For those workers who continually refuse to comply with safety requirements, further disciplinary action can be considered based on the evaluation of previous documentation. Disciplinary action can be in the form of written notice, temporary suspension or termination. The action need not be progressive but is dependent on the circumstances. Suspension without pay shall be considered, extending from the rest of the shift to several days, when the severity of the violation requires more than written notice and termination is considered too severe. ENFORCEMENT: First line Supervisors, such as Foreman and General Foreman are primarily responsible for the implementation of the safety program. Before they are able to enforce the program requirements it is their responsibility to ensure their crews are aware of the elements that apply to the work they are involved in. The first line Supervisors are the key to effective control of operations. They are in the best position, of direct supervision, to detect and correct unsafe acts and conditions that cause accidents and losses.

Though safety personnel are considered primarily to have a supportive role, they as well as all management personnel, have the responsibility and authority to correct unsafe acts and conditions and to stop unsafe work. DOCUMENTATION:



Written notices of disciplinary action taken shall be retained on file at head office. TRAINING: This policy will be communicated to workers at time of orientation.



DISCIPLINE NOTICE Attention: Mr. /Mrs. __________________________________________________________ You are hereby notified that your conduct, namely: ________________________________ ___________________________________________________________________________ ___________________________________________________________________________ is deemed to be unacceptable and detrimental to the good conduct expected of personnel working in this workplace. Further contraventions associated to your ________________________________________ may result in you being _______________________________________________________ ___________________________________________________________________________ Signed: _____________________________ Title: _______________________________ Copy issued to ______________________________________________________________ This ______________ day of ___________________, 20____, at _______________ am/pm.



PERSONAL PROTECTIVE EQUIPMENT



PERSONAL PROTECTIVE EQUIPMENT

PURPOSE:

As an employer, Sullivan is committed to ensuring that employees wear and use personal protective equipment as required by law and or a company/client policy. POLICY: PROTECTIVE HEADWEAR: Every worker shall wear protective headwear at all times when on a construction project or as required by a client/customer policy. The protective headwear shall be a CSA or ANSI certified hard hat. PROTECTIVE FOOTWEAR: Every worker shall wear protective footwear at all times when on a construction project or as required by management, or by a client/customer policy. The protective footwear shall be CSA certificated “Grade 1” work boots, with electric shock resistant soles. If so equipped, work boots shall be laced sufficiently so as to provide ankle support and bet tied. PROTECTIVE EYEWEAR: Every worker shall use protection appropriate in the circumstances when there is a risk of eye injury or when a client policy dictates that eye protection is to be worn. Workers and their supervisor must assess the degree of risk associated with a task and select the appropriate eye protection. Tinted safety glasses should be worn in bright atmospheres. Low Risk – due to the constantly changing risks in a workplace, it is strongly recommended that workers wear safety glasses at all times when on a project. Safety glasses should also be worn when working on or under vehicles/equipment to make repairs or carry out maintenance work. Medium Risk – safety glasses and a face shield must be worn when grinding, chipping or drilling etc. High Risk – when there is a high risk of injury to the eyes from flying particles or a substance splash, safety glasses shall be worn. Chemical goggles should also be considered when there is a possibility of a substance splash. Safety glasses must be CSA certified.



RECOMMENDED CLASS OF HEARING PROTECTOR Table 1

MAXIMUM NOISE LEVEL (dBA) RECOMMENDED CLASS OF HEARING PROTECTOR Less than 85dBA No Protection Required Up to 89dBA Class C Up to 95dBA Class B Up to 105dBA Class A Up to 110dBA Class A plug + Class A or Class B muff More than 110 dBA Class A plug + Class A or Class B muff and limited

exposure TYPICAL NOISE LEVEL MEASUREMENTS FOR CONSTRUCTION

*EQUIPMENT NOISE LEVEL (dBA) AT OPERATOR’S POSITION Cranes 78-103 Backhoes 85-104 Loaders 77-106 Dozers 86-106 Scrapers 97-112 Trenches 95-99 +Pile drives 119-125 Compactors 90-112 +Explosive-actuated tools 120-140 Grinders 106-110 Chainsaws 100-115 Concrete saw 97-103 Sand blasting nozzle 111-117 Jackhammers 100-115 Compressors 85-104



HEARING PROTECTION: In general, if one is standing at arm’s length from another individual and cannot carry on a conversation in a normal tone of voice because of noise, then hearing protection shall be worn AT ALL TIMES. Sullivan, as an employer, will take all measures reasonably necessary in the circumstances to protect employees from exposure to hazardous sound levels. The protective measures shall include the provision and use of engineering controls, work practices and hearing protection devices. No employee shall be exposed to a sound level greater than an equivalent sound exposure level of 85dBA. Employees shall wear/use hearing protection devices appropriate in circumstances to protect them from sound levels greater than the limit if the engineering controls that are required: • Are not in existence or not obtainable • Are not reasonable or not practical to adopt, install or provide because of the duration or frequency of the exposure or because of the nature of the process, operation or work • Are rendered ineffective because of a temporary breakdown of the controls, or • Are ineffective to prevent, control or limit exposure because of an emergency. Where practicable, a clearly visible sign shall be posed at every entry to an area where the noise level regularly exceeds 85 dBA, warning of the hazard. Employees will be trained to be diligent in selecting and using appropriate hearing protection for the sound levels exposed to and how to fit and care for it as per the manufactures instructions. Equipment with noise reduction components is to be used when available and all equipment is to be operated and maintained, as per manufacturer’s specifications, to minimize noise levels. When employees are present on or in a client premises requiring the use of hearing protection, they shall abide by the client policies. Hearing protection is provided to employees as follows: Ear muffs which, if properly fitted and worn, provide a better noise reduction factor. Ear plugs must be fitted to provide a good seal. Foam ear plugs should not be reused. Neoprene style ear plugs may be washed and reused. NOTE THE NOISE LEVEL CHART. SKIN PROTECTION: Workers shall use protection appropriate in the circumstances when there is a risk of injury to the workers skin from a noxious gas, liquid, fume or dust, an object that may puncture, cut or abrade the skin, a hot object, hot liquid or molten metal and radiant heat.



FALL ARREST EQUIPMENT: When a worker is exposed to a fall hazard as described under section 26 of O/Reg. 145/00, he or she shall wear a full body harness adequately secured so as to arrest a fall without the person bottoming out. Before using a body harness for the first time the individual must be trained in “Working at Heights”. The employer must develop and review with him/her, a written rescue plan. The full body harness must be properly fitted and adjusted so as to prevent roll out, should the wearer be subjected to a fall. RESPIRATORY PROTECTION: When working on sewage systems, with chemicals or substances where the MSDS recommends or stipulates that respiratory protection be worn, the appropriate type of respirator shall be worn. Employees required to use respiratory equipment should be deemed to be medically fit to use a respirator and fit tested by a qualified caregiver. Supervisor(s) shall ensure that workers required to wear a respirator, know how to field test their respirators for fit and how to properly clean and maintain the respirators they are issued as per the manufacturer’s specifications. Workers wearing respiratory protection should be clean shaven.

Cartridge Colour: General Use: White Acid Gases Black Organic Vapours Purple Hepa Filter (Asbestos) Grey Dusts, Fumes & Mists

HIGH VISIBILITY CLOTHING: Employees working in an area where they may be endangered by vehicular traffic and/or operating equipment, must wear a garment that provides a high level of visibility. The garment, as a minimum, should cover the upper portion of the body and may be fluorescent orange or green in colour with reflective stripes on the front and back. For night work, additional stripes or bands must be worn on the arms and legs. Note: When the high visibility garment is a vest, it must be a five-point tear away style with a flame-retardant value if working near energized electrical equipment. ALL PERSONAL PROTECTIVE EQUIPMENT MUST BE INSPECTED BY THE USER DAILY TO ENSURE IT IS IN A SATISFACTORY CONDITION.



Employees will be responsible for, maintaining the personal protective equipment being used by them, in a good condition. Damaged or defective equipment must be reported to a supervisor forthwith and taken out of service if warranted. COMMUNICATION AND TRAINING: This policy will be communicated to employees during “orientation training” and during safety meetings/talks. Employees will be trained in the selection, use and care of personal protective equipment as per company policy and manufacturers specifications.



PREVENTATIVE MAINTENANCE



PREVENTATIVE MAINTENANCE PURPOSE: The purpose of this procedure is to identify a minimum standard for inspection of tools, equipment, vehicles and facilities used by Sullivan employees. It also includes a tagging system for the identification of damaged or defective tools, as well as repaired tools and tools and equipment in good operating condition. This procedure is not intended to replace the responsibility of users to inspect tools/equipment and vehicles for defects before use, and to remove defective items from service. PROCEDURE: When a tool, piece of equipment or vehicle is found to be damaged or defective it is to be removed from service and reported to the Superintendent or designate. A Red Tag is to be fixed to the item identifying that it is damaged or defective and not to be used. The item is not to be entered back into service until it has been inspected, and or fixed by a competent or licensed individual. If the item is then deemed acceptable for use a green tag is applied. If not, it is removed from service permanently. SCOPE: This procedure applies to:

• Fall arrest equipment such as harnesses, lanyards, lifelines, horizontal cable lines and rope grabs • Rigging such as slings, hooks, shackles, come-along, chain falls, hydraulic and mechanical jacks • Electrical equipment such as cords, electrical tools and GFI’s • Chainsaws • Ladders • Compacting equipment • Scaffolding • Vehicles and equipment • Small tools, quick cut saws, air chisels, jack hammers, skill saws and table saws etc. • Measuring equipment, lasers and levels, etc. and • Company facilities, offices, storage facilities, repair garages



INSPECTIONS: Inspection of tools/equipment will be by competent personnel, whose trade or experience has given them knowledge of the tool or equipment being inspected. Scaffolding designed by a professional engineer shall be inspected by her/her before it is used to ensure that it is erected in accordance with the design drawings. If defects are found, scaffolding will not be used until fixed/repaired. DEFECTIVE TOOLS/EQUIPMENT: Defective tools requiring repairs should be tagged defective, with a red tag. Users should note defects or required repairs on the red tag as specifically as possible. Tools/equipment that cannot be repaired to perform in the intended manner shall be removed from service. A sample of the defect tag is attached. REPAIRED TOOLS/EQUIPMENT: Green tags are to be attached to repaired tools or small equipment and tools or equipment examined and found to be in good condition. A sample good to go green tag is attached. MAINTENANCE OF VEHICLES/EQUIPMENT: Vehicles and equipment such as trucks, forklifts, personnel hoists, cranes, etc., will be maintained and repaired in accordance with the manufacturers specifications, or if required those of a professional engineer. Every replacement part for a vehicle, machine, tool or equipment shall have the same safety factor as the part it is replacing. All machines, vehicles, tools and equipment rated at greater than 10 horsepower shall be equipped with the manufacturer’s operator manuals. The equipment manager/supervisor shall be responsible for establishing a schedule and maintaining documentation to ensure compliance. COMMERCIAL VEHICLE MAINTENANCE: The purpose of this standard is to establish a procedure to inspect, maintain and repair commercial vehicles owned or leased by Sullivan. Records shall be kept for each commercial vehicle that indicates the following:

• The make, year, V.I.N., license and fleet number • The type and date of every repair or maintenance activity • The odometer reading at the time of the repair or maintenance activity • The type of inspection and maintenance being performed, (A) quarterly and (A) annually • A record of any suspension modification that affects the gross vehicle or axle weight rating



• The required information must be assembled and kept current for each vehicle • The vehicle records must be kept for two years in the company garage office • If a vehicle is sold, destroyed or returned to its lesser, the records for that vehicle may be discarded after

six months SERVICING SCHEDULES QUARTERLY (Q SERVICE)

• As per inspection worksheet • Repairs to be recorded on a work order



TRIP INSPECTIONS/COMMERCIAL MOTOR VEHICLES: APPLICATION: This directive applies to the following Sullivan commercial motor vehicles:

1. Trucks and truck tractors with registered gross weights over 4,500 kg (9,920 lb), 2. Trucks and truck tractors with an actual weight over 4,500 kg. Actual weight means the weight of the

truck or truck tractor only, which may include any weight transferred to it by an attached trailer, and 3. Buses. Bus means motor vehicle designed for carrying ten or more passengers, excluding the driver, and

used for the transportation of persons. Note: The weight transmitted to the road by the axle(s) of an attached trailer does not have to be added to the RGW of the truck if the transmitted weight is 2,000 kilograms (6,172 lb) or less. IN THIS DIRECTIVE: “Operator” means the person directly or indirectly responsible for the operation of a commercial motor vehicle including the conduct of the driver and the carriage of goods or passengers, if any, in the vehicle or combination of vehicles. REQUIREMENTS: No person shall drive a commercial motor vehicle unless the person has inspected or caused to be inspected the commercial vehicle within the previous 24 hours. Highway Traffic Act of Ontario. A driver must not exceed 13 hours of driving in one day. All commercial vehicle operators must complete a daily log which is maintained for 6 months by dispatch. No driver shall operate a commercial vehicle while under the influence of alcohol or drugs. They must not operate while their ability or alertness is impaired due to fatigue. OUTSIDE INSPECTION:

1. All lights and reflectors (equipped and functioning as required under the Act and the regulations). 2. Wheels and fasteners (for wheel or rim cracks, defect lock rings, loose or missing fasteners). 3. Tires (for tread depth, flat or noticeable leak, any visible bumps or bulges, mixture of bias and radial tires

on same axle, contact with any part of the vehicle or any other tire). 4. Fuel system (for a visible leak at any point, tank filler caps shall not be missing, fuel tank shall be securely

mounted). 5. Exhaust system (for audible leaks, missing or loose components, and secure mountings). 6. Fifth wheel (for loose, missing or ineffective fasteners, missing, broken or deformed parts in the locking

mechanism, operating handle being in closed or locked position when in use).



