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Safety Manual 2012 Updates

Safety Manual Table of Contents

Section Title Page Section One: General Requirements 1.1 Requirements for Jobs 1-1 1.2 Additional Requirements for jobs designated as “long term projects 1-3 1.3 Requirements for Contracting Offices 1-3 1.4 Requirements for Fabrication Shops 1-3 1.5 Requirements for Safety Manager 1-4 1.6 Requirements for Safety Coordinators 1-4 1.7 Requirements for Subcontractors 1-4 1.8 Requirements for Policy Translation 1-5 1.9 Disciplinary Policy 1-5 1.10 Drug and Alcohol Free Workplace Policy 1-8 1.11 Light or Restricted Return to Duty 1-13 1.12 General Rules 1-16 Section Two: Hazard Identification/Evaluation/Control 2.1 Hazard Identification 2-1 2.2 Hazard Evaluation 2-2 2.3 Hazard Control 2-2 2.4 Inspections 2-4 2.5 Insurance Agency/Company – Safety/Loss Control Program 2-6 2.6 Behavior Based Safety 2-6 Section Three: Accident Reporting and Recordkeeping 3.1 Accident Reporting 3-1 3.2 Recordkeeping Legal Requirements 3-1 3.3 Guidelines – Recordable Cases vs. First-Aid 3-5 Section Four: Accident Investigation 4.1 What Should Be Investigated 4-1 4.2 Why Accidents Must Be Investigated 4-1 4.3 Fact Finding 4-1 4.4 How to Conduct an Accident Investigation 4-2 4.5 Step-by-Step Use of Form, Parts I - V 4-5 4.6 Instruction for Management on Completing the “Manager Review” 4-7 4.7 Step-by-Step Use of Form – Part VI (Management’s Review) 4-8 4.8 Guide for Identifying Root Causes 4-8 Section Five: Governmental Regulation Compliance 5.1 Role of Management Representative 5-1 5.2 Presenting Credentials 5-1 5.3 Scope of Inspection 5-2 5.4 Employee Representative 5-2 5.5 Employee Interviews 5-2 5.6 Note-Taking 5-3 5.7 Trade Secrets / Photographs 5-3

Section Title Page 5.8 Correcting Apparent Violations 5-3 5.9 Records Access / Information Request 5-4 5.10 Industrial Hygiene Sampling 5-4 5.11 Closing Conference 5-5 5.12 The Citation Arrives 5-5 5.13 Fatality 5-6 5.14 Checklist of Employer Responsibilities (U.S. Dept. of Labor) 5-6 5.15 Types of OSHA Violations 5-7 Section Six: Emergency Medical Treatment 6.1 First Aid Kits 6-1 6.2 Requirements for Personnel Trained in First-Aid 6-2 6.3 Use of Hospitals, Local Physicians and Ambulance Services 6-2 6.4 Procedures for Transporting Injured Employees 6-3 6.5 Occupational Exposure to Bloodborne Pathogens 6-3 Section Seven: Safety Regulations and Procedures 7.1 General Safety Rules 7-1 7.2 Ladders 7-1 7.3 Scaffolds 7-2 7.4 Confined Spaces 7-5 7.5 Fall Protection 7-12 7.6 Electrical 7-22 7.7 Lock Out / Tag Out 7-24 7.8 Hot Work – Welding, Burning, Cutting, Grinding 7-25 7.9 Personal Protective Equipment 7-29 7.10 Fire Protection and Prevention 7-38 7.11 Cranes and Derricks 7-39 7.12 Rigging 7-41 7.13 Excavation, Trenching and Shoring 7-44 7.14 Signs, Signals and Barricades 7-44 7.15 Hand and Power Tools 7-45 7.16 Powder Actuated Tools 7-45 7.17 Pneumatic Tools 7-46 7.18 Housekeeping 7-47 7.19 Asbestos Awareness 7-47 7.20 Warehouse Safety 7-48 7.21 Metal Fabrication Facilities 7-50 7.22 Insulation Fabrication Facilities 7-50 7.23 Hazard Communication Program 7-51 7.24 Process Safety Management (PSM) 7-54 7.25 Equipment Tagging Procedures 7-56 7.26 Lead 7-57 7.27 Lead – Renovation, Repair and Painting 7-66 7.28 Mold Prevention and Reporting Policies 7-71 7.29 Silica 7-71 7.30 Inorganic Arsenic 7-72 7.31 Hexavalent Chromium 7-80 7.32 Ammonia 7-87 7.33 Refractory Ceramic Fibers 7-87

Section Title Page 7.34 Environmental Policy 7-90 7.35 Proper Lifting Techniques 7-95 7.36 Pre Work Stretching 7-96 7.37 Cell Phones 7-97 7.38 Heat Related Illness 7-97 Section Eight: Emergency Action Plans 8.1 Fire 8-1 8.2 Serious Injury 8-3 8.3 Severe Weather, Tornado, Lightning 8-3 8.4 Earthquakes 8-3 8.5 Employee Verification 8-4 8.6 Bomb Threats 8-4 8.7 Crisis Management 8-5 Section Nine: Training and Motivation 9.1 General 9-1 9.2 Tool Box Safety Meetings 9-1 9.3 Brochures/Posters/Publications 9-2 9.4 Manager/Superintendant/Foreman Education 9-2 9.5 Motivational Programs 9-3 9.6 Documentation 9-3 9.7 New Hire Orientation 9-3 9.8 Task Specific Training 9-4 9.9 Job Hazard Analysis 9-4 9.10 New Employee Mentoring Program 9-4 Section 10: Vehicular Safety 10.1 Traffic Control 10-1 10.2 Lift Truck (Forklifts) 10-1 10.3 Vehicle-Mounted Elevating Work Platforms (JLGs, Scissor Lift, etc.) 10-4 10.4 Fleet Management of Company Vehicles, Trucks, and Vans 10-5 Section 11: Off the Job Safety 11.1 Purpose 11-1 11.2 Most Common Types of Off-the-job Injuries and How to Prevent Them 11-1 11.3 Wellness 11-2

Gribbins Insulation Company 2012 Page1- 1

Section One

General Requirements

Requirements for all operations as a minimum standard to comply with OSHA Safety and Health Regulations for Gribbins Insulation Company, Inc.

1.1 Requirements for Jobs 1. Every job shall plan and execute work in compliance with this Safety Program

Manual. 2. All projects shall have a competent person or persons responsible for

communication with the safety officer and for the Accident Prevention Program. 3. Designated projects shall establish a Job Site Orientation Program for all

personnel. Documentation must be maintained for all orientation sessions. The Orientation Program shall include, but is not limited to the following items:

a. Gribbins Insulation Company Safety Policies and Procedures b. Job Site Safety Rules (General and Specific).

Rules shall be written. A copy shall be available to each employee and the rules discussed as a topic of a Tool Box Safety Meeting. (Documentation required).

c. Emergency Procedures for fire, serious injury and natural disaster. Procedures shall be written. The procedures shall be discussed

with all employees as a topic of a Tool Box Safety Meeting. (Documentation required).

d. Types and use of require Personal Protective Equipment (PPE). When PPE is necessary and what PPE is required to be worn. How to properly put the PPE on, adjust, wear and remove. How to inspect PPE so the defective or damaged equipment is

removed from service. This training must be documented on the Tool Box Safety Meeting

Report Form. Specific job site rules (if any) must specify the necessary

equipment. e. Hazard Communication Program/MSDS

This should be a review of all hazardous materials the employee will be exposed to on any particular job (See Section 7).

f. Provide jobsites with approved First-Aid Kits. Where First-Aid services are provided by others, (A First-Aid station) we should request a copy of the First-Aid Log on a scheduled basis. This log shall be maintained on file.