7. Suspension, spring, air bags and controlling attachments (for any cracked, broken, lose or missing axle positioning or fastening parts, broken or missing spring leaves, broken coil springs, deflated air suspension due to system failure).

8. Towing and coupling devices as required under the Act and the regulations (for missing or unattached safety devices, or safety devices not capable of secure attachment, wear kinks or broken cable strands, improper repairs).

9. Load security: the following conditions must exist before a driver can operate a commercial motor vehicle:

a) The vehicle cargo must be properly distributed and adequately secured. b) Make sure that all secured equipment and vehicle structures are in good working order and

used consistently with their capability. c) Stow vehicle equipment. d) Make sure that nothing obscures front and side views or interferes with the ability to drive

the vehicle or respond in an emergency. The driver must complete periodic inspections during transit.

10. Load covering (for compliance with the requirement of Regulation 577 of Revised Regulations of Ontario, 1990).

11. Air brake adjustment and connections (for absence of braking action on each wheel, missing, broken or loose mechanical components readily visible, audible air leaks and brake readjustment limits).

12. Hydraulic brake fluid (for visible leakage) 13. Mirrors as required for condition and adjustments.

INSIDE INSPECTION:

1. Steering wheel, excessive play, looseness 2. Brake pedal reserve and fade 3. Brake booster operation 4. Brake failure warning light functions as intended 5. Brake air pressure or vacuum gauge 6. Warning signal, low pressure or low vacuum 7. Windshield washer and wipers function as intended 8. Windshield and windows are to afford the driver a clear view 9. Mirrors, adjustment and condition 10. Defroster and heaters function as intended 11. Horn functions as intended 12. Driver’s seat belt and seat security function as intended 13. Parking brake adequate to hold vehicle



14. Emergency equipment as required under any Act and the regulations made there under that class of vehicle

DOCUMENTATION:

Upon completion of an inspection the person carrying out the inspection shall record on an inspection report:

• The motor vehicle make; • The number plate or unit number of the truck, bus or tractor; • The number plate or unit numbers of any trailer towed by the truck, bus or tractor; • The date and time of the inspection; • The name and signature of the person who carried out the inspection; and • Any safety defects of the items referred to disclose by the inspection

If no safety defects are disclosed by the inspection, the person who carries out the inspection shall record that fact on the inspection report. Every driver of a commercial motor vehicle shall, when he or she finishes driving the vehicle in a 24-hour period commencing with the inspection required, record on the inspection report any safety defects of the items referred to, he or she observed while driving or while otherwise in charge of the vehicle. Every driver shall forward the inspection report to the operator that is responsible for the commercial motor vehicle as soon as possible after the inspection report is completed. An inspection report is completed:

(a) If no safety defects of the items referred to are disclosed, at the end of the 24-hour period, (b) If a safety defect of any item referred to is disclosed, after a person who undertakes to repair the safety

defect completes the entries required. Every person who undertakes a repair safety defect recorded in an inspection report shall record on the inspection report the date on which the repair is completed, or the fact that no repair is required and shall sign each entry made by him or her on the report. TRAINING: Training will be provided to the appropriate people on an ongoing basis.



FACILITY MANAGEMENT PURPOSE: The management of Sullivan have developed a policy, outlining responsibilities of the Facilities Manager, in maintaining facilities under the care and or control of the company. POLICY: The Facilities Manager will, with co-operation of each property manager/supervisor, be responsible for the care and maintenance of the properties under his control, Property care would include but is not limited to:

• Ensuring floors, aisles and walkways are kept free of slip and trip hazards • Ensuring stairs are maintained in a good condition and free of clutter • Ensuring facilities are kept clean and orderly including washrooms, kitchen and eating areas • Ensuring adequate lighting is provided both indoors and outdoors • Ensuring that materials are stacked, shelved and stored so as not to create a hazard by tripping or falling • Ensuring that hazardous chemical spills are contained and cleaned up by personnel, trained, equipped

to handle and safely dispose of the material Property maintenance would include, but is not limited to:

• The cleaning of snow from parking lots, yards, walkways, doorways and driveways in an appropriate time frame;

• Ensuring that outdoor walks, paths, driveways, parking lots and facility entrances are treated with a sand/salt mixture sufficient to minimize the risk of a slip and fall incident;

• Ensuring that snow and ice accumulating on a roof is removed or protection is in place to warn of the hazard, should it slide from the roof;

• Ensuring that parking lots adjacent to the facility are maintained in good condition; • Ensuring that fire suppression equipment is inspected and certified annually; • Ensuring that all alarm systems are tested at least annually or as per the manufacturers specifications; • Ensuring that roof top units are inspected as per the manufacturers specifications and the access walks

and travel restraint anchor points are inspected annually; • Ensuring that all lifting equipment is inspected at least annually, or as per manufacturers specifications,

including vehicle hoists, chain falls, and lifting jacks; • Ensuring that all personnel lifts are inspected at least annually or as per the manufacturers specifications;



• Ensuring that electrical installations and components are protected and maintained in good condition with gfci protection where required;

• Ensuring that doors are maintained in a good operating condition, with clear pathways to allow for emergency exit and that emergency exit lighting is illuminated;

• Ensuring that emergency lighting is functional and adequate where deemed necessary; • Ensuring that window cleaning operations are carried out in a safe and compliant manner and; • Ensuring that all equipment guards are maintained and in good working order.

Records of all repairs, testing and inspections will be maintained by the facility manager/supervisor, with copies being forwarded to the corporate Safety Officer. COMMUNICATION: This policy will be reviewed with appropriate personnel during a safety meeting.



TRAINING AND

COMMUNICATION



ORIENTATION PURPOSE: It is the policy of Sullivan to educate and train all new and re-hired workers with health and safety information and known hazards associated with the workplace. A copy of the completed orientation document along with the individuals training records is to be forwarded to the company office in Arnprior for the attention of the safety department. Transferred workers shall be informed of workplace hazards, prior to starting work at a new workplace. A copy of the workers training records should be obtained and retained at workplace. The orientation will be provided by the project supervisor or a competent person designated by him or her. PARTICIPANTS: New Employees: Individuals coming into the workplace, including but not limited to, new hires, client representatives and subcontractor employees. Re-hired Employees: Employees who have not been in the employ of Sullivan for three months or more. Transferred Workers: Employees who have worked for Sullivan for more than three consecutive months and are moved to various company workplaces. RESPONSIBILITIES: Orientation activities are an ongoing process that requires diligent attention. MANAGEMENT:

• Develop policies and procedures on workplace orientation • Maintain and keep records of orientation(s) along with copies of the individuals Trade or Skill Set

certification and other applicable training records for Sullivan employees. • Review and monitor procedures and implement changes when warranted.



SUPERVISOR(s): Ensure that orientation is carried out at the workplace for all new and re-hired employees within forty-eight hours of hiring and that a copy of the “New Worker Orientation” form along with copies of the individuals training records and Trade or Skill Set certificates if applicable, are forwarded to head office. Ensure that orientation is completed for client representatives and subcontractor personnel at the first reasonable opportunity after they commence work in his or her workplace. The completed orientation form along with copies of the individuals training records are to be kept at the workplace. WORKERS: Understand and participate in the orientation process. Ensure that they understand their rights and obligations in the workplace. OTHER PERSONNEL: Personnel visiting the site occasionally for business reasons, or by invitation, may not require orientation, but if they are wanting to visit work locations, they must be escorted. ORIENTATION PROCEDURES:

• Explanation of the workplace and expected duties; • Reference the company “Safety & Accident Control Policy”; • Personal Protective equipment requirements; • Reporting requirements for accidents, injuries, discomforts, near misses and unsafe acts or conditions; • Review of company rules; • First aid kit locations & attendants; • Emergency response procedures; • Identification of workplace safety personnel; • Project telephone number(s) and absentee reporting requirements; • Explanation of the company “Return to Work” policy; • Specific hazards identified or known to the workplace; • Training and Trade or Skill Set certificates verified.



COMMUNICATION: This policy will be communicated to employees by means of “tool box” or “safety meeting” talks. TRAINING: Training on the Orientation Program and how to conduct Orientations will be provided by the CHSO to Supervisors or Designates when required. EVALUATION: Management along with the corporate Joint Health & Safety Committee will review this policy annually. Recommendations, if any, will be developed and implemented to ensure continuous improvement of these activities.



ROLES

Manager/Direct Supervisor

The Manager/Supervisor plays an important part in the orientation of a new employee. It is essential that a new employee is properly trained and introduced to Sullivan to ensure his/her safety as well as that of others. In addition, a proper orientation of new employees helps engage and interest them in the company, starting what will hopefully be a long and mutually beneficial relationship.

New Employee

A new employee of M. Sullivan and Son is expected to follow the procedures outlined in his/her orientation, and comply with all relevant policies and procedures.

“Buddy” Employee

Depending on the classification (occupation) of the new employee, a “buddy” employee may be assigned to him/her. The “buddy” is usually from the same occupation as the new employee, however, other employees may be considered as long as they have a thorough understanding of the new employee’s responsibilities. The Buddy is responsible for answering general questions of the new employee for the first six months of employment and will hopefully be a “mentor” to the new staff member. The orientation checklist will be signed by the Manager and Employee and filed in the respective employee personnel file.

For the period of time the new employee is on probation, the Manager should schedule regular meetings to determine if the employee feels

- Confident he/she can perform the job - He/she understands and feels part of the culture - He/she understands the organizational structure and people


White copy- site Yellow- employee file Pink- employee

SQF 112 rev 003 2016-08-08


WORKPLACE HEALTH & SAFETY ORIENTATION/REVIEW ___________________________________

Sullivan is a company dedicated to the creation of safe work places for everyone therein.

This is achieved, in part, through compliance with the applicable laws and regulations, policies and safe work procedures and the most important element of a good safety program, “you and your performance”.

As a Supervisor-Worker, you will be expected to conduct yourself in a safe, compliant and orderly manner at all times.

Failure to do so may result in disciplinary action being taken and you’re being prohibited from entering the workplace.

If you are not sure how to conduct your work in a manner that is compliant with the law and/or a safe work procedure, “ask”.

Personal protective equipment, including protective headwear and protective footwear, must be worn on a construction project.

Appropriate eye protection, safety glasses, face shields, goggles, etc. must be worn when there is risk of injury to an eye or the face from flying or falling particles, a liquid or substance splash, dust, welding and cutting activities.

Appropriate respiratory protection must be worn when subjected to a hazardous dust, fume or mist or as per direction of a MSDS.

Falls continue to be the major cause of death and critical injury accidents. Accordingly, every precaution must be taken to prevent falls through the proper use of fall arrest equipment, ladders, scaffolds etc., a travel restrain system and/or adequate guardrail systems. All injuries resulting from a workplace activity must be promptly reported to the workplace supervisor. Materials, tools and equipment must be maintained and used in a manner that does not pose a hazard to yourself or other person(s) in your work area. Ongoing cleanup of materials and debris created through your work activity must be carried out, so as not to create a hazard.

REMEMBER, YOUR HEALTH AND SAFETY ARE IMPORTANT TO EVERYONE



TRAINING PURPOSE: Sullivan will encourage employees to seek educational training and development opportunities that will enrich their lives, improve job performance and develop potential in current and prospective positions. RESPONSIBILITIES: Management:

• Research and develop training programs that are relevant to Sullivan workplaces and their employee needs.

• Ensure that legislated training is completed and updated as required. • Maintain training records of employees.