A First-Aid Log is not required for the use of the First-Aid Kit. The criteria for trained First-Aid personnel as outlined in Section 6 must be met.

g. Post emergency phone numbers and addresses for the following: Fire Police Rescue Squad/Ambulance Service Hospital (for emergency treatment – include directions) Local Doctor (for emergency treatment, if available – include

directions)

This information shall be known to all personnel working on jobs. These numbers should be posted at the job site telephone. In addition, a backup plan should be established for use of company or private vehicle for transportation of injured or ill personnel.

h. In order to establish an employee’s level of comprehension regarding Gribbins Insulation Company’s safety regulation, Gribbins Insulation Company, has implemented an “Orientation Exam and Certification”. The Orientation Exam will test each new hire on their understanding of Gribbins Insulation Company’s safety regulations. The examination consist of 50 True/False and multiple choice questions. A score of at least 80% must be achieved or the new hire will retake the orientation and complete the exam. After completing the exam portion, each employee must complete the Certification of Awareness. This assures Gribbins Insulation Company, that the employee has been made aware of our safety regulations and policies governing each person’s work ethic and missed questions on the exam have been reviewed. This form should be placed in the employee’s file. (See Appendix 1.1).

i. Prepare written First Reports of Injury for all injuries which require First-Aid or medical treatment off the jobsite. These reports are to be forwarded immediately to the Safety Department. (See Appendix 1.2)

j. Prepare a written Accident Investigation Report for any accident that causes death, serious injury, lost time, is an OSHA recordable, head injury, back injury or property damage. (See See Appendix 1.3)

k. Perform on-going inspections of work sites and warn worker immediately of hazards. Take action to eliminate the hazards. (See Appendix 1.4)

l. Conduct Tool Box Safety meeting on a weekly basis. Stress two-way communication between supervisors and workers to maintain a high level of safety awareness. Documentation must be maintained. (See Appendix 1.5)


m. A copy of the OSHA Job Safety and Health Poster shall be displayed at each job site.

1.2 Additional Requirements for Jobs that Gribbins Insulation Company designates as “long term projects”.

1. All of the preceding information. 2. Tool Box Safety meetings conducted on a weekly basis at a designated day

and time and documentation of the meetings be maintained on Gribbins Insulation’s Safety Meeting Report Form. (See Appendix 1.5) (Preferred – prior to starting work each Monday).

3. A set of written Safety Rules (See Section 7). These general job site safety rules are to be used as a guideline to establish safety rules for each job. The list may be used as is, or specific rules can be added when necessary.

4. Requirement that Gribbins Insulation’s Safety Inspection Report and Checklist be completed at the start of a job and at least weekly thereafter for as long as a work crew is being maintained at the job. (See Appendix 1.4)

1.3 Requirements for Contracting Offices

1. Designate a person responsible for Office Safety. 2. Prepare a list of Safety Rules for the general office area and other areas

under or accessible to contract personnel. This information should be posted and communicated to all employees and visitors, as appropriate.

3. Indoctrinate all personnel with emergency procedures for severe injury, fire, and natural disaster. The indoctrination should also include proper use of fire extinguishers and other firefighting equipment.

4. Prepare bomb threat emergency plan. Specific office personnel should be given instructions on how to handle a bomb threat by a telephone caller.

5. Emergency telephone numbers as outlined in Section 1.1, shall be posted at each telephone location.

6. Provide an approved First-Aid kit for office use. 7. A copy of the OSHA Job Safety and Health Poster shall be displayed and the

OSHA 300 form shall be maintained and posted in accordance with Federal Regulations.

1.4 Requirements for Fabrication Shops (Permanent and Non-Permanent)

1. To include all the aforementioned, where appropriate.


2. Safety regulations to include plans for the safe use and maintenance of each piece of equipment utilized in the Fab Shop Operation, and the proper handling and storage of all material

1.5 Requirements for Safety Manager

1. Shall be evaluated annually to determine performance. 2. Reports all safety issues immediately to upper management. 3. Continue education to acquire knowledge pertaining to job related task. 4. Maintain Gribbins Insulation’s OSHA 300 log. 5. Manage all worker’s compensation claims. 6. Review and revised the safety manual annually or when regulations are

altered. 7. Enforce all Gribbins Insulation, Owner, Construction Manager, General

Contractor, Federal, State and Local Rules and Regulations

1.6 Requirements for Safety Coordinators

1. Have completed the OSHA 30 hour construction training. 2. Have completed Gribbins Insulation Safety Coordinator Training. 3. Reports directly to the Safety Manager. 4. Have completed fall protection training. 5. Have completed First Aid and CPR training. 6. Train employees on and enforce all Gribbins Insulation, Owner, Construction

Manager, General Contractor, Federal, State and Local Rules and Regulations.

7. Shall be evaluated annually to determine performance. 8. Conduct random jobsite inspections. 9. Continue training to ensure they are competent in all aspects pertaining to job

related tasks. 10. Enforce Gribbins Insulation’s Drug Free Workplace Policy.

1.7 Requirements for Subcontractors

1. Must complete a Gribbins Insulation Safety Prequalification Form and must

be approved by the Safety Department before beginning work. (See Appendix 1.6) Subcontractors must have an EMR of 1.0 or below, an OSHA Total Recordable Incident Rate (TRIR) and Days Away, Restricted, Transfer Case Rate (DART) and have no fatalities within 5 years. If these conditions


are not met, the Safety Manager can grant a variance if the subcontractor shows they have corrected any discrepancies.

2. Shall designate an onsite safety representative with at least the OSHA 10 hour construction training.

3. Shall follow all Gribbins Insulation, Owner, Construction Manager, General Contractor, State, Federal and Local regulations.

4. Shall have MSDSs for all hazardous material brought onsite. The MSDS sheets shall be kept with the Gribbins Insulation Safety Manual.

5. Shall work with Gribbins Insulation’s safety representative to maintain a safe work site.

6. Shall immediately report all accidents, injuries, illnesses, spills, fires, or unsafe conditions to the Gribbins Insulation representative.

7. Shall have a project specific safety plan. 8. Shall conduct weekly safety meetings. 9. Shall implement a Drug and Alcohol Testing Program. 10. Safety provisions shall be included in subcontractor’s contracts.

1.8 Requirements for Policy Translation

When an illiterate or non-English speaking employee is hired Gribbins Insulation will furnish an interpreter.

1.9 Disciplinary Policy

While discipline should never be thought of as a substitute for effective training and followup, it is a vital support beam in the structure of any safety program. The purpose of this discipline is to improve or correct the employee’s behavior to assure more safety oriented conduct. All employees are under the disciplinary program. Management will be evaluated on their safety commitment and treated with the same warning actions if needed.

The majority of disciplinary actions are intended to be positive. Positive or corrective actions include direct supervision, verbal and written reprimands, or suspensions. Because all the actions presume the employee will return to the workplace as a more productive, cooperative, and safe employee, the only truly negative discipline is discharge.

Examples of violations are listed below, and have been broken into 4 classes. This is not intended to be an all-inclusive list.