Supervisors:

• Ensure “Basic Health & Safety Orientation” training is provided to employees as required by the corporate “Orientation” standard

• Ensure that employees under their supervision have adequate training to conduct assigned tasks and are informed about the hazards in the workplace

• Specialized training will be conducted by individuals who are deemed to be competent as the result of their knowledge, experience, and training with respect to the subject matter

Employees:

• To participate in training such as orientation, emergency procedures, and safe work procedures • Report unsafe conditions to supervisor • Apply the training and instruction received while carrying out assigned tasks

Benefits of Training:

• Well trained employees require less supervision • Employees are more productive and motivated • Employees that are engaged in continuous learning are better able to meet the challenges of an ever

changing work environment Communication:

• This policy will be communicated to employees through safety meetings/talks



Training: • Training requirements for individual roles within the company are as follows:

Sr. Management – 5 step Supervisor Awareness, WHIMS 2015 and AODA

(Working at Heights, First Aid/ CPR are not mandatory but encouraged)

Project Managers – 5 step Supervisor Awareness, WHIMS 2015 and AODA (Working at Heights and First Aid/ CPR are not mandatory but encouraged)

Superintendents/ Supervisors - 5 step Supervisor Awareness, 2 Day IHSA Supervisor Training, WHIMS 2015, Working at Heights, First Aid/CPR Field Staff /Workers/Sub Contractors – 4 step Worker Awareness, WHIMIS (Working at Heights if required, and any other Job Specific Training as per legislative requirements) JHSC Members – 4 step Worker Awareness, WHIMS and H&S Rep Training H&S Rep – 4 step Worker Awareness, WHIMS and H&S Rep Training, (H&S Rep Certification if required as per legislation)

Evaluation:

• Management along with the corporate Joint Health & Safety Committee will review this policy annually. Recommendations, if any, will be developed and implemented to ensure continuous improvement of this training standard.

COMPETENCY: A “competent person” means a person who,

• Is qualified because of knowledge, training and experience to organize the work and its performance • Is familiar with Occupational Health & Safety Act and Regulations that apply to his/her work, and • Has knowledge of any potential or actual danger to health or safety in the workplace • Minimum qualifications for each position identified on the company organization chart have been

established



POLICY: Training will be ongoing in various aspects of the company including, but no limited to: Legislation, safe work procedures, personal protective equipment, the use of tools and the operation of equipment and vehicles, etc. Training records will be received from all employees at time of orientation and job specific training provided when deemed necessary. New employees and inexperienced workers will be assigned, whenever possible, to work with a mentor to learn the safe and efficient manner of carrying out a work assignment. The workers supervisor shall monitor and assess a new or transferred workers performance and in consultation with his/her mentor and fellow workers, establish that individual is competent to perform work with limited supervision, before assigning him or her to work alone. This will be considered a probationary period. Management reserves the right to decide the competency level of an employee as the result of their on the job experience, training and reliability. COMMUNICATION: This policy will be communicated to employees through safety meetings/talks. HEALTH & SAFETY AWARENESS TRAINING: All workers must complete, or provide proof, of having completed the basic Ontario “Health & Safety Awareness Training for Workers” program. The basic occupational health & safety awareness training program shall include, but is not limited to, instruction in the following:

• The duties and rights of workers under the Act • The duties of employers and supervisors under the Act • The roles of the Ministry, the • Workplace Safety and Insurance Board (WSIB) and designated entities under the Act with respect to

occupational health and safety



• Common workplace hazards • The workplace Hazardous Materials Information System (WHMIS), with respect to information and

instruction on controlled products; and • Occupational illness, including latency

All supervisors, within one week of performing supervisor duties, shall complete the basic Ontario “Health & Safety Awareness Training for Supervisors” which shall include, in addition to the above named topics, instruction in the following:

• The roles of a health & safety representative and joint health & safety committees under the Act • How to recognize, assess and control workplace hazards and evaluate those controls • How to source information on occupational health & safety

Records of employee training will be maintained by the employer.



CRISIS COMMUNICATION PURPOSE: The purpose of this policy is to develop a communication standard that will provide a framework for the communication of workplace activities including but not limited to, co-ordination, safe work practices, known hazards and instruction. Communication may be oral, written, conveyed electronically, by facsimile, telephone, radio or by signals. Communication, when possible, should be verified as received and understood. RESPONSIBILITIES: EMPLOYER: Responsibilities include by are not limited to:

• Developing safe work policies and procedures for hazardous workplace activities • Communicating with sub-contractors, suppliers etc., the requirement to work in a safe manner, with safe

equipment and in compliance with applicable laws and regulations and in accordance with corporate and/or client safety policies

• Provide ongoing safety education and training SUPERVISORS: Responsibilities include, but are not limited to:

• Ensuring worker orientations are conducted as per company policy • Advising workers and others in the workplace of known hazards therein • Providing instruction on safe work practices and procedures • Initiating and participating in workplace safety discussions and meetings • Commending workers for good health, safety and environmental performance



WORKERS: Responsibilities include, but are not limited to:

• The prompt reporting to supervision, work related accidents, incidents, including near misses, injuries and or discomforts, equipment/property damage and hazards that have developed during work activity

• Participating in workplace safety discussions, meetings and training CRISIS COMMUNICATION: “Crisis”. The sudden or rapid development of an incident or situation where life, property and/or the environment is endangered or at serious risk. In the event of a crisis situation, communication responding to that event should be handled from a safe area, out of sight of the crisis scene and with a link to company senior management being established to keep them informed and up to date as to the status of the situation. Senior field staff or the facility manager should first communicate known circumstances of the crisis situation with those directly affected, including victims, fellow workers, families and with those indirectly affected such as other workplace parties and our own Board of Directors. A senior company spokesperson from the crisis site (the manager or supervisor) should prepare to meet with the media in a safe place away from the crisis location, within an hour or two of the event, to brief them with known factual information which can be provided at a future specified time and location. BUY-TIME STATEMENT: (EXAMPLE) My name is _________________________ and I am a ________________________ with Sullivan. This _____________________________ has just happened and I am not prepared to answer any questions at this time. I will do my best to gather factual information that someone will share what they can with you at _________ o’clock, this _____________________________. Please remain or return to this location so that we can continue to investigate and report back to you. When the information about the crisis situation has been gathered and verified, the statement being released to the media shall be made by the company president or a member of the Senior Management Team after consultation with legal counsel if possible. INJURY STATEMENT: (EXAMPLE) (NEVER RELEASE THE NAME OF INDIVIDUAL)



A _________________________, age _______ years, was injured today. He/She was taken for treatment and care, however, the extent of the injuries has not been verified at this time. We are co-operating fully in the investigation to find out how this happened so that we can establish controls to prevent this from happening in the future. FATALITY STATEMENT: (EXAMPLE) (NEVER RELEASE THE NAME OF INDIVIDUAL) We are deeply saddened to report that _________________________ has died as the result of an incident that occurred at ___________________________. He/She suffered injuries as a result of______________. Our deepest sympathy goes out to family, friends and fellow workers for who we will provide any assistance we can. GUIDELINES FOR RESPONSE TO MEDIA QUESTIONS:

• Only one spokesperson (President/Senior Management Team Member) responses to media questions • Never reveal victim name(s) • Never reveal the location where the victim was taken • Limit responses to the details that you know the media is aware of • If you don’t know the answer to a question “say so”. Don’t make up an answer



WORKPLACE SAFETY AND COMPLIANCE INSPECTION

POLICY



WORKPLACE SAFETY AND COMPLIANCE INSPECTION POLICY PURPOSE: The purpose of this procedure is to establish a standard for workplace inspections. Inspections are intended to identify safe and unsafe work practices and workplace conditions, situations that could cause or contribute to accidents and loss. Inspections are one of the tools used to evaluate compliance, and the effectiveness of our safety program. PROCEDURE: Informal inspections shall be conducted by management/supervisory personnel as part of their daily role activities. Conditions requiring correction shall be actuated as soon as possible through contact with workers or a supervisor. A corrective direction must be followed up to ensure appropriate action is taken. Manager/supervisors have a responsibility to investigate reported unsafe conditions in their workplace and if found, delegate the corrective action to be taken. Formal inspections of their workplace must be carried out by supervisors or their designate once a week. Formal inspections by safety personnel shall be conducted monthly, as a minimum, in work places, material storage units and lay down areas. Worker health and safety representatives shall participate in the inspection criteria and:

• Review the previous inspection report • Identify outstanding items and reassign if necessary

As part of the inspection process:

• Document inspection team attendance, date, time and location of work place inspected • Document good observations and deficiencies. Have imminent danger and high risk hazards corrected

immediately • Complete a report and stipulate corrective action responsibilities, and • Request a report back from assigned personnel that corrective actions have been taken

TRAINING: This policy will be communicated to employees through safety meetings/talks.



REPAIRED TOOLS/EQUIPMENT: Green tags to be attached to repaired tools or small equipment and tools or equipment examined and found to be in good condition. A sample good to go green tag is attached. (see page 132) MAINTENANCE OF VEHICLES/EQUIPMENT: Vehicles and equipment such as trucks, forklifts, personnel hoists, cranes, etc. will be maintained and repaired in accordance with the manufacturers specifications, or if required, those of a professional engineer. Every replacement part for a vehicle, machine, tool or equipment shall have the same safety factor as the part it is replacing. All vehicles, machines, tools or equipment rated at greater than 10 horsepower, shall be equipped with the manufacturers operator manuals. The equipment manager/supervisor shall be responsible for establishing a schedule and maintaining documentation to ensure compliance. COMMERCIAL VEHICLE MAINTENANCE: The purpose of this standard is to establish a procedure to inspect, maintain and repair commercial vehicles owned or leased by Sullivan. Records shall be kept for each commercial vehicle that indicates the following:

• The make, year, V.I.N., license and fleet number • The type and date of every repair or maintenance activity • The odometer reading at the time of the repair or maintenance activity • The type of inspection and maintenance being performed, (Q) quarterly and (A) annually • A record of any suspension modification that affects the gross vehicle or axle weight rating • The required information must be assembled and kept current for each vehicle • The vehicle records must be kept for two years in the company garage office • If a vehicle is sold, destroyed or returned to its lesser, the records for that vehicle may be discarded after

six months SERVICING SCHEDULES: QUARTERLY (Q SERVICE):


ANNUAL SAFETY CERTIFICATION INSPECTION (A SERVICE) • As per inspection worksheet • Repairs to be recorded on a work order



PREVENTATIVE MAINTENANCE PURPOSE: The purpose of this procedure is to identify a minimum standard for inspection of tools, equipment and vehicles used by Sullivan employees. It also includes a tagging system for the identification of damaged or defective tools, as well as repaired tools and tools and equipment in good operating condition. This procedure is not intended to replace the responsibility of users to inspect tools/equipment and vehicles for defects before use, and to remove defective items from service. SCOPE: This procedure applies to:

• Fall arrest equipment such as harnesses, lanyards, lifelines, horizontal cable lines and rope grabs • Rigging such as slings, hooks, shackles, come-alongs, chainfalls, hydraulic and mechanical jacks • Electrical equipment such as cords, electrical tools and GFI’s • Chainsaws • Ladders • Compacting equipment • Scaffolding • Vehicles and equipment, and • Small tools, quick cut saws, air chisels, jack hammers, skill saws and table saws etc. • Measuring equipment, lasers and levels, etc., and • Company facilities, offices, storage facilities, repair garages

POLICY: INSPECTIONS: Inspection of tools/equipment will be by competent personnel whose trade or experience has given them knowledge of the tool or equipment being inspected. Scaffolding designed by a professional engineer shall be inspected by him/her before it is used to ensure that it is erected in accordance with the design drawings. If defects are found, scaffolding will not be used until fixed/replaced.