Class 1 Violation

Grounds for immediate termination


1. Willful or grossly negligent violation of Safety, Health, Security or Environmental Policy.

2. Initiation of horseplay or harassment that results in personal injury or physical confrontation.

3. Possession of explosives, firearms, tasers, or other lethal weapons on the jobsite.

4. Verbal abuse, violence, or threats of violence to other employees or fellow workers.

5. Acts of sabotage, vandalism or bomb threat. 6. Theft of property. 7. Sleeping on the jobsite. 8. Fighting on the jobsite. 9. Gross insubordination. 10. Failure to adhere to the Harassment Policy Guidelines 11. Willful or grossly negligent damage or mutilation of property. 12. Refusing to submit to a metal detector, lunch box, locker or vehicle

inspection. 13. Possession or sale of alcohol or controlled substances within the site

property. 14. Failure to adhere to affirmative action/EEO/non-discrimination requirements. 15. Absence of three consecutive days without proper notification to employer. 16. Traveling through coupled train cars.

Class 2 Violation

1st violation – Employee subject to suspension of 3 days. (-80 points)

2nd violation – Employee subject to suspension of 30 days, if 2nd violation within 1 year subject to termination (-160 points)

3rd violation – Employee subject to termination

1. Not using fall protection when exposed to a fall of 6 feet or greater, working from aerial boom lift, fall protection required scaffolding, or when other tasks required fall protection.

2. Confined Space violations – breaking the plane without being trained, completing permit, conducting monitoring or having an attendant on duty.

3. Conducting work on a piece of equipment that is not locked or tagged out. 4. Failure to following scaffold tagging instructions or altering a scaffold. 5. Working within 10 feet of overhead power lines. 6. Not completed hot work permit when required or not following hot work

procedures.


7. Reckless use of forklift, aerial lift, scissor lift or other equipment. 8. Failure to report jobsite injury before the end of the shift.

Class 3 Violation

1st violation – Employee subject to written warning ( -40 points)

2nd violation – Employee subject to 3 day suspension, if 2nd violation with a year employee subject to 30 day suspension. (-80 points)

3rd violation – Employee subject to termination (-120 points or total loss)

1. Failure to use fall protection correctly. 2. Standing on the guardrails of an aerial lift or scissor lift. 3. Failure to use Ground Fault Circuit Interrupter (GFCI) when using electrical

equipment. 4. Unauthorized use of Owner’s facilities or Gribbins Insulation vehicles. 5. Excessive late starts, early quits or absenteeism. Three in a 30 day period

including excessive tardiness. 6. Leaving the jobsite without proper employer notification 7. Failure to log in or out using an established site program when entering or

leaving site. 8. Smoking or smokeless tobacco use in restricted areas. 9. Unsatisfactory work performance. 10. Refusing work assignment. 11. Gambling 12. Failure to report on the job injuries within 15 minutes of occurence. 13. Failure to obey jobsite traffic signs or speed limits. 14. Violation of Company Driving Policy.

Class 4 Violation 1st violation – Employee subject to verbal warning (-20 safety points) 2nd violation – Employee subject to written warning, if 2nd written warning with in 1 year employee subject to 3 days suspension (-40 safety points) 3rd violation – Employee subject to 3 day suspension, if 3rd violation within 1 year employee subject up to termination (-80 points)

1. Failure to wear proper eye protection for task at hand. 2. Failure to wear proper hand protection for task at hand. 3. Improper use of ladder. 4. Not completing pre use inspection of aerial lift, scissor lift or fork lift.


5. Failure to sign in or out on STA or JHA 6. Failure to use Ground Fault Circuit Interrupter at power source. 7. Failure to obey posted warning signs on the jobsite.

This is in no way intended to be an all inclusive list of violation and disciplinary action, but is intended to give an idea of the seriousness of each violation and the disciplinary action to be taken. Gribbins Insulation reserves the right to change this policy at any time or take more strict disciplinary action if needed. Even though these are a list of our disciplinary policies, when working on jobsite with more stringent disciplinary programs, we will be required to follow those policies when violations occur.

It is extremely important that every effort be made to determine whether the violation was the result of negligence, willful disregard of safety rules or the result of a misunderstanding or lack of knowledge on the employee’s part.

All verbal and written warnings will be documented and kept in the employee’s file for future reference.

In the event of an appeal, Gribbins Insulation’s position should indicate:

Was the violated safety rule, procedure or practice known to the employee?

Did the employee have prior warnings of possible disciplinary action for repeated safety violations?

Has discipline for safety violations been uniform prior to the incident? Do we have documentation to prove our actions and position? Is there an investigation of the safety violation?

1.10 Drug and Alcohol Free Workplace Policy

1. Statement Gribbins Insulation Company prohibits all employees from engaging in the illegal use of drugs and the use of alcohol at the workplace. It is a violation of Gribbins’ policy for an employee to be under the influence of alcohol, be engaging in the illegal use of drugs at the workplace or have alcohol or illegal drugs on the employee or employer’s premises. The illegal use of drugs and the use of alcohol at the workplace presents dangers to the employee engaging in such behavior and to his or her fellow employees, employees of others at off-premises work sites and to the public in general. Such conduct can result in slowed reaction times, irrational and inappropriate behavior, and other feelings and actions that could result in


property damage or bodily injury, including death. The danger is heightened whenever the person affected is operating a motor vehicle or any equipment or tools.

2. Program Mechanics

All drug testing shall be conducted in accordance with procedure of the U.S. Department of Health and Human Services (DHHS) as outlined in the “Mandatory Guidelines for Federal Workplace Drug Testing Programs” as set forth in the Federal Register. The testing laboratory shall be licensed or certified by the Substance Abuse and Mental Health Service Administration (SAMHSA). Employees will provide a urine specimen for the drug test. The specimen will be collected at a facility selected by Gribbins Insulation Company. The specimen shall be separated, as a minimum, into two containers at the time it is collected. The collection facility or laboratory shall maintain chain-of custody documentation for the specimen. Drug Screening and Gas Chromatography/Mass Spectrometry (GC/MS) confirmation for ten categories will be required with cut-off limits as established in the aforementioned DHHS guidelines, which currently are:

Drug Class Screening Cut-Off Confirmation Cut-Off Limit (ng/ml) Limit (ng/ml)

Amphetamines 1000 500 Barbiturates 300 200

Benzoylecgonine (Cocaine Metabolite)

300 150

Cannabinoids (THC) 50 15 Methaqualone 300 100

Opiates 2000 1000 Phencyclidine (PCP) 25 25

Benzodiazepines 300 300 Methadone 300 300

Propoxyphene 300 200

The cut-off limit for Alcohol is that established by the Department of Transportation.

3. Testing

A. An employee shall be tested as follows: 1. Pre-employment, employee will be sent directly to testing facility before

reporting to work, if not in possession of current Drug Test results acceptable to Gribbins Insulation Company. Employee’s time will start


when testing facility opens and will report directly to the predetermined jobsite upon completion of the drug test with testing verification in hand.

2. Once per calendar year. Upon receipt of notification, the employee will have five (5) calendar days to test for renewal of their drug card.

B. Random Testing 1. Randomly, tested on Gribbins Insulation Company time, if selected

quarterly as one-twelfth (1/12) of twenty-five percent (25%) of total employed at that time. An independent firm with a computer selection program to ensure random selection will be utilized. Upon notification from the independent firm Gribbins Insulation Company’s Program Administrator will contact the randomly picked employees. Upon receipt of notification, the employee will have 24 hours to take their random test.

C. An employee may also be required to be tested as follows:

Reasonable Suspicion

1. Reasonable suspicion exists if certain objective facts and circumstances warrant rational inferences that a person may be under the influence of alcohol or a banned substance. Illustrative, but not all-inclusive of reasonable suspicion are (generally, a person under the influence exhibits a combination of such criteria):

(a) A pattern of abnormal conduct or erratic behavior; a dramatic decline in work performance; excessive sick time usage.

(b) Information provided by reliable and credible sources, which is independently corroborated.

(c) Observation, such as direct observation of use and/or physical symptoms of being under the influence of alcohol.

(d) Difficulty walking; slurred speech; needle marks; glazed stare. (e) Possession of alcohol or a banned substance.

D. Post-Accident/Incident (Drug and Alcohol Testing shall be completed as soon as reasonably possible)

1. Fatal accident – any accident that involves loss of life. 2. Non-fatal – any accident/incident where the Employee or another

individual is injured and requires medical attention away from the scene of the accident.

3. Involvement in any accident/incident that causes property or equipment damage of a Contractor or Owner.


4. Violation of a safety rule or practice including a citation under state or local law.

An employee tested under provisions C-D will be transported to the testing facility by Gribbins Insulation Company, or tested on site. The employee will, at Gribbins Insulation Company’s option, be suspended pending the test result. If the participant passes the test, he shall be paid for the time missed.

4. Participant Obligation

All employees employed must have a current drug free certification card acceptable to the Policy Committee. Employees must initially be tested by November 1, 2000.

Gribbins Insulation Company will require any employee to provide and deposit drug-testing results upon employment. Gribbins Insulation Company will be held responsible for the results.

1. An employee must sign Gribbins Insulation Company’s Drug Free Workplace agreement and comply with all testing procedures. Failure to do so shall result in termination of employment.

2. An employee possessing counterfeit Drug Testing results will be terminated from employment, and be deemed a positive test.

3. An employee with an adulterated specimen (defined as tampering with or adulterating the specimen to interfere with, meddle with, etc.), so as to damage, to alter, to make no quite genuine shall consult with the Medical Review Officer for evaluating. All costs incurred for laboratory examination of the adulterated sample as well as the cost of a subsequent test will be the responsibility of the participant.

An employee who fails to abide by provisions 1, 2, or 3 above shall be deemed as having met the second or subsequent offenses: per Article V, Provision 6.

In order to be eligible to receive a Drug Test, an employee must have met all financial obligations of this Agreement.

An employee shall pay for the cost of Employee Assistance Program Treatment.

5. Positive Test


In the case of a positive test result, the employee,

1. May advise the Medical Review Officer of any medication prescribed by his own physician, which may have affected the results of the test.

2. May have the original specimen independently re-tested, at their own expense, by a laboratory selected by the employee that meets the guidelines of Article II herein. If the independent retest is negative, the employee will be reimbursed for the cost of the independent test.

3. Comply with the Medical Review Officer’s & Program Administrator’s “Return to Duty” decisions, including passing a test in order to obtain Drug Testing results.

4. Shall be subject to additional tests over a twelve-month period as determined by the Medical Review Officer.

5. Shall pay for these tests as a result of having more than one positive test during the time period described below (excluding random and annual tests).

6. Disciplinary action (second and subsequent offenses within twenty four months from the date of the previous offense):

A: First offense: not eligible for re-testing for 30 days and compliance with Article V, Provision 3.

B: Second offense: not eligible for re-testing for 90 days and compliance with requirements of Article V, Provision 3.

C: All subsequent offenses: not eligible for re-testing for 180 days and compliance with requirements of Article V, Provision 3.

6. Return to Duty

Gribbins Insulation Company’s Medical Review Officer & Program Administrator will be responsible for the following:

1. Notifying the tested participant of a positive result. 2. Reviewing and verifying a confirmed positive test result. 3. Providing the tested participant with an opportunity to discuss the

reasons why their test result might be positive. 4. Reviewing the participant’s Medical Record as provided by or at the

arrangement of the tested participant, as appropriate. 5. Verifying the Laboratory results. 6. Notifying the appropriate union and Gribbins Insulation Company’s

contact person of all positive test results. 7. Processing a request for re-testing of an original specimen. 8. Participating in Return to Duty decisions as required. 9. Referring the employees testing positive to an appropriate Employee

Assistance Program.


10. Providing a Release form to Gribbins Insulation Company declaring the donor fit for re-testing.

7. Compliance With Owner Requirements

In the event the Owner requires additional drug testing requirements Gribbins Insulation will adhere to these requirements. Examples include Metro Indianapolis Coalition for Construction Safety (MICCS) and DISA, Inc.

1.11 Light or Restricted Return to Duty

Gribbins Insulation Company actively attempts to accommodate any employee that has restrictions of duty due to a work related injury. The Safety Manager, Project Manager and Job Foreman will evaluate the employee’s skill level, type of restrictions and jobs available to find a match for that employee that will not aggravate or possibly aggravate the injury and meet the doctor’s requirements. Examples of jobs used in the past are: job take off, shop worker, warehouse helper.

It is the policy of Gribbins Insulation Company that the prevention of occupational injuries and illnesses will be given highest priority. In the event an employee is injured on the jobsite with restrictions Gribbins Insulation Company actively attempts to accommodate those restrictions. Gribbins Insulation Company will work with the employee, medical care provider and workers’ compensation representative to get the employee back to work as quickly as possible. We believe the faster the employee returns to work, the sooner the employee will return to full duty.

The Safety Manager, Project Manager and Job Foreman will evaluate the employee’s skill level, type of restrictions and jobs available to find a match for that employee that will not aggravate or possibly aggravate the injury and meet the doctor’s requirements. Examples of jobs previously available include:

Job Take Off – Employees have helped estimators or project managers take off footages of jobs being bid or jobs being set up. This could also include marking piping and equipment with the type and thickness of insulation to be installed.

Shop Worker – Employees have cut metal, cut bands, installed clips on bands and cut wire. These are all productive jobs that employees can do without having to carry heavy objects or move frequently.


Warehouse Helper – Employees have helped in the warehouse cutting metal, cutting bands, installing clips on bands, cutting wire or helping with counting materials during inventory.

Studies have shown that frequent contact with injured workers increases early return to work. The Safety Manager should contact the employee within 24 hours of the accident and at least once a week until the employee returns to full duty. The employee should be assured that they are missed and explain worker’s compensation benefits so employees know they will be taken care of. These courtesies promote a rapid return to work and can counter negative messages or feelings the employee may experience.

Gribbins Insulation promotes the fastest possible recovery, but in cases where full recovery may take an extended amount of time, Gribbins Insulation guarantees transition duty for up to 60 days. If the case takes more than 60 day this policy may be varied to conform to the average diagnostic recovery time of the injury.

The goals of this program are:

To promote the earliest possible safe return to work of an occupational related injury or illness.

To keep the employee active to promote therapeutic recovery. To reduce cost of Worker’s Compensation claims due to absence when the

employee could be performing transitional duties.

Responsibilities

Supervisor is responsible for:

Obtain immediate medical attention by first aid trained employee or in house medical staff if available.

Contact the safety department immediately after the incident or injury. Complete the Accident/Injury/Illness Investigation form including employee and

witness statements. Accompany injured worker to medical provider, if at all possible, and tell the

doctor about your company’s return to work process and provide the doctor with an explanatory letter.

Instruct employees on the proper reporting of incidents and injuries and return to work procedures.

With the assistance of the Safety Manager, develop alternative assignment that will meet the doctor’s restrictions, that are meaningful, and ensuring that the injured employee follows these restrictions.


Communicate information to the safety department.

Safety Department is responsible for:

Providing written policy statement and procedures, and making sure that the program is applied consistently.

Ensuring or acting as the return to work coordinator who will take a proactive approach in the return to work program.

Planning, leading, controlling, and monitoring the return to work activities. Providing the treating doctor with Gribbins Insulation’s Return to Work Policy.