DEFECTIVE TOOLS/EQUIPMENT: Defective tools requiring repairs should be tagged defective, with a red tag. Users should note defects or required repairs on the red tag as specifically as possible. Tools/equipment that cannot be repaired to perform in the intended manner shall be removed from service. A sample of the defect tag is attached. (see page 132) REPAIRED TOOLS/EQUIPMENT: Green tags to be attached to repaired tools or small equipment and tools or equipment examined and found to be in good condition. A sample of good to go green tag is attached. (see page 132) MAINTENANCE OF VEHICLES/EQUIPMENT: Vehicles and equipment such as trucks, forklifts, personnel hoists, cranes, etc. will be maintained and repaired in accordance with the manufacturers specifications, or if required those of a professional engineer. Every replacement part for a vehicle, machine, tool or equipment shall have the same safety factor as the part it is replacing. All machine vehicles, machines, tools and equipment rated at greater than 10 horsepower shall be equipped with the manufacturer’s operator manuals. The equipment and manager/supervisor shall be responsible for establishing a schedule and maintaining documentation to ensure compliance. COMMERCIAL VEHICLE MAINTENANCE: The purpose of this standard is to establish a procedure to inspect, maintain and repair commercial vehicles owned or leased by Sullivan. Records shall be kept for each commercial vehicle that indicates the following:

• The make, year, V.I.N., license and fleet number • The type and date of every repair or maintenance activity • The odometer reading at the time of the repair or maintenance activity • The type of inspection and maintenance being performed, (Q) quarterly and (A) annually • A record of any suspension modification that affects the gross vehicle or axle weight rating • The required information must be assembled and kept current for each vehicle • The vehicle records must be kept for two years in the Company garage office • If a vehicle is sold, destroyed or returned to its lesser, the records for that vehicle may be discarded after

six months



SERVICE SCHEDULES: QUARTERLY (Q SERVICE):


ANNUAL SAFETY CERTIFICATION INSPECTION (A SERVICE)




TRIP INSPECTIONS/COMMERCIAL MOTOR VEHICLES: APPLICATION: This directive applies to the following Sullivan commercial motor vehicles:

1. Trucks and truck tractors with registered gross weights over 4,500 kg (9,920 lb.), 2. Trucks and truck tractors with an actual weight of over 4,500 kg. Actual weight means the weight of the

truck or truck tractor only, which may include any weight transferred to it by an attached trailer, and 3. Buses. Bus means a motor vehicle designed for carrying ten or more passengers, excluding the driver,

and used for the transportation of persons. Note: The weight transmitted to the road by the axle(s) of an attached trailer does not have to be added to the RGW of the truck if the transmitted weight is 2,800 kilograms (6,172 lb.) or less. IN THIS DIRECTIVE: “Operator” means the person directly or indirectly responsible for the operation of a commercial motor vehicle including the conduct of the driver and the carriage of goods or passengers, if any, in the vehicle or combination of vehicles. REQUIREMENTS: No person shall drive a commercial motor vehicle unless the person has inspected or caused to be inspected the commercial vehicle within the previous 24 hours. Highway Traffic Act of Ontario. OUTSIDE INSPECTION:

1. All lights and reflectors (equipped and functioning as required under the Act and the regulations). 2. Wheels and fasteners (for the wheel or rim cracks, defective lock rings, loose fasteners). 3. Tires (for tread depth, flat or noticeable leak, any visible bumps or bulges, mixture of bias and radial tires

on same axle, contact with any part of the vehicle or any other tire). 4. Fuel system (for a visible leak at any point, tank filler caps shall not be missing, fuel tank shall be securely

mounted). 5. Exhaust system (for audible leaks, missing or loose components, and secure mountings). 6. Fifth wheel (for loose, missing or ineffective fasteners, missing, broken or deformed parts in the locking

mechanism, operating handle being in closed or locked position when in use). 7. Suspension, spring, air bags, and controlling attachments (for any cracked, broken, loose or missing axle

positioning or fastening parts, broken or missing spring leaves, broken coil springs, deflated air suspension due to system failure).

8. Towing and coupling devices as required under the Act and the regulations (for missing or unattached safety devices, or safety devices not capable of secure attachment, wear kinks or broken cable strands, improper repairs).



9. Load security: The following conditions must exist before a driver can operate a commercial motor vehicle: a. The vehicle cargo must be properly distributed and adequately secured.

b. Make sure that all secured equipment and vehicle structures are in good working order and used

consistently with their capability. c. Stow vehicle equipment. d. Make sure that nothing obscures front and side views or interferes with the ability to drive the vehicle

or respond in an emergency. The driver must complete periodic inspections during transit. 10. Load covering (for compliance with the requirement of Regulation 577 of Revised Regulations of Ontario,

1990). 11. Air brake adjustment and connections (for absence of braking action on each wheel, missing, broken or

loose mechanical components readily visible, audible air leaks and brake readjustment limits). 12. Hydraulic brake fluid (for visible leakage). 13. Mirrors as required for condition and adjustments.

INSIDE INSPECTION:

1. Steering wheel, excessive play, looseness. 2. Brake pedal reserve and fade. 3. Brake booster operation. 4. Brake failure warning light functions as intended. 5. Brake air pressure or vacuum gauge. 6. Warning signal, low pressure or low vacuum. 7. Windshield washer and wipers function as intended. 8. Windshield and windows are to afford the driver a clear view. 9. Mirrors, adjustment and condition. 10. Defroster and heaters function as intended. 11. Horn functions as intended. 12. Driver’s seat belt and seat security function as intended. 13. Parking brake adequate to hold vehicle. 14. Emergency equipment as required under any Act and the regulations made there under for that class of

vehicle. DOCUMENTATION: Upon completion of an inspection the person carrying out the inspection shall record on an inspection report:

• The motor vehicle make; • The number plate or unit number of the truck, bus or tractor; • The number plate or unit numbers of any trailer towed by the truck, bus or tractor; • The date and time of the inspection; • The name and signature of the person who carried out the inspection; and • Any safety defects of the items referred to disclosed by the inspection.



If no safety defects are disclosed by the inspection, the person who carries out the inspection shall record that fact on the inspection report. Every driver of a commercial motor vehicle shall, when he or she finishes driving the vehicle in a 24-hour period commencing with the inspection required, record on the inspection report any safety defects of the items referred to, he or she observed while driving or while otherwise in charge of the vehicle. Every driver shall forward the inspection report to the operator that is responsible for the commercial motor vehicle as soon as possible after the inspection report is completed. An inspection report is completed

(a) If no safety defects of the items referred to are disclosed, at the end of the 24-hour period, (b) If a safety defect of any item referred to is disclosed, after a person who undertakes to repair the safety

defect completes the entries required. Every person who undertakes to repair a safety defect recorded in an inspection report shall record on the inspection report the date on which the repair is completed or the fact that no repair is required and shall sign each entry made by him or her on the report. TRAINING: Training will be provided to the appropriate people on an ongoing basis.



FACILITIES MANAGEMENT PURPOSE:

The management of Sullivan have developed a policy, outlining responsibilities for the care and maintenance of the properties under his control.

Property care would include but is not limited to: • Ensuring floors, aisles and walkways are kept free of slip and trip hazards • Ensuring stairs are maintained in a good condition and free of clutter • Ensuring facilities are kept clean and orderly including washrooms, kitchen and eating areas • Ensuring adequate lighting is provided both indoors and outdoors • Ensuring that materials are stacked, shelved and stored so as not to create a hazard by tripping or falling • Ensuring that hazardous chemical spills are contained and cleaned up by personnel, trained, equipped

to handle and safely dispose of the material Property maintenance would include, but is not limited to: • The cleaning of snow from parking lots, yards, walkways, doorways and driveways in an appropriate time

frame • Ensuring that outdoor walks, paths, driveways, parking lots and facility entrances are treated with a

sand/salt mixture sufficient to minimize the risk of a slip and fall incident • Ensuring that snow and ice accumulating on a roof is removed or protection is in place to warn of the

hazard, should it slide form the roof • Ensuring that parking lots adjacent to the facility are maintained in good condition • Ensuring that alarm systems are tried and tested at least annually • Ensuring that fire suppression equipment is inspected and certified annually • Ensuring that all alarm systems are tested at least annually or as per the manufacturers specifications • Ensuring that roof top units are inspected as per the manufacturers specifications and that access walks

and travel restraint anchor points are inspected annually • Ensuring that all lifting equipment is inspected at least annually, or as per manufacturers specifications,

including vehicle hoists, chain falls and lifting jacks • Ensuring that all personnel lifts are inspected at least annually or as per the manufacturers specifications • Ensuring that electrical installations and components are protected and maintained in good condition

with gfci protection where required • Ensuring that doors are maintained in a good operating condition, with clear pathways to allow for

emergency exit and that emergency exit lighting is illuminated • Ensuring that emergency lighting is functional and adequate where deemed necessary • Ensuring that window cleaning operations are carried out in a safe and compliant manner and • Ensuring that all equipment guards are maintained and in good working order.

Records of all repairs, testing and inspections will be maintained by the facility manager/supervisor, with copies being forwarded to the corporate Safety Officer.

COMMUNICATION:

This policy will be reviewed with appropriate personnel during a safety meeting.



ACCIDENT/INCIDENT INVESTIGATION AND

REPORTING



ACCIDENT/INCIDENT/NEAR MISS/INVESTIGATIONS AND REPORTING PURPOSE: To develop a policy for the reporting of accidents, incidents and near miss occurrences at Sullivan workplaces. DEFINITIONS: Accident: an undesirable or unfortunate happening that occurs unintentionally and usually results in harm, injury, casualty, damage or loss. Incident: an unwanted event which, in different circumstances, could have resulted in harm to people, damage to property or loss to a process, including legislated and client requirements. Near Miss: an unplanned event that threatens human safety or health, the environment, or the continued normal operation of the business. ACCIDENT COSTS: All accidents, incidents and near misses are costly to the company whether accompanied by loss or not. This is evidence by:

• Damaged equipment • Slow down or stoppage in production; and • Increased compensation payments

POLICY: All accidents, incidents and near miss occurrences must be investigated to determine their cause so that corrective action can be implemented to prevent a recurrence. All employees, including subcontractor employees, are to be trained during “orientation” that they must report all accidents, incidents and near miss occurrences to the workplace manager/supervisor. Managers/Supervisors shall ensure that all accidents, incidents and near miss occurrences in our workplaces, including those involving subcontractor employees, are reported to the company Safety Officer or to the Arnprior office for the attention of a company Safety Officer, with sufficient detail as to identify the seriousness thereof. All accidents, incidents and near miss occurrences, including those involving subcontractors, occurring on client premises, shall be reported to the hiring client, by the workplace manager/supervisor. All accidents involving company owned vehicles or equipment must be reported to the company Safety Officer or the Arnprior Office, for the attention of a company Safety Officer, at the first reasonable opportunity, so that prompt attention can be given to the matter.



The following incidents shall be promptly reported to the company Safety Officer or to the Arnprior Office for the attention of a company Safety Officer.

• A worker falling a vertical distance of three metres or more • A worker falling and having the fall arrested by a fall arrest system other than a fall restricting system • A worker becoming unconscious for any reason • Accidental contact by a worker or by a worker’s tool or equipment with a live electrical conductor or live

electrical equipment • Accidental contact by a crane, or similar hosting device, backhoe, power shovel or other vehicle or

equipment or its load, with an energized electrical conductor rated more than 750 volts • Structural failure of all or part of falsework designed by, or required by this regulation to be designed by,

a professional engineer • Structural failure of a principle supporting member, including column, beam, wall or truss, of a structure • Failure of all or part of the structural supports of a scaffold • Structural failure of all or part of an earth or water-retaining structure, including a failure of the

temporary or permanent supports for a shaft, tunnel, caisson, cofferdam or trench • Failure of a wall of an excavation or of similar earthwork with respect to which a professional engineer

has given a written opinion that the stability of the wall is such that no worker will be endangered by it • Overturning or the structural failure of all or part of a crane or similar hoisting device

ACCIDENT/INCIDENT INVESTIGATIONS: All accident, incident and near miss occurrences shall be investigated to determine the root cause thereof and corrective action(s) to be taken to prevent a recurrence. A company Safety Officer, trained in accident investigation, shall participate in investigations, when possible. The investigation results shall be documented with reports being forwarded to Sullivan senior management, the client, and if legislated, to the Ministry of Labour, the WSIB, the workplace safety personnel. Investigations are to be carried out by personnel trained in accident investigation. CRITICALLY INJURED: Means an injury of a serious nature that:

• Places life in jeopardy • Produces unconsciousness • Results in a substantial loss of blood • Involves the fracture of a leg, arm, hand or foot, but not a finger or toe • Involves the amputation of a leg, arm, hand or foot, but not a finger or toe • Consists of burns to a major portion of the body, or • Causes the loss of sight to an eye



WHERE A PERSON IS KILLED OR CRITICALLY INJURED FROM ANY CAUSE AT A WORK PLACE, THE CONSTRUCTOR, IF ANY, AND THE EMPLOYER, SHALL NOTIFY THE MINISTRY OF LABOUR IMMEDIATELY OF THE OCCURRENCE BY TELEPHONE OR OTHER DIRECT MEANS. A CRITICAL INJURY ACCIDENT SCENE SHALL NOT BE DISTURBED, EXCEPT FOR THE PURPOSE OF CARRYING OUT LIFE-SAVING PROCEDURES. NOTE: If there is any doubt as to the seriousness of an injury, treat it as critical and preserve the scene. Work at a critical injury accident scene may only be resumed when authorization has been given by an inspector of the Ministry of Labour. In the case of a “Near Miss” incident, the company Safety Officer may visit the location to propose changes to prevent further incidents or may make recommendations through a form of communication. TRAINING: This policy will be communicated to employees through safety meetings/talks.