(See Appendix 1.7) Providing the injured employee’s job description to treating doctor. Providing a work status report to the worker to give to treating doctor. (See

Appendix 1.8) Communicating regularly with the injured employee and the doctor after each

follow up visit. Providing information to doctors to help them understand the employee’s regular

job, the employer’s return to work program, and available work alternatives. Sending Bona Offer letter certified to employee offering light duty assignment if

doctor indicated modified duty. (See Appendix 1.9) Sending copy of Bona Offer letter and work status report to insurance

representative. Acting as the employer’s representative. Maintaining contact with the health care provider, the insurance company, the

employee, and the employee’s supervisor. Developing and maintaining record keeping and reporting systems for incident

and injuries. (See Appendix 1.10) Inform the employee of the authorization for release of information and have

employee complete. (See Appendix 1.11)

Employee is responsible for:

Understanding your company’s procedures for reporting injuries, and reporting any injury immediately to your supervisor.

Informing treating doctor of alternative work availability and the return to work process. Giving the medical provider Gribbins Insulation’s Return to Work Policy, work status report and copy of job description.

If restricted for any type of work, notifying supervisor immediately, and if off work, at least once a week to let them know how you are doing.

Returning to work on the next schedule shift, if the medical provider releases you to work or wages will not be paid for those days.

Following the medical provider’s orders, if the medical provider gives you medical restrictions for an alternative productive work assignment.

Health Care Provider is responsible for:

Providing immediate, appropriate, and effective treatment that facilitates recovery and expedited return to work.


Assessing the abilities of the injured employee, and provide the employee with physical restrictions to follow when performing job functions.

Providing information about the employee’s work capabilities to the employer and return to work coordinator.

Becoming familiar with operations at the employee’s workplace. Completing, filing out and returning to Gribbins Insulation the work status report.

Workers’ Compensation Adjuster is responsible for:

Determining if an offer of employee meets Worker’s Compensation rule. Terminating workers’ compensation benefits, if the employee accepts the bona

fide offer and is earning pre injury wages. Terminating workers’ compensation benefits, if the employee does not accept the

offer. Once the employee achieves full duty status a brief discussion with him/her, his/her supervisor, physician, and anyone else key to the program’s success should be held to review and evaluate the process.

1.12 General Rules

a. Work place violence will not be tolerated by Gribbins Insulation Company. Work place violence includes, but is not limited to harassment, intimidation, threats, theft, stalking, assault, arson and sabotage.

b. Horseplay in any form will not be tolerated. c. Gambling or playing games for money is not permitted. d. Weapons are prohibited on Gribbins Insulation Company or jobsite property. e. No employee may be under the influence or possess drugs or alcohol on jobsite

property. f. If employees feel ill or fatigued to the point the point of not being able to perform

their duties safely they shall notify their supervisor immediately. g. If an employee is fired or laid off, the employee must be escorted by a Gribbins

Insulation Company representative until of the jobsite. h. If an employee is going to be late or absence, they must call their foreman or

office to notify them. If an employee fails to call in for two consecutive days they will be terminated on the third day.

Gribbins Insulation Company 2012 Page 2 - 1

Section Two

Hazard Identification/Evaluation/Control

2.1 Hazard Identification

Any workplace or job site can be separated into categories which have common hazards associated with them. There are six such categories, which can be applied, forming the basis to assure that hazards are identified by the process of self-inspection. The six categories are:

1. Work Place Hazards Includes such things as floors or other working surfaces, housekeeping, floor and wall openings, entrances and exits, sanitation, illumination, fire, ventilation and others.

2. Machine and Equipment Hazards Includes such things as machine guarding, operational techniques, special safety devices, inspection and maintenance, mounting, anchoring, grounding and other protection.

3. Material Hazards Materials that are utilized, processed or applied on the job that yield dangerous vapors, fumes, mists, dusts or are ignitable and/or explosive must have standard established for their safe storage and use. Included in this category would be the use of compresses gases for burning and the storage and use of toxic solvents, coating, adhesives, mastics, etc.

4. Worker – Employee Hazards Includes such things as the type of personal protective equipment and devices that must be furnished, special training requirements to operate specific equipment and the medical First-Aid services required.

5. Power Source Hazards Electrical, pneumatic, hydraulic, steam, explosive-actuated and other sources or power must have standards applicable to their safe use and application.

6. Operation Hazards Standards should be established covering all special processes, such as welding, cutting, abrasive blasting, elevated work, use of ladders and scaffolds, cable climbers, high lifts, lift truck, aerial lifts, etc.

Any employee that feels as though working conditions are unsafe has the authority to stop the job. The employee should immediately inform their supervisor of these unsafe conditions. If the employee feels as though the supervisor is not taking the proper steps they should contact the Safety Manager.


If the employee would rather communicate the hazard or suggestion through written form, they may fill out and return a hazard identification/suggestion card to the Safety Department. (See Appendix 2.1)

2.2 Hazard Evaluation

1. Field Inspection Report Gribbins Insulation Company has a “Safety Inspection Checklist” designed for indicated and correcting hazards observed in the field operations. (See Appendix 1.4) This signed hazard assessment will indicate if hazards are present or likely to be present, which may necessitate the use of PPE.

2. Common Hazards For most job site hazards, the potential danger is readily apparent. For example, an opening in a floor that is not boarded over or suitably barricaded will probably cause injury to any worker falling through it; or in the case of scaffolding platforms not protected by guardrails, a worker who fall off for whatever reason is likely to be injured. All six categories listed previously should be examined for hazards and hazard potential.

3. Special Hazards Some job site hazards are not as apparent and may require expert evaluation by a technician to determine the hazard potential. Examples would be working in enclosed spaces such as tanks and vessels, working with toxic materials, the proper erection and operation of a lifting hoist, the inspection of cables and safety mechanisms on sky-climbers, working in open trenches, demolition work, excavation and other construction work adjacent to existing properties, etc.

2.3 Hazard Control

When a situation that endangers the safety and health of employees occurs, Gribbins Insulation Company must immediately take steps to eliminate it. One or more of the following three methods of control must be applied:

1. Engineering Controls It is always preferable and more reliable to protect by mechanical means than protection dependent upon human behavior. Examples of this type of protection would be to equip table or band saws with a dust collector, or if working with materials that give off dangerous vapors, to exhaust the vapors mechanically or substitute a non-hazardous chemical. These methods are more reliable then dependence being placed on a respirator to protect the worker. This type of


control also includes such things as barricading openings in floors and wall, shoring in trenches, guards on various types of tools and equipment, etc.

2. Administrative Controls In the case of exposure to air contaminants and noise, work assignments on a rotation basis and/or limiting the amount of time an employee will work at an operation can be used so that permissible levels of exposure will not be exceeded. As a matter of practicality, on most construction projects this method is extremely difficult to administer and likely to be impossible to document in the event of future injury claims based on these exposures. If administrative controls are established, consideration should also be given to the use of personal protective equipment. The ultimate administrative control would be to stop work in an area or a situation where conditions are such that the safety of your workers cannot be assured.

3. Personal Protective Equipment When the hazard cannot be eliminated through engineering or administrative controls, the use of personal protective equipment is mandatory. Included is protection for the eyes, ears, face, head and extremities. It deals with equipment such as hard hats, safety glasses, goggles, face shields, welding helmets, ear muff, ear plugs, protective clothing, respiratory devices, protective shields and barriers, safety harnesses, life lines, self-contained breathing devices, etc. OSHA regulations require that protective equipment shall be provided, used and maintained in a sanitary and reliable condition whenever it is necessary by reason of hazard of processes or environment, chemical hazard or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact. Each project must establish a clear-cut policy on use of personal protective equipment and it should be made a part of the job site work rules. It must be consistent with prevailing regulations as to availability, proper use, inspection, care and maintenance of the equipment. Since the law makes the employer responsible for “employee-owned equipment”, such equipment must receive the same attention as company owned equipment to assure its adequacy (the use of employee-owned safety equipment should be discouraged).


Employees must be trained in the proper use, care and limitations of the equipment, prior to actually working under hazardous conditions requiring its use. Responsibility should be assigned to supervisors to enforce the use of personal protective equipment and a rigid policy for employee compliance must be maintained.

4. Equipment Purchasing Purchase orders for tools, equipment, and personal protective equipment should include a statement requiring that all items must meet the OSHA standards. Standards for tools and equipment commonly used in construction work are found in part 1926 – Safety and Health Regulations for Construction. This section of the regulations, as well as other OSHA regulations, forms, etc., may be obtained from local or regional offices of the U.S. Department of Labor – OSHA.

2.4 Inspections

1. Technical Inspections Gribbins Insulation Company’s insurance company’s Representatives will give assistance in job hazard analysis to determine the accident potential of job procedures, equipment, tools and materials, and will help determine how hazardous acts can be eliminated, what unsafe materials should be replaced, and recommended special equipment necessary to do a job safely. Civil Engineering Specialist are available who have expertise in all phases of building construction and can advise and evaluate potentials for personal injury and property damage. When encountering technical problems or conditions that your personnel are not trained to handle, contact our Insurance Company’s Representative.

2. Periodic Inspections Periodic Inspection include the type conducted at the start-up of each job. On jobs that employ ten or more employees, inspections are additionally required to be conducted on a weekly basis throughout the duration of the work. If necessary, the frequency of inspections can be increased on these jobs or smaller jobs, due to hazards faced. The person responsible for making the inspection should be trained and familiar with required standards and the OSHA regulations. They must be able to recognize hazards and be knowledgeable with the safety equipment available to


protect against hazards. Inspections should be well planned so they can be made systematically with dispatch and efficiency. All level of supervision and management should be involved in conducting unscheduled periodic inspections. These inspections must be documented.

3. Continuous Inspection The job foreman is generally the most important inspector any organization has because they spend practically all of their time on the job. They are in constant contact with their employees and thoroughly familiar with the work to be done. They should be on the alert at all times to discover and correct unsafe conditions and practices and complete at least weekly inspections. They should encourage their employees to maintain a high level of safety awareness and to immediately correct hazardous conditions or to report those that they are not authorized to correct. Foremen shall monitor employee’s activities and behaviors to determine if employees should be removed from the worksite.

4. Corporate Audits Each year selected locations will be inspected to determine the adequacy and effectiveness of the Safety Program. The audit will follow a pattern of examination of all records and documentation pertaining to safety, followed by inspection visits to job sites. The items that will be reviewed (as a minimum) are: Safety function, Safety Program Manual, OSHA 300 Log, Employee Orientation, Tool Box Safety Meetings, Emergency Procedures, Lift trucks, man lifts, vehicles, accident investigations, safety inspections, injury management, job site inspection results, safety communications, safety posters, hazard communication, safety incentive and safety awareness programs, emergency medical treatment and personal protective equipment.

5. Location Audits Location audits should be performed to ensure that policies are being followed. The Safety Manual serves as a blueprint to guide each location in running an effective program. The single most important activity in a safety program is the visible concern by Management for safety activities and plans. The safety audit is a key activity in sending this message. An effective audit will address:

a. Incident Prevention This includes site inspections, incident investigations, use of personal protective equipment, training, hiring strategy and layoff strategy.

b. Incident Management


This includes incident reporting, medical facility use, first aid training, return to work policy and job retraining.

c. Communication This includes tool box safety meetings, supervisor meetings, management involvement, project/job set-up, job close-out, safety policies, safety procedures and job rules.

2.5 Insurance Agency/Insurance Company – Safety/Loss Control Program

Gribbins Insulation Company is covered by their insurance agency’s and company’s field inspection program.

Special Instructions:

1. Each location should pre-plan the “Loss Control” visit to best utilize the representative’s time.

2. Productively utilize the agency’s/company’s representative’s expertise during the visit.

3. Hold a brief re-cap meeting at the end of each visit to agree on the results.

2.6 Behavior Based Safety

1. Objectives a. Promote Behavior Based Safety observations by all employees in all

workplace environments. b. Collect and analyze data from the observation process. c. Increase individual safety awareness by providing positive reinforcement of

safe behaviors d. Address observed safety issues by providing recommendations to appropriate

level of management. e. Provide feedback from the analysis of BBS observations through the monthly

safety bulletins.

Policies, procedures, programs and discipline are any essential part of any traditionally good safety program. To create an even safer work environment, Gribbins Insulation will incorporate a behavior based safety program into our existing program. Gribbins Insulation Behavior Based Safety program will promote a safety culture minimizing “at risk behavior” through application of the Behavior Based Safety concept.

In general, the process of applying behavior based safety is:

1. Identifying safety related behaviors that are critical to excellent performance 2. Gathering data on workgroup safety excellence 3. Providing ongoing, two-way performance feedback 4. Removing system barriers to continuous improvement


BBS concepts change at-risk behaviors. Changing your behaviors is what it’s all about. Keeping a high level of safety awareness is key to achieving this. Safety awareness is good, but unfortunately it is difficult to maintain a high level of awareness during routine daily activities. By recognizing the “why” we can develop programs to increase employee awareness and encourage reduction of specific at-risk behaviors.

Safety awareness is good, but you need behavior modification to have lasting change. Lasting change occurs when you can see value in safety. For example, why do you wear a seat belt? You have to see value in safety protection for your efforts to be habitual.

Another avenue to lasting change is to have a belief in the process. Just like with your kids, setting a good example is also an effective tool in establishing behavior modification.

The principles of Behavior Based Safety include supplementing a good, existing safety management approach. It does not replace it. Encouraging employee involvement in the process. It is an ongoing process not another “typical” safety process. And encourages personal responsibility and more importantly, interpersonal interaction about safety. (Communication)

In a traditional safety program policies and procedures are more reactive occurring after an incident has already occurred. The BBS concept is more proactive trying to get employees to take care of problems before and incident occurs.

The ABCs of BBS are the Antecedent, Behavior and Consequence. The antecedent is something that comes before and triggers a behavior. It is anything that prompts us to act. The behavior is what we do and how we act. And the Consequence is what follows or happens as a result of the behavior.

2. Definitions

a. Behavior Based Safety – The science of people’s behaviors associated with their surroundings, choices, and actions regarding safety. The study of why people take chances with their safety and what drives them to take those chances.

b. At risk – Action or condition that poses a potential danger. Contributes to most incidents often a result of outside influence. BBS doesn’t wait till an accident occurs it addresses behavior before an accident happens.

3. Examples of Safety Behaviors a. Positive Behaviors


i. Changing the way you usually do your job to a safer method. ii. Reminding co-workers about taking safety precautions and wearing

ppe motivating them. iii. Consistently wearing your PPE iv. Consistently using safety program procedures v. Providing feedback to supervisors regarding other employee’s

safety issues. b. Negative Behaviors

i. Not wearing ppe or using general safety equipment ii. Not following safety procedures/programs (welding procedures,

ladder safety, and tool safety). iii. Taking shortcuts.