EMERGENCY RESPONSE

PROCEDURE



EMERGENCY RESPONSE POLICY PURPOSE:

The objective of this plan is to ensure that the emergency procedures that are in place are sufficient to respond to an emergency in an accurate, timely consistent and dependable manner. RECOGNITION: An emergency is any situation that has the potential to affect the life, health and safety of people, or to have a detrimental effect to property or the environment. POLICY: Every workplace Manager/Supervisor /Worker Rep and or JHSC will develop an Emergency Response Plan specific to his/her workplace with major access routes identified for emergency vehicles. The plan shall contain the following information and be posted by the First Aid Kit and workplace phone (if present):

• The civic address of the workplace or a physical description of the location • Traffic plan/Emergency Entrance/Exits • Location of First Aid Kit(s) • Location of storage and parking areas • Location of fire hydrants (if present) • Location of fire extinguishers • Location of overhead power lines (if present) • Location of in ground utilities if and when a survey is completed • Identity of streets and names adjacent to the workplace • Location of the Designated Emergency Assembly area • Post an “EMERGENCY RESPONSE POSTER” with a map indicating the route to the nearest hospital; and • The emergency numbers of first responders, Ambulance, Fire and Police as well as utilities hydro,

communication(s), natural gas and the Ministry of Labour office • Type and location of the alarm component (air horn, siren, etc.)

In all emergency or suspected emergency situations the person in charge of the workplace must be notified immediately. ACTION: The person in charge of the workplace shall assess the situation and take command:

• Protecting against known or potential hazards • Ensuring care is provided to those in need; and • Initiating a call to emergency services



Access to this site for emergency response agencies should be from: (name of highway, street, avenue, etc.) Individuals should be assigned to maintain a path for emergency response vehicles and to meet direct and assist them on their arrival at the workplace. A source of transportation to a medical facility will be made available on request. In the event of fire, explosion or collapse, survivors or lead hands shall promptly conduct, or have conducted, a head count of their onsite personnel, including visitors, and report accordingly to the workplace manager/supervisor, lead hand. Sub-contractor supervisors/lead hands must also promptly conduct a head count of their onsite employees and report their findings to the workplace manager/supervisor, lead hand. The company head office in Arnprior, Ontario shall be notified as soon as possible about the emergency by some form of reliable communication. TRAINING: This policy will be communicated to employees through safety meetings/talks.



FIRE PROTECTION PLAN PURPOSE: Sullivan values its employees, their health and safety, as well as company assets, including buildings and equipment, etc. The risk and cost of fire can be extremely high in economic and human terms and accordingly a fire protection plan has been developed as a guideline for all managers and supervisors to follow. POLICY: The company will initiate and implement, monitor and verify that all management, supervisory and employee personnel are aware of the fire protection plan developed for their workplace. New workers will receive training regarding the fire protection plan at the time of his/her orientation. The posted plan will include exit routes, the location of fire extinguishing equipment and first aid kits. Construction projects will have fire extinguishers whose contents are discharged under pressure and shall have an Underwriters Laboratories of Canada 4A40BC rating. O.Reg. 213/91, sections 52-58. Every fire extinguisher shall be inspected for defects or deterioration at least once a month by a competent person who shall record the date of the inspection on a tag attached to it. After a fire extinguisher is used, it shall be refilled or replaced immediately. Before hot work is performed, employees must check for fire hazards such as but not limited to: wooden forms, scrap lumber, packing materials, cardboard and paper, flammable liquids and oily rags. Gasoline, oil, grease and other flammable materials must be stored in safe locations, clear of work areas and not in any building or location where workers are likely to gather. “NO SMOKING” and “FLAMMABLE MATERIALS” signs should be posted outside the storage area. Gasoline and other flammables should be transported in closed metal containers with flame arrestors. Safety cans with spring loaded caps. All fire prevention regulations established by customers and site owners must be observed. Employees must report fire damage to company property and or equipment to their supervisor/manager. Employees will be trained in the use of fire extinguishing equipment and specifically in the use of fire extinguishers using the acronym “PASS.”

• P (pull the pin) • A (aim the discharge hose at the base of the fire) • S (squeeze the handle) • S (spray the contents of the extinguisher from side to side at the base of the fire)



If an employee decides to try to extinguish a small fire, he/she shall establish his/her evacuation route and never allow the fire to spread to an area between them and their evacuation point. If in doubt as the magnitude of the fire, leave the area promptly and notify the supervisor/manager. EVACUATION PLAN: An evacuation plan will be designed for each workplace to assist all employees and visitors to leave the work location in the case of an emergency. The supervisor/manager shall develop for his/her workplace, a method of implementing an alarm, that will alert people of the need to evacuate the area and gather at a pre-determined “muster point” for a head count. Should it be determined that someone is missing, no one should go back into the evacuated area. Await the arrival of emergency personnel, alert them that someone is missing and offer assistance that may help to locate the individual. COMMUNICATION: This policy will be communicated to employees through safety meetings/talks and during Orientation.



POWER LINE CONTACT POLICY

- Operator to stay in/on equipment - Keep everyone away from equipment in contact with power line. This includes buckets, load, load line,

slings and outriggers etc. - If possible, operator should break contact by moving the equipment clear of power line - Never touch equipment and ground at the same time - Get someone to call local utility to shut off power - Beware of time relays. Even after breakers are tripped by line damage, relays may be triggered to restore

power - Do not move the machine until the utilities have the power shut off and have confirmed that the power

is off - If an emergency such as a fire forces you to leave the machine, JUMP CLEAR, NEVER STEP DOWN. If part

of your body contacts the ground while another part touches the machine, electric current will travel through you

- JUMP WITH FEET TOGETHER AND SHUFFLE AWAY – HEEL-TO-TOE. Do not take big steps. With voltage differential across the ground, one foot may be in higher voltage area than the other. The difference can kill you

- Report contact to utility and ESA. Contact may have weakened conductor causing it to fall later - Issue a report to local MOL within 2 days



SAFETY STATISTICS AND

RECORDS



SAFETY STATISTICS AND RECORDS

PURPOSE: To identify trends in safety performance and identify goals to improve health and safety within the Sullivan Company. POLICY: The corporate safety officer will prepare monthly reports, reporting on the number and category of incidents, the number and type of injuries, the category of aid provided and the status as to modified work, no lost time, lost time, for all incidents, injury occurrences on Sullivan workplaces. The reports will be forwarded to and reviewed with senior management at the beginning of the new month. Corrective actions will be developed and implemented for trends deemed to be unacceptable. An annual report summarizing the number of incidents and injuries for the year will be prepared in January of the New Year and reviewed with senior management. This report will compare the health and safety performance of the company for, at least, the past two years. Construction industry statistics should also be studied to identify trends in health and safety. COMMUNICATION: This policy will be reviewed with senior management during a meeting.



279,717 233,703

293,244 329,328 324,861

2013 2014 2015 2016 2017

Total Manhours Worked

0 0 0 0 0

2013 2014 2015 2016 2017

MOL Violations

1713

8 1053 2 3 3 2

2013 2014 2015 2016 2017

Number of Medical Aids and First Aids

Medical Aids First Aids

0.56 0.72

1.4

0.6

2013 2014 2015 2016 2017

Lost Time Frequency Rate

13.6

5.1

12.27

0

2013 2014 2015 2016 2017

Lost Time Severity Rate



0.444

0.806

0.618

0.131

-0.2012013 2014 2015 2016 2017

wsib CAD- Firm Performance Index



LEGISLATION



LEGISLATION PURPOSE: The management and staff of Sullivan is committed to planning and conducting all work is the safest possible manner while adhering to all relevant Acts and Regulations pertinent to our operations. Acts & Regulations The following list identifies, but is not limited to the Acts and Regulations that govern M. Sullivan & Son operations. Occupational H&S Act- 213/91 First Aid Regulation – 1101 WHIMS 2015 Regulation-860 Designated Substances Regulation 490/09 Confined Space Entry Regulation 32/05 Industrial Regulation 851 POLICY: Managers/supervisors will be responsible for ensuring that the following are posted or available, in a conspicuous location, in their workplace. Items include but are not limited to:

• The Occupational Health and Safety Act of Ontario • Ontario Regulations relevant to the workplace, (e.g. Construction Projects, 213/91, Industrial

Establishments, 851/90, Asbestos on Construction Projects, 278/05 and Workplace Hazardous Materials Information System, 860/90 etc.)

• Health & Safety at Work poster • Ontario Regulation 1101, First Aid • WSIB Poster from 82 • Safety Representative, Safety Committee names(s) • MSDS for controlled products present in the workplace • The address and telephone number of the nearest Ministry of Labour Office • Ministry of Labour reports, directives, etc.

Additional for construction projects:

• Name, address and telephone number of constructor • Name of supervisor • Notice of Project • Registration of Contractors/Employers (Form 1000) • Project inspection reports; and



• Safety meeting minutes All employees must have “Health and Safety Awareness Training and “Workplace Hazardous Materials Information System”. COMMUNICATION: This policy will be communicated to employees through safety meetings/talks.



OCCUPATIONAL

HEALTH



OCCUPATIONAL HEALTH PURPOSE: The management of Sullivan in the interest of occupational health, has developed a policy to inform employees of health hazards associated with some of the tasks they perform. POLICY: Managers and supervisors are responsible to ensure that employees are aware of hazards associated with tasks being assigned, including immediate and long term health effects. The following is a list of some of the known hazards, but is not limited to these: Workers are not to be exposed to any harmful substance that exceeds the Occupational Exposure limits.

Materials/Tasks Hazard Major Diseases Controls Sprayed on fireproofing, pipe and boiler insulation, asbestos cement products, vinyl tiles, drywall joint filling compounds and drywall/plaster.

Asbestos, dust, fibres. Type 1 only removal permitted.

Mesothelioma, lung cancer, asbestosis

Respirators, enclosures, heap vacuums

Extreme Cold Temperatures

Hypothermia Frost bite, pneumonia

Dress in layers, drink plenty of warm fluids, frequent sheltered breaks

Extreme Hot Temperatures

Becoming disoriented, fainting

Heat stroke, exhaustion and stress

Wear light loose fitting clothing, drink plenty of cool fluids (water), follow the guidelines on the Humidex Based Heat Response Plan

Diesel, gasoline or propane powered engines in enclosed spaces or deep excavations

Exhaust fumes, carbon monoxide

Drowsiness, unconsciousness, may increase risk of lung cancer

Ventilation, pipe exhaust to outdoors, use exhaust scrubbers

Heavy equipment, explosive actuated

Noise Noise induced hear loss, Tinnitus

Engineering controls to reduce noise, use



tools, chainsaws, grinders, chipping tools, jack hammers and general work environment

of noise reduction equipment, use of hearing protection components adequate to reduce noise level

Vibration White finger disease, soft tissue injury

Equipment maintained with anti-vibration components, tool handles equipped with shock absorbing materials, frequent rest periods or trade-offs, use of anti-vibration gloves

Drilling, cutting grinding, chipping, shoveling, sweeping, such as sand, gravel and concrete

Silica Silicosis, lung cancer Where a dust hazard is created, exposed workers must wear respiratory protection, wash and cleanup facilities should be used before eating

Working with wet cement, concrete, hardeners, paints and solvents

Various chemicals Dermatitis, allergic or reaction to chemicals that tough the skin

Review the MSDS data for the product being used, follow instruction on use of PPE

Welding and flame cutting

Metal fumes and gases

Irritation to the eyes, nose and throat, nervous system effects, cancer

Proper PPE and exhaust hood.

Removal or burning of lead based paints, coatings or anywhere lead was used

Lead Nervous system effects. Impaired male reproduction, impaired pregnancy

Use respiratory equipment, use clean suits, wash before eating or smoking



SILICA – SAFE WORK PROCEDURES PURPOSE: Sullivan , in the interest of health and safety of its employees and the public, have developed a policy outlining safe work procedures for the control silica dust in its work places. Silica dust and particles are generating from:

• Cutting, chipping, grinding and drilling concrete and rock • Sandblasting concrete • Cutting, chipping, grinding and drill masonry products • Crushing, hauling and dumping stone aggregate • Milling asphalt containing stone; and • Charging mixers and hoppers with sand, having a 95 per cent or more, silica content

The prolonged inhalation of respirable dust containing crystalline silica my result in silicosis, a disease characterized by progressive “fibrosis” (excess fibrous tissue or scar tissue) of the lungs. Workers must not be exposed to more than 0.05 milligrams per cubic metre of air by volume of respirable crystalline silica dust, during an eight hour day or forty hour weekly time-weighted average limit. The average concentrations silica dust, to which a work is exposed, shall be determined from the analysis of air samples taken in the immediate area of the dust source during work operations. CONTROLS: Three basic ways to control silica dust, include:

• Prevent silica dust form getting in the air • Remove silica dust from the air; and • Prevent workers from inhaling silica dust

POLICY: During the cutting, grinding or drilling operation, if safe to do so, wet the area that is being worked on continuously with water to suppress the dust. If water cannot be used to suppress the dust, if possible, select equipment with a vacuum attachment that will collect the dust. An N95 filtering face piece respirator is only appropriate for short – duration tasks when local exhaust ventilation is available, or a “HEPA vacuum” system is available on the tools.



A full-face piece air-purifying respirator equipped with a 100 series particulate filter, properly fitted shall be worn by all workers exposed to a dust suspect of containing silica particles in a concentration greater than 0.05 milligrams in a cubic metre of air. A properly fitted hood with a fresh breathing air supply system may also be used, to protect workers, during sandblasting operations. The manufacturer’s instruction in the general use, care and maintenance of respirators must be followed whenever they are required. Whenever possible, operate vehicles and equipment with pressurized cabs in dusty conditions, keeping windows and doors closed and air intake filters clean. In outdoor environments, set up the work area so that the wind blows from behind you and carries the dust cloud away from your breathing area. Notify other workers that the work will generate silica dust and suggest that they keep at least 10 metres away or use respiratory protection while the work is being carried out. Post signage warning of the hazard. Set up an enclosure around the cutting, grinding and blasting operations if unable to prevent the spread of dust to other workers or the public who are not protected. After finishing the cutting, grinding, drilling or blasting operation, remove the dust from the tools, equipment and clothing with a damp cloth or vacuum equipped with a HEPA filter. Clean the work area to prevent the buildup of silica by wet sweeping or the use of a HEPA vacuum. Never use compressed air to blow the dust away or clean the dust from your clothing. Wash your hands and face with soap and water before smoking, eating, drinking or chewing in an uncontaminated are.



TRAINING: Workers will receive training on the hazards of silica exposure, chronic, accelerated and acute, the methods to be implemented to minimize or eliminate the risk, through a safety meeting or talk presentation. MEDICAL SURVEILLANCE PROGRAM: Sullivan employees exposed to air borne silica dust on a regular basis, will be requested to participate in a medical surveillance program. The objective of the program is to protect the health of employees by:

• Ensuring their fitness for exposure to silica • Evaluating their absorption of silica • Enabling remedial action to be taken when necessary; and • Providing health education

The medical surveillance program will include pre-employment and pre-placement medical examinations, periodic medical examinations and clinical tests, health education and record keeping.



FIRST AID/MEDICAL AID



FIRST AID PURPOSE: The Workplace Safety & Insurance Board, Regulation 1101, requires that workplaces have first aid equipment and trained personnel present. Prompt and correct treatment of injuries both on and off the job, can not only reduce pain and suffering but save lives as well. POLICY: Should an injury occur at a Sullivan work location, it is essential that First Aid be administered immediately, followed by proper medical treatment, if necessary. All workplace managers/supervisors shall be trained in First Aid and CRP and re-certified as required by Regulation. A minimum of one additional person in each workplace should be trained in First Aid and CPR and be re-certified as required by Regulation. A copy of the workplace First Aider’s certificate must be posted in the workplace, preferably next to where the First Aid Kit is located. Service vehicles must contain a First Aid Kit of the size and contents as required by Regulation 1101 and drivers should be familiar with its location on the vehicle. A record of first aid treatment, including: the persons’ name, date, time treatment rendered and the name of the person providing the treatment, shall be documented for all workplace injuries and illnesses and retained on file with the company. First Aid Kits should be inspected as to their condition and contents on being introduced to the workplace, and at not less than quarterly intervals thereafter, with the inspection card being dated and initialed by the person completing the inspection. Every workplace will be equipped with a proper eye wash station as well as an adequate washing facility. The WSIB Form 82 shall be posted in a workplace. COMMUNICATION & TRAINING: This policy will be reviewed with employees at safety meeting/talks and training provided as needed.



HEALTH & SAFETY REPRESENTATIVES

AND COMMITTEES



HEALTH & SAFETY REPRESENTATIVE(S) PURPOSE: This policy is developed to assist Sullivan in complying with the Occupational Health & Safety Act, regarding health and safety representatives in workplaces. POLICY: Where the number of workers in a workplace regularly exceeds five, the manager/supervisor shall cause the workers to select a worker safety representative from amount the workers at the workplace who do not exercise managerial functions. The Health and Safety Representative should:

• Have a current First Aid certificate • Have a working knowledge of the Occupational Health and Safety Act of Ontario and its regulations, as

well as the WHMIS regulation and corporate Health & Safety Manual; and • Have health & safety related training

The Health and Safety representative should perform or participate in monthly workplace inspections, participate in investigating and reporting on, workplace accidents, incidents and near miss occurrences, help to meditate disputes about unsafe conditions and confer with workers, supervisors and Ministry of Labour Inspectors whenever necessary. Unsafe situations requiring prompt corrective action must be reported to the workplace manager/supervisor immediately. Where twenty or more workers regularly work in a workplace, a Joint Health & Safety Committee consisting of at least two people, shall be formed. One committee member shall be selected by management and the other committee member selected by the workers. Where fifty or more workers are regularly employed in a work place, a Joint Health & Safety Committee consisting of at least four persons, shall be formed. Two committee members shall be from management and two committee members selected from among the workers at the workplace.

• Where fifty or more workers are present in a workplace, the committee shall cause a Worker Trade Committee to be established, with a worker from each trade participating in the committee to discuss safety concerns or issues from the membership

Two members of the Worker Trade Committee are then selected to meet with the Joint Health & Safety Committee and bring forward the safety concerns or issues. Joint Health & Safety Committee meetings shall be co-chaired and have meeting minutes recorded and distributed to each trade in the workplace.



Joint Health & Safety Committee meetings shall be held at least every three months and on construction projects, they shall be held on a monthly basis. The name(s) of the safety representative or of the safety committee members shall be posted in a conspicuous location in the workplace. It is the function of a committee and it has the power:

• Identify situations that may be a danger or a hazard to workers • Make recommendations to the constructor/employer and the workers for the improvement of health

and safety workers • Recommend to the constructor/employer and workers, the establishment, maintenance and monitoring

of programs, measures and procedures, respecting the health and safety of workers • Obtain information from the constructor/employer respecting the identification of potential or existing

hazards of materials, processes or equipment and the health and safety experience, work practises and standards in similar or other industries of which the employer/constructor has knowledge

• Obtain information from the employer/constructor concerning the conducting or taking of tests of any equipment, machine, device, article, thing, material or biological, chemical or physical agent in or about a workplace for the purpose of occupational health and safety; and

• Be consulted about, and have a designated member representing workers be present at the beginning of testing in or about the workplace, if the designated member believes his/her presence is required to ensure that valid testing procedures are used or to ensure that the test results are valid

COMMUNICATION: This policy will be communicated to employees through safety meetings/talks. SAFETY OFFICER: The corporate Safety Officer’s duties will include, but not limited to:

• Responding to both accidents and incidents to investigate, complete and submit the necessary reports • Ordering and distributing of safety materials (glasses, gloves, hard hats and hearing protection,

respiratory protection, etc.) and other related safety material (posters, bulletins and policies, etc.) • Advising management on the progress of the Safety Program and completing statistical information on

injures, incidents, employment hours, etc. • Maintaining liaison with the Infrastructure Health & Safety Association of Ontario • TO network with agencies, organizations, employers and contractors in matters of safety compliance

and adopting “Best Practices” in our work procedures • Visiting workplaces, advising and assisting supervision in accident prevention procedures • Schedule training for employees and maintain training records



WORKPLACE VIOLENCE

AND HARASSMENT

POLICIES



ANTI-VIOLENCE/ANTI-HARASSMENT PROCEDURES PURPOSE: The management of Sullivan is committed to providing a safe working environment for personnel in its’ various workplaces. In pursuit of this goal, Sullivan will not condone or tolerate acts of violence or harassment against, or by people in the company.

DEFINITIONS:

1. Harassment is defined as any interaction between individuals that can be characterized as unwelcome, intimidation, bullying, violence or misconduct. Sullivan rejects and entirely disapproves of all harassment based on grounds of: race (i.e. colour, ethnicity, origin, nationality or decent), sex, marital status, age, sexual orientation, gender history, religious beliefs, political convictions, disability or medical condition. Such acts include:

• Inappropriate physical conduct • Creating an intimidating or offensive working environment; or • Creating a degrading, humiliating or hostile work environment

2. Violence is defined as any interaction or acts of aggression or hostility between individuals that involves

causing physical injury to another person and or the utterance of threatening remarks subjected another individual to emotional distress. Acts of violence may also include possessing a firearm or other weapons considered to be dangerous while in an Sullivan workplace, or while conducting Sullivan business. Carrying out acts of harassing surveillance (stalking, etc.) and or displaying irrational behavior.

3. Threats of violence or harassment are considered serious and will be treated accordingly. Threatening behaviour includes, but is not limited to:

• Throwing objects at another person • Verbally threatening harm to another person or his/her property • Making threatening or menacing gestures, and/or the escalation of unacceptable behavior in a

workplace



POLICY AND PROCEDURES: Each employee, including subcontractor employees, will be introduced to the Workplace Anti-Violence Policy and the Anti-Harassment Policy during their orientation. They will then initial the orientation forms after they have read them and to confirm they understand them. The policies will be posted in a conspicuous place in all company workplace offices. These policies prohibit physical or verbal threats (with or without the use of weapons) intimidation, or violence in the workplace to minimize risk of injury or harm. Weapons: The following items are considered to be weapons and are strictly prohibited in any Sullivan workplace:

• Firearms such as pistols, revolvers, shotguns and rifles, etc. • Knives not required in the performance of work • Explosives or explosive devices not required for work • Metal knuckles • Air guns, pellet guns, and blow guns, etc. • Any replica of the above items; and • Any other item that is gestured for use or is used to inflict injury on another individual

It is also a violation of the Sullivan Anti-Harassment and Anti-Violence Policies, for anyone to knowingly make a false complaint of harassment or violence, or to provide false information about a complaint. Sullivan employees are prohibited from engaging in any violent or harassing behavior towards others. Any physical, verbal or visual act, (with or without a weapon) that threatens, intimidates, creates fear, or has the purpose of interfering with an individual’s duties, is forbidden. Managers, supervisors with the assistance of Safety Personnel, will take action necessary to resolve any situation that involves harassment or violent behaviour. This includes, but is not limited to, calling 9-1-1 for police assistance if warranted. Incidents that constitute a suspected criminal act, shall be referred to the appropriate police service forthwith by the workplace supervisor.



Complainants are encouraged to file a complaint immediately following an alleged incident of harassment or violence, threatened or real. Individuals who believe that they have experienced harassment, violence or a threat of violence, should lodge a complaint to a supervisor at the first reasonable opportunity. Where a complaint is being made against a supervisor or manager, the complainant should make the complaint directly to the head office at Arnprior, Ontario for the attention of the corporate General Manager or President by telephoning (613) 623-6584 at their first reasonable opportunity. Sullivan pledges to assist employees, managers and supervisors in the investigation and documentation of alleged acts of harassment or violent behaviour. Individuals who violate this policy are subject to disciplinary and/or corrective action, from a written reprimand, to time off, or termination of employment. This policy encourages employees to freely express, in a reasonable and orderly fashion, their thoughts, opinions and feelings regarding harassment or violence complaints. In no case, shall any employee who reports threats or acts of violence, be retaliated against through disciplinary action. Acts of retaliation would include, but are not limited to, interference, coercion, threats, physical restraint and/or workload reassignments, etc. Acts of alleged retaliation must be reported to corporate senior management at the first reasonable opportunity. Should an employee be harassed or threatened by an individual from outside the workplace, and has reason to believe this person may harm them, the employee shall report the concern at the first reasonable opportunity to his or her supervisor. If other employees are working in proximity to the concerned employee, they should be made aware of the situation in confidence. If, as an employer, Sullivan becomes aware, or ought reasonably to be aware, that domestic violence that would likely expose a worker to physical injury that may occur in the workplace, take every precaution reasonable in the circumstances for the protection of the worker. If an employee is in possession of a legal court order (e.g. a restraining order, or a “no contact” order, etc.), against another person, the employee should advise his or her supervisor accordingly. Where the employee believes the person may attempt to contact him or her at work, the said employee should provide a copy of the court order to his or her supervisor for reference. The information on the court order shall be treated as confidential, however individuals working with or in the area of the court protected employee, must be made aware of the situation.