4. Observation

New employees will be made aware of our Behavior Based Safety Program through new hire orientation. Employees that are interested and want to participate in this process will then be trained through Gribbins Insulation Behavior Based Safety Observation Training Program. Once employees have been trained it will be the employees responsibility to conduct observation on fellow Gribbins Insulation employees on their job site and give feedback and one-on-one coaching to the employees they observed. This in turn will heighten safety awareness of hazards that exist on the job.

Once an employee completes an observation they can either mail the observations back to the safety department at the end of the month or send them back to the office through truck drivers or other office personnel. Once the observations are collected they will be entered into a spreadsheet, which will be used to analyze the data to find prevalent at risk behaviors and the barriers that cause the types of behavior. The information that is taken from this analysis will be sent to employees through a monthly safety bulletin.

A monthly behavior based safety committee meeting will be held to analyze data, review safety opportunities shared, and discuss any other relevant safety issues. The committee will consist of field employee and management personnel. Once this meeting is conducted the meeting minutes along with the data will be forwarded to upper management.

5. Observation Checklist


Through our observation forms, we are looking at 4 points of infuses: tools and equipment, people, PPE and work environment/procedures. (See Appendix 2.2) This is not an exhaustive list just a template of hazards to be aware of.

Tools and equipment: examines the proper selection, use, transportation, travel, conditions, process equipment, storage, guards or other issues.

People: observes body mechanics, line of fire, pinch points, communication, pace, eyes on task/walking, carrying, handrails, material handling and lifting.

PPE: examines eye/face protection, hand protection, head protection, fall protection, foot protection, protective clothing, respiratory protection and hearing protection.

Work environment/procedures: observes job surroundings, proper lighting, housekeeping, barricades, jobsite information, permits, inspections, and first aid kits.

When doing observations, if any of these items are found to be at-risk they should be marked in the “at risk” box to the right. The observer must then find out what barrier led to that at risk behavior and document it on the observation form.

Barriers include:

Procedures – are tangible thing that can be corrected by changing the way we do things including schedule.

Culture – would be an at-risk behavior that is a long established practice. Equipment/facility – would be an acknowledged at-risk condition and or

equipment. Personal Choice – is when a worker has adequate skills and resources, but

chooses to work at-risk to save time or effort. Personal Factors – are intangible things that deal with personal issues, such

as, fatigue, stress, medication or lack of attention. Training – would be if the employee did get enough or the right type of

training to do the job safely and correctly. Unsure of / Disagreement of Safe Practices - is when there is a disagreement

on a work rule or the worker does not know the rule or how to interpret it.

6. Accident Investigation / Root Cause

When an accident or incident occurs, an accident/incident investigation will be complete along with a guide for finding the root cause of the accident. It is important to ask why when trying to find the root cause. The first question should be “Why did this accident/incident occur?” Once this question has been answered ask “why” to the answer at least five more time to come to the true root cause.


Ex. Why did the employee receive a steam burn to his arm and shoulder? Because the gasket blew out on a flange coupling near him. Why did the gasket blow out on a flange coupling near him?

Because the safety valve didn’t pop off to release excessive pressure in the steam line.

Why didn’t the safety valve pop off to release excessive pressure in the steam line?

Because the valve was not inspected. Why wasn’t the valve inspected? Because there was no procedure calling for the valve to be inspected. Why wasn’t they’re a procedure calling for the valve to be inspected? Because no one thought it was important.

Doing this type of accident investigation will not only solve the problem temporarily, but finding the root cause will allow programs or procedures to be put in place to correct the problem permanently.

Use a structured tool to help you identify root causes an example is this is the Guide for Identifying Causal Factors and Corrective Actions. Look for causes relating to equipment, environment, management, and people. Generally there is more than one root cause to the incident and you will be able to identify a clear combination of root causes. If you have more than three root cause combinations, your analysis and fact finding may not have been through enough.

7. Safety Opportunity Shared

Another integral part of the BBS Program is safety observations shared. This allows employees to relay near misses, safety concerns or suggestions for the behavior based safety committee. This process should not be used if there is a situation that requires immediate attention for an unsafe act or condition these should be reported to site supervision or the safety department. But for instances where there is a near miss that happens or an unsafe act that is observed then the form can be filled out and the information will be relayed back to other employees so they can learn from it. They should be turned into the foreman on the job and returned to the safety department. (See Appendix 2.3)


Section 3

Accident Reporting and Recordkeeping

3.1 Accident Reporting

1. Cases that Require Reporting

A. All near misses, incidents, first aids, injuries or illnesses requiring medical attention and property damage incidents must be reported immediately.

B. All incidents no matter how insignificant they seem shall be reported. C. These incidents shall be reported to the jobsite foreman immediately.

Once the foreman is informed they must contact the safety department within 30 minutes.

2. Catastrophic Events or Fatality A. Management must be notified immediately. B. OSHA must be notified within 8 hours of an accident which results in a

fatality or the hospitalization of 3 or more employees. The employer must orally report the incident to (317) 232-2693 or 1-800-321-OSHA. This requirement also applies to each fatality or hospitalization of 3 or more employees that occurs within 30 days after the work related accident.

C. The notification to OSHA must include: name of the establishment, location and time of incident, number of fatalities, number of hospitalized employees, a company contact person, a company telephone number, a brief description of the incident.

3.2 Recordkeeping Legal Requirements

1. Gribbins Insulation’s Safety Manager is responsible for maintaining a log of all recordable occupational injuries and illnesses. The OSHA 300 form is used for that purpose.

2. Key Points Regarding Recordkeeping a. OSHA Form 300 – This form must be used to record work related injuries

and illnesses. It must be maintained for five years following the end of the calendar year which the injuries relate.

b. OSHA Form 300A – This form is a summary of the OSHA 300 form. This form must be posted on the job sites from February 1st thru April 31st. Even if there were zero recordables, a form must be posted with all the zeros indicated. On sites that we have no place to post this, the foreman must place a copy in the back of the safety manual.


c. OSHA Form 301 – All recordables listed on the OSHA 300 Form must be supported by a completed OSHA Form 301 or a completed First Report of Injury Form (Worker’s Compensation Insurance Report). This means all recordables not just those that are compensable.

d. OSHA Form 300S – This is a survey form mailed by the states. It must be completed and sent back to OSHA.

e. Posters (Federal & State) – Posters concerning protection and obligations of employees under OSHA must be posted. This should be done in a reasonable number of places where all employees will be exposed to them. General Contractor’s posting of this is suitable.

f. Location of Records – “Logs must be available at Gribbins Insulation’s Main Office for inspection and copying by representative of the Department of Labor, D.H.E.W., or states accorded jurisdiction under the Act.” “Records for personnel who do not primarily report to work at a single establishment, such as traveling salesman, technicians, engineers, etc., shall be maintained at the location from which they are paid or based from which personnel operate to carry out their activities.” Although it is possible to prepare and maintain the log at another location, using data processing equipment if desired, a copy updated to within 45 calendar days must be present at all times in the establishment.

g. Establishment – A single physical location where business is conducted or where services or industrial operations are performed (for example: a factory, mill, store, hotel, restaurant, movie theater, farm, ranch, bank, sales office, warehouse or central administrative office). Where distinctly separate activities are performed at a single location, such as construction activities operated from the same physical location as a lumber yard, each activity shall be treated as a separate establishment. For firms engaged in activities which may be physically dispersed, such as agriculture, construction, transportation, communications and electric, gas and sanitary services, records may be maintained at a place to which employees report each day.

h. Work Environment – Comprised of the physical location, equipment, materials processed, or used, and the kinds of operations performed in the course of an employee’s work, whether on or off the employer’s premises.

i. Log Entries (OSHA Form 300) – Each recordable case must be entered within six (6) work days after learning of its occurrence. Enter the date of the work related accident which resulted in injury. For occupational illnesses, enter the date of the initial diagnosis or illness, or if absence from work occurred before diagnosis, enter the first day of the absence attributed to the illness which was later diagnosed or recognized.


“If, during the 5-year period the log must be retained, there is a change in the extent and outcome of an injury or illness which affects entries in Columns A, B, G, H, I, J, K or L the first entry should be lined out and a new entry made. For example: If an injured employee at first required only medical treatment, but later looses days away from work, the check in Column J should be lined out, and checks entered in Columns H and the number of lost work days entered in Column K. In another example: If an employee with an occupational illness lost work, returned to work, and then died of the illness, the entries in Column H and M should be lined out and the date of death entered in Column G. The entire entry for an injury or illness should be lined out if later found to be recordable. For example, an injury or illness which is later determined not to be work related, or which was initially thought to involve medical treatment, but later was determined to have involved only First-Aid.”

j. Days Away – Any day which involves days away from work, or days of restricted work activity, or both must be recorded since it actually involve one or more of the criteria for recordability.

k. Decision Authority on Recordables – See “A Brief Guide to Recordkeeping Requirements for Occupational Injuries and Illnesses.”

l. Days of Restricted Work Activity – Restricted work activity or part-time work after the date of injury constitutes a recordable injury/illness. “Enter the number of workdays (consecutive or not) for which, because of injury or illness: (1) the employee was assigned to another job on a temporary basis, or (2) the employee worked at a permanent job less than full time, or (3) the employee worked at a permanently assigned job, but could not perform all duties normally connected with it.”

m. Occupational Injury – Is any injury such as a cut, fracture, sprain, amputation, etc., which results from a work accident or from an exposure involving a single incident in the work environment. NOTE: Conditions resulting from animal bites, such as insect or snake bites or from one-time exposure to chemicals, are considered to be injuries. In addition, recordables include any accident involving loss of consciousness, restriction of motion, or transfer to another job.

n. Occupational Illness – Of an employee is any abnormal condition or disorder, other than one resulting from an occupational injury, caused by exposure to environmental factors associated with employment. It includes acute and chronic illnesses or diseases which may be caused by inhalation, absorption, ingestion, or direct contact.


The following listing gives the categories of occupational illness and disorders that will be utilized for the purpose of classifying recordable illnesses. For purposes of information, examples of each category are given. These are typical examples, however, and are not to be considered the complete listing of the types of illnesses and disorders that are to be counted under each category: Occupational Skin Diseases or Disorders – Include contact dermatitis, eczema, or rash caused by primary irritants, sensitizes or poisonous plant, oil acne, chrome ulcers, chemical burns or inflammation, etc. Dust Diseases of the Lungs (Pneumoconiosis) – Include Silicosis, Asbestosis, coal worker’s pneumoconiosis, byssinosis, siderosis, and other pneumoconiosis. Respiratory Conditions due to Toxic Agents – Include Pneumonitis, pharyngitis, rhinitis or acute congestion due to chemicals, dust, gases, or fumes, farmer’s lung, etc. Poisoning (Systemic Effects of Toxic Materials) – Include poisoning by lead, mercury, cadmium, arsenic, or other metals, poisoning by carbon monoxide, hydrogen sulfide, or other gases, poison by benzol, carbon tetrachloride, or other organic solvents, poisoning by insecticide sprays such as parathion, lead arsenate, poisoning by other chemical such as formaldehyde, plastics and resins, etc. Disorders due to Physical Agents (Other than Toxic Materials) – Include heatstroke, sunstroke, heat exhaustion, and other effects of environmental heat, freezing, frostbite and other effects of exposure to low temperatures, caisson disease, effects of ionizing radiation (isotopes, X-rays, radium), effects of nonionizing radiation (welding flash, ultraviolet rays, microwaves, sunburn), etc. Disorder Associated with Repeated Trauma – Include noise-induced hearing loss, synovitis, tenosynovitis and bursitis, Raynaud’s phenomena and other conditions due to repeated motion, vibration or pressure. All Other Occupational Illnesses – Include Anthrax, brucellosis, infectious hepatitis, malignant and benign tumors, food poisoning, histoplasmosis, coccidioidomycosis, etc.


3.3 Guidelines – Recordable Cases vs. First-Aid

1. For OSHA recordkeeping not all workers’ compensation claims are recordable cases. While worker’s compensation insurance pays for both First-Aid and medical treatment by a doctor, OSHA only requires you to log or record medical treatment cases.

2. Any industrial related illness, regardless of treatment administered or lost workdays, is recordable. (This would include welding flash burns, which are considered an illness by OSHA.)

3. Any industrial injury resulting in days away from work or days of restricted work activity should be recorded.

4. Lacerations, puncture wounds, etc., resulting in suture or cutting away of dead skin should be recorded.

5. Uncomplicated removal of foreign bodies such as by irrigation, may be considered First-Aid treatment and not recordable.

6. Tetanus shots and initial X-rays, unless rendered with other services indicating medical treatment, would not have to be recorded.

7. First degree burns usually receive First-Aid treatment and are not recordable. However, second and third degree burns normally require medical treatment and are recordable.

8. Applying hot or cold compresses or elastic bandages to muscle sprains, etc., on the initial visit to doctor’s office, or medical facility need not be recorded unless lost workdays are involved.

9. Pain relievers, muscle relaxants, etc., are First-Aid, only if they are non-prescription.

10. Examination of bruises, contusions, or abrasions by a doctor or nurse or medical facility need not be recorded unless further treatment or repeated visits are indicated.

11. Any injury incurred while participating in a company sponsored athletic contest or any other work related activity should be recorded. (This is assuming treatment exceed normal First-Aid).

Gribbins Insulation Company 2012 Page 4 -1

Section Four

Accident Investigation

4.1 What Should Be Investigated

An accident that causes death or serious injury obviously should be investigated as well as all lost time injuries and all OSHA recordables. All head and back injury cases must also be investigated. Investigation should also include near misses that might have caused death, serious injury, minor injuries or property damage such as: almost falling through a floor opening or breaking of a hoisting sling or a scaffold rope. These near misses are equally important from the safety standpoint. Accidents that cause damage to property or equipment should also be investigated.

Each investigation should be made by the end of the work shift and no later than 24 hours following the accident. A delay in investigating may permit important evidence to be destroyed or removed, intentionally or unintentionally. Also, the publicity value in the safety education of employees and supervisors is greatly increased by promptness.

Any epidemic of minor injury demands study. Dust particles in the eye or a scratch from handling metal may be a very simple case – the immediate cause is obvious and the loss of time may only be a few minutes. However, if cases of this or any other type occur frequently, an investigation should be made to determine the underlying causes.

4.2 Why Accidents Must Be Investigated

Accident investigation and analysis is one of the means used to prevent accidents. The more complete the information, the easier it will be for the individual responsible for safety to design effective counter measures. For example, knowing that 40% of the locations accidents involve ladders is not as useful as knowing that 80% of the ladder accidents involve broken rungs.

By analyzing the causes of accidents, positive actions can be taken to prevent similar type injuries occurring time and time again. The information from the reports can also be used very effectively in the employee safety training program.

4.3 Fact Finding

For purposes of accident prevention, investigations must be fact finding, not fault finding; otherwise, they may do more harm than good.


NOTE: “The Accident/Injury/Illness Investigation” report is not the same as the “First Report of Injury” report. It is a separate report that probes much deeper to determine all the causes and events of the accident, and also recommends corrective actions to prevent recurrence of similar accidents