If any visitor to a Sullivan workplace is seen with a weapon making a verbal threat or committing an assault against an employee or another individual in the premises, witnesses are immediately required to call 9-1-1 and notify their immediate supervisor. Employer duties as set out in section 25, supervisor duties as set out in section 27 and worker duties as set out in section 28 of the Occupational Health and Safety Act of Ontario, apply as appropriate, with respect to workplace violence. All harassment and violence reports, along with subsequent investigation reports, will be classified as confidential and not disclosed, except as required by law. Sullivan will protect this privacy so long as doing so remains consistent with the enforcement of this policy and adherence to the law. This Anti-Harassment and Violence Policy must never be used to bring fraudulent or malicious complaints against employees. Any compliant made in bad faith, if demonstrated as such through investigation, will result in disciplinary action being taken against the individual lodging the fraudulent or malicious complaint. Disciplinary or corrective action may be taken, up to and including, suspension of duties or termination of employment, for any violation of this policy. Sullivan will conduct assessment risks of workplaces for violence and harassment concerns that may arise from the nature of the workplace, the type of work or the conditions of work. The assessment shall take into account, circumstances that would be common in similar workplaces and circumstances specific to the workplace. Re-assessment of violence/harassment risks will be conducted as often as is considered necessary to ensure that workers are protected by the existing policies. COMMUNICATION: This Policy and procedure will be communicated to employees during orientation, safety meetings and talks.



HARASSMENT/VIOLENCE INCIDENT REPORT FORM Date and Time of Incident:

am/pm

(day) (month) (year) Complainant:

Name:

Workplace:

Craft/Position:

Age:

Type of Incident: assault/physical injury/verbal abuse/threatening behavior/verbal threat/damage to personal or other property harassment/other:

Location of Incident:

Nature of activity at time of incident:

Offender(s):

(name) (name) (name) Male/Female Male/Female Male/Female

Description:



HARASSMENT/VIOLENCE INCIDENT REPORT FORM

Relationship: Co-worker/patient/student/client/member of public Other (specific)

Apparent Motive:

Witnesses: Name: Name: Name:

Address:

Address:

Address:

Complaint Submitted by:

(Signature) (craft)

Provided to:

Date:

(day) (month) (year) Time am/pm



RETURN TO WORK PROGRAM



RETURN TO WORK PROGRAM PURPOSE: Workplace injury claim costs can have a direct negative impact on the operating costs of Sullivan. It is therefore necessary to make every reasonable effort to provide sustainable modified duties to a worker who is injured during the course of employment. POLICY: Temporary modified work will be offered by Sullivan to an employee, who as a result of a workplace injury, is unable to return to his/her regular work. ROLES AND RESPONSIBILITIES: MANAGEMENT: The corporate Safety Officer will act as the modified “Return to Work” manager and ensure that resources are in place to develop, implement and maintain modified duties including modifications to the workplace to accommodate the needs of the injured worker, unless that would create undue hardship. Determine if the injured employee’s regular work can be modified to accommodate any physical restrictions prescribed by the treating health care professional, using a “Physical Demands Analysis” form. Identify alternative temporary modified job tasks that are suitable for the injured employee to perform. A WSIB return to work specialist could be of assistance in determining suitable modified work. Maintain regular contact with the injured employee and the health care provider throughout the duration of the modified work to ensure progressive recovery. Track all WSIB claims and provide a report annually, or as requested to Senior Management. SUPERVISORS: Ensure that workers are apprised of the corporate “Return to Work” program at the time of workplace orientation. Provide injured employees with initial transportation to a health care facility if necessary and when safe to do so, or if requested, following a workplace injury.



Provide the injured worker with a WSIB “Treatment Memorandum” form requested that he/she provide the completed form, along with the company letter of introduction to the health care provider. Offer and provide temporary suitable modified work in accordance with the stipulations on the providers completed “Functional Abilities Form”. Report to management if an employee on modified work experiences any difficulties with the assigned modified work activities. WORKERS: Report all accidents or illnesses immediately to the workplace supervisor or health and safety representative. Obtain first aid and medical attention if necessary. Inform the health care provider that Sullivan offers temporary modified work. After health care has been provided, return a completed WSIB “Functional Abilities Form” to workplace supervision and discuss modified duties, if necessary. Co-operate in the modified work program. Report any modified work difficulties to workplace supervisor. Regularly provide workplace supervisor with updated information on recovery progress. RETURN TO WORK PLAN/PROCEDURES ELIGIBILITY: An employee who has experienced injuries or occupational illnesses in the workplace. The “Return to Work” process begins immediately or as soon as practical after the injury/illness occurs. Workplace parties to maintain regular contact in an effort to manage the “Return to Work” process. The “Return to Work” manager (corporate Safety Officer), will meet frequently with the workplace parties (supervision and worker) to review the modified work duties and difficulties, if any, experienced while carrying out the assigned tasks. Modifications, if any, shall be documented with continued follow up.



EXIT FROM “RETURN TO WORK” PROCESS: When an injured worker is capable of return to their regular job at full functional capacity supported by functional ability information. When an employer is unable to provide suitable, available work. When a permanent placement has been established in alternative work. WSIB must be kept informed of wage changes, work reintegration change in duties, failure to co-operate, adjustment to the duration of the return to work program and the return to full employment, close out of program, of an injured worker. RETURN TO WORK DISPUTES: When there is a dispute between the company and the subject employee, regarding a “Return to Work” plan, the following steps shall be taken: A review of the “Return to Work” plan and the “Functional Abilities Form” will be conducted and if a modification to the assigned task is deemed necessary, steps shall be taken to correct it. If necessary, obtain an updated “Functional Abilities Form” and review it to assess the suitability of available work. When the dispute cannot be resolved internally, the matter shall be referred to the WSIB requesting assistance from a “Return to Work Specialist” to resolve the issue(s). OBLIGATION TO RE-EMPLOY: As per the WSIB legislation, there is an obligation to re-employ an injured worker. OBLIGATION TO RE-EMPLOY: As per the WSIB legislation, there is an obligation to re-employ an injured worker. COMMUNICATION:



This policy will be communicated to employees during orientation or through a safety meeting/talk. TRAINING: Training will be provided to employees when and where necessary. EVALUATION: Management, along with the corporate Joint Health & Safety Committee, will review this policy annually. Recommendations, if any, will be developed and implemented to ensure continuous improvement of these activities.


OFFER OF MODIFIED WORK ________________________________ has reported having experienced a work related illness/injury, on the _______________ day of _____________________, _________________.

Health care assessment has revealed the employee can return to a modified form of work and accordingly the following work is being offered on a temporary basis, at the workers’ pre-injury earnings.

Clean and repair of tools and equipment: Clean up of work areas, including sweeping and sorting of light materials: Clean up tool cribs and trailers: Cleaning and sorting lumber: General offices duties: Ordering/shipping/receiving materials: Signaling duties for vehicles, equipment, and hoisting operators: Traffic control duties: Other:

It is hereby understood that the following restrictions are to be strictly adhered to by the worker, while carrying out this work.

I, the undersigned employee, accept this offer of modified work, this _____________ day of

________________________, ______________________ at ________________.

______________________________________ ____________________________________ Employee Signature Supervisor Signature


Physical Demand

Task #

Frequency Describe Activity Note Distances, Durations & Surfaces N R O F C

Mobility Walking Standing Sitting Crawl Driving (Forklift/Vehicle/Other)

Posture – Back Bending Forward Bending Backwards Twisting Posture – Reaching Above Shoulder Level Chest to Shoulder Level Below Chest Level Behind Body Posture– Elbow/Forearm/Wrist Elbow Flexion/Extension Wrist Flexion/Extension Wrist Rotation Posture – Neck Forward Bending/Flexion Backward Bending/Ext. Twisting/Turning/Tilting Posture – Hip/Knee/Ankle/foot Crouching/Squatting Kneeling Climbing (Stairs/Other) Jumping Foot Pedal/Action

N=Not Required, R=Rarely (<2%), O=Occasional (3-33%), F=Frequent (34-66%), C=Constant (67-100%)


MANAGEMENT REVIEW

HEALTH & SAFETY



MANAGEMENT REVIEW – HEALTH & SAFETY PURPOSE: The management of Sullivan will participate in an annual review of the corporate Health and Safety Program. POLICY: The Management of Sullivan will review all Elements of the H&S Program at a minimum of once annually. Further this the items below will be reviewed Monthly during the Sr. Management H&S review with the CHSO. Establish and maintain a system that keeps a record of;

• Accident Investigations; • Injury Reports; • Hazard Reports; • Workplace Inspection Reports; • Health & Safety Committee meeting reports (minutes); and • Ministry of Labour reports. • Changing Circumstances, Legal Requirements • Industry Trends

GUIDELINE: In order to recognize and monitor the success of the Health and Safety Program, reports, records and other performance measures must be reviewed by management. Analysis of these reports will help identify what elements of the program require attention and improvement. ROLES AND RESPONSIBILITIES: WORKER: Report all accidents, incidents, injuries, first aid and near miss occurrences, equipment and or material damage to the workplace supervisor.



SUPERVISOR: Maintain records of worker orientation, project inspections and Ministry of Labour reports. Ensure accident, incident, injury and near miss occurrences are investigated and reports prepared accordingly. Review accident, incident, injury, first aid, near miss occurrences, equipment and material damage reports for purpose of developing procedures to prevent a recurrence. Ensure that the corporate Safety Officer gets copies of all relevant safety information, including Ministry of Labour and Safety Committee reports including follow-up action reports. SENIOR MANAGEMENT: Establish a system to maintain records of orientation, project inspections, safety audits, MOL reports and follow-up actions. Review all Elements of the H&S Program at least annually. Monitor injury frequency rates. Compile an annual report of workplace health and safety activities and occurrences. Establish “targets” from information learned in the annual report that will enhance the corporate health and safety program in future. RECORDS REVIEW AND STATISTICAL ANALYSIS PROCEDURES: All project safety data will be registered and recorded at the workplace. Appropriate actions will be documented and initialled by the supervisor when complete. All workplace safety data will be copied to the Arnprior Safety Officer for disbursement to senior management. Workplace inspection, injury and occurrence reports may be statistically analysed and form a part of the annual Health and Safety report, as follows:



PROJECT INSPECTIONS:

• Number performed, hazards identified and issues involved ACCIDENT INVESTIGATIONS:

• Number performed, by occupation and category LOST TIME INJURIES:

• Frequency, injury type, by occupation and number of days lost SAFETY COMMITTEE MEETING MINUTES:

• Members indicated, issues identified and resolve determined Health and Safety targets will be established from trends identified, repeat contraventions, injuries and/or commonly identified hazards. HEALTH AND SAFETY MANAGEMENT REVIEW: To be completed annually by company internal auditor(s) and Senior Management. Audit report is to be prepared and forwarded to Senior Management for sign off. COMMUNICATION: This policy will be communicated to Senior Management during management safety meeting. TRAINING: Training will be provided when and where necessary. EVALUATION: Senior Management will review this policy annually. Recommendations, if any, will be developed and implemented to ensure continuous improvement of these activities.



MISCELLANEOUS

POLICIES



WHMIS



WORKPLACE HAZARDOUS MATERIAL INFORMATION SYSTEM (WHMIS) PURPOSE: The “Workplace Hazardous Material Information System” (WHMIS), is designed to protect the health and safety of Sullivan employees, by providing information about any hazardous materials they may work with or encounter on the job. DESCRIPTION: There are four main areas of WHMIS system, as follows:

1. Hazard Symbols 2. Warning labels on containers of hazardous materials 3. Material Safety Data Sheets (MSDS) 4. Worker Education and Training

CONTROLLED PRODUCTS: A controlled product is a material or substance that falls into any of the following six hazard classes: Class A: Compressed Gases Class B: Flammable and Combustible Materials Class C: Oxidizing Materials Class D: Poisonous and Infections Materials Class E: Corrosive Materials Class F: Dangerously Reactive Materials LABELS: A “Supplier Label” is generally affixed to the container or packaging of the controlled product and includes information such as the product name, the hazard symbol(s) identifying hazards associated to the product, risk phrases, precautionary measures, first aid measures and reference to a Material Safety Data Sheet. A “Workplace Label” is a label placed on the container of decanted material by the manager or worker to identify the contents thereof. The “Workplace Label” must contain such information as the product name, safe handling instructions and reference to a Material Safety Sheet.



When a supplier label is missing from or becomes illegible on a shipping container or package, a workplace label should be drafted and affixed to it. EMPLOYER RESPONSIBILITIES:

• Ensure that containers of hazardous materials have labels on them • Ensuring that labels are not removed, defaced or altered while there is a product in the container or

package • Ensure that employees are trained and understand WHMIS responsibilities

EMPLOYEE RESPONSIBILITIES:

• Workers must report to their manager, supervisor/lead hand, when labels on containers or packaging are unreadable, have been removed or altered

• Workers must participate in WHMIS training and understand the system • Workers must consult MSDS for risks, hazards and personal protection identified for the product they

are about to handle MATERIAL SAFETY DATA SHEETS (MSDS): EMPLOYER RESPONSIBILITIES:

• Ensure that MSDS’s are available in the workplace for all controlled substances present • Ensure that the MSDS’s are current. Issued within three years of last publication date • Ensure that workers are familiar with the content of MSDS for a product they are about to use • Ensure that an MSDS is provided to a physician or nurse on request for diagnosis and or treatment in an

emergency EMPLOYEE RESPONSIBILITIES:

• Ensure that he/she knows that an MSDS exists at the workplace and where it is kept • To read and understand the MSDS before using a controlled product for the first time

EDUCATION AND TRAINING: The main goal of WHMIS is to increase the workers’ knowledge of the risks and hazards of a product they may work with.



WHMIS training will be provided to all employees every three years or as required. COMMUNICATION: This policy will be reviewed with personnel at time of orientation and/or through safety meetings/talks.



COMPANY DEDICATED VEHICLE POLICY STANDARD: Sullivan considers the use of company vehicles for anything beyond work purposes to be a privilege. As employees of Sullivan, and our representatives in the field, your actions should reflect our high standard of integrity in the communities where we live and work. ELIGIBILITY AND TERMS UNDER WHICH SULLIVAN VEHICLES ARE TO BE OPERATED, INCLUDE, BUT ARE NOT LIMITED TO THE FOLLOWING:

• Employees eligible for the assignment of a company vehicle will be chose at the discretion of the company President/CEO in consultation with the Vice President/General Manager of the Arnprior or Kingston office

• The assignment of a company vehicle is conditional upon the employee having a valid driver’s license for the province in which he/she resides

• Driver’s license “abstracts” will be reviewed annually • The driver of a company vehicle is expected to maintain his/her assigned vehicle in a safe operating

condition. Particular attention must be paid to the maintenance schedule requirements, to keep the vehicle warranty valid, if applicable

• All unsafe vehicle conditions are to be reported immediately to a company Vice President/General Manager

• The driver of a company vehicle is responsible for ensuring all necessary precautions are taken to prevent damage and theft of the company vehicle and/or its contents

• All employees operating a company vehicle shall report to the “administrator” at the Arnprior office, all accidents, charges including parking tickets, M.T.O. inspection reports and vehicle damage at the first reasonable opportunity

• Drivers will be accountable for the payment of penalties incurred during the operation of a company vehicle

• When a company vehicle is used for personal trips, fuel is to be paid for the by the employee • Non employees such as spouses, children, relatives or friends are not to operate company vehicles



DRIVER ACKNOWLEDGEMENT I have been made aware of my responsibilities and conditions as an employee afforded the privilege of a company vehicle. By my signature below, I accept the responsibilities and conditions as set out in this company vehicle policy. Employee Name Printed ______________________________________________________ Employee Signature ______________________________________________________ Description of Vehicle: Make: ______________________________________________________ Model: ______________________________________________________ License Plate: ______________________________________________________ Witnessed By ______________________________________________________ Date ______________________________________________________



INSURANCE CLAIMS – PROTOCOL The following is a basic outline of how we should respond to insurance claims – big or small. Executive Summary – four very important steps

• STEP ONE/DAY ONE: take whatever emergency mitigation measures are needed to stop the water, fire or whatever is causing the damage

• STEP TWO/DAY ONE: without delay – report the claim to both your direct supervisor/Project Manager and the CFO

• STEP THREE: after emergency mitigation is complete, operate ONLY under the express authority of the owner. Our first inclination is to help out, which is OK during the first day of emergency mitigation, but thereafter only with proper authorization

• STEP FOUR: preserve evidence of claim Below are more detailed steps for what to do and expect with an insurance claim: DAY ONE:

1. Mitigation measures that should be implemented immediately: • IF this is an emergency situation – take necessary steps to stop the water, put out the fire, clean

up the spill and/or whatever else is required to respond to the emergency • Non-emergency work should not occur without claims advice from our insurance adjuster. Any

work beyond immediate emergency mitigation work should not proceed without an approved change order

• Photos are work a thousand words – take them if you can! • If others (e.g. – emergency operations) have done emergency work, we have to be mindful of

long term warranty concerns that may have been caused by the other contractors’ work • If media, policy or government authorities arrive on site, follow instructions as outlined in our

safety manual • DO NOT ADMIT LIABILITY TO OTHERS under any circumstance

2. For all claims – property, third party injury, damage to other’s property, employee injury: • Call your Supervisor/Project Manager immediately and the company CFO • The insurance adjuster will be called by them and ideally the adjuster should attend within 4

hours of the damage occurring. • Report injuries to employees and third parties as outlined in our safety manual

3. Preserve evidence: • Keep all of the parts that may have caused or contributed to the loss



• Do not disturb the site as we may not be at fault and we may be able to recoup the cost of the claim, but to do so we need to preserve the evidence

• Outside experts may need to be called in – this will be determined by the insurance adjuster 4. CFO to review coverage with Broker/Adjuster:

• The adjuster should be able to determine the deductible that is applicable to the loss • We will review the coverage as to whether or not this is a Course of Construction (e.g. Builders’

Risk) policy or a Third Party Property Claim DAY TWO AND BEYOND

5. DO NOT ADMIT LIABILITY TO OTHERS under any circumstances 6. If damage is to a third party property (e.g. – fire to an adjacent/attached building):

• DO NOT rush in to fix the problem – even though it may well be our fault, it may not be our problem. The third party will have their own insurance policy

• CALL your Supervisor/Project Manager and the company CFO immediately • The insurance adjuster will assess our coverage and will quantify the third party loss in the event

of liability 7. Quantify the loss as soon as possible:

• Use our Manager – Restoration Services to price out the emergency work if possible, if not available, we will bring in an insurance contractor to price the loss as a guideline only

• Then the rebuild needs to be priced the same way, using the above as a guideline 8. Change Orders and Contractual Obligations

• Supervisor/Project Manager and CFO need to meet as soon as possible after the on-site inspection to review the contracts at hand

• Work should be done ONLY under an APPROVED, WRITTEN CHANGE ORDER. The approval should come from both the owner and their insurance company

• Keep in mind that the change order does not necessarily have to abide by the original contract terms (in fact we may not be operating under the original contract itself) – but it must be approved by both the owner and insurance company

9. Implementation of the work: • Keep track of time, material and equipment used for any work done. Keep in mind that items

claimed still have to follow the proposed change order as approved above (e.g. the change order may require signatures from the owner on our time sheets)

• Cross reference these costs with the Manager – Restoration Services and the Xactimate Insurance pricing

10. Meeting with the Broker/Adjuster



• Once the emergency work is completed, we will meet with the adjuster and examine a “draft” copy of the claim before filling it with the owner

Generally, in gathering documentation, we will most always require the following:

• Contract/Sub Trade Contracts • Turnover dates and permits • QA/QC – Commissioning Reports • All change orders associated with the damages and potential root causes of the loss • Change orders issued with respect to work implemented as a result of the loss • Specifications and drawings • Engineering/architect minutes surrounding the issue that could have caused the loss

Every claim is unique and they all possess individual challenges. First party and third party claims differ in the approach and coverage available and they should be treated differently. The key to any investigation is EARLY INTERVENTION, OBSERVING THE DAMAGE AND PRESERVING THE EVIDENCE BUT DO NOT, UNDER ANY CIRCUMSTANCES, PROCEED BEYOND EMERGENCY MITIGATION MEASURES UNLESS EXPRESSLY DIRECTED BY THE OWNER AND THEIR INSURER IN WRITING.



CELL PHONE/

ENTERTAINMENT DEVICES



CELL PHONE/ENTERTAINMENT DEVICES ON SULLIVAN CONSTRUCTION PROJECTS STANDARD: To establish policies limiting the use of cell phones and entertainment devices on Sullivan construction projects. DEFINITIONS: CELL PHONE: is a mobile phone that can make and receive telephone calls and text messages, copy images, and record audio and/or video content, transmit audio files, and/or radio signals. ENTERTAINMENT DEVICES: include, but are not limited to, I phones, mp3 players, tablets, cameras and video equipment. PROCEDURES: The use of cell phones and entertainment devices on Sullivan construction projects will be restricted to: Site Management/Supervisory and Safety personnel. On site workers anticipating an urgent call, may be granted written authorization to bring a portable phone onto a construction site, by the Project Supervisor, and or his designate. Radio phones and two way radios will be allowed on a construction site when required for communication purposes in carrying out a task. THIS POLICY DOES NOT REFERENCE BUILT IN RADIOS IN VEHICLES AND/OR EQUIPMENT Subject to restrictions by owners of a project: cell phones may be brought onto a construction site by a vehicle, if vehicles are allowed on site. Devices are to be left in vehicle during working hours and utilized by workers during breaks or lunch periods. Cameras and video equipment may be brought onto a construction project if written authorization is provided by the site supervisor or his designate. NON COMPLIANCE WITH THIS POLICY MAY RESULT IN DISCIPLINARY ACTION BEING TAKEN



WORK REFUSAL PROCESS



WORK REFUSAL PROCESS The purpose of this standard is to establish a procedure for dealing with a workers right to refuse “unsafe work”. RESPONSIBILITIES WORKERS: When a worker believes that work assigned to him/her may put his/her or another workers health and/or safety in danger, the work has a right to refuse to do the work. Upon refusing work the worker shall promptly make his/her supervisor or employer aware of his/her refusal and remain in a safe area as close to his/her assigned work area as possible, while the matter is being investigated. SUPERVISOR/EMPLOYER: The supervisor and/or employer have a legal responsibility to investigate the circumstances of the refusal in the presence of the worker, the workplace safety representative, a member of the health and safety committee or a worker chosen by his/her union or fellow workers. If the “refusal” is determined to be authentic, then the necessary corrections shall be made and the worker agrees to return to work. If the supervisor and/or employer do not agree that the work assignment, area or machinery, tools or equipment are a danger, then the Ministry of Labour must be notified of the “refusal” and requested to investigate. The Ministry of Labour Inspector’s decision as to unsafe work is final. The worker refusing the assigned work, may be given other work pending the outcome of the investigation. Another worker may be asked to perform the work being refused provided he/she informed that an unsafe work refusal is in place and an explanation is provided as to the reason for the refusal.



OFFICE SAFETY



OFFICE SAFETY PURPOSE: To develop a policy for Sullivan management, workers and visitors to reference while in company office premises. POLICY: The following is a list of items that should be considered when in or about an Sullivan office premise, but is not limited to: OUTDOOR:

• The parking lot, sidewalk surfaces are smooth, without potholes or other slip and trip hazards and have adequate lighting

INDOOR:

• Office entrance ways are kept clean and free of obstructions • Wet and/or slippery floors are marked with warning signs • Office corridors and stairways are kept clear of articles, obstructions, trip hazards and have adequate

lighting • Furniture is maintained in good condition • Office workstations are comfortable with a strong emphasis on ergonomics, good posture and proper

lighting • Washrooms are kept clean and maintained with adequate supplies of toiletries • An adequate supply of drinking water is available • Emergency exit lighting is adequate • Adequate fire extinguishers with signage are in place with inspection tags being signed monthly • Chemical products, such as cleaners and sanitizers, shall be kept in their respective containers with

consumer labels affixed warning of classification hazards • If electrical office equipment has to disassembled, it first must be turned off and unplugged (expect for

testing), before being worked on. Manuals must be referenced for stored energy and/or hot sources • Ensure guards and locks are in place for paper shredders, cutting boards and binding machines, etc. • Ensure shelving is not overloaded and materials are stored to prevent them from falling



BEHAVIOUR: • Employees working at their desks, workstations, and/or drawing tables for long periods of time, will be

encouraged to periodically stand up, stretch and move around for a few minutes • Employees will be encouraged to maintain good posture when sitting or standing • Discomforts experienced during work hours must be promptly reported the workplace health and safety

representative and/or an office manager • Running in office corridors, up and down stairways is prohibited • When descending stairways, consideration should be given to grasping the handrail • Use proper lifting and carrying techniques when handling heavy or bulky packages

COMMUNICATION: This policy will be communicated to the appropriate people during a safety meeting/talk.

health & safety policies manual - m. sullivan & son limited · return to work program ......

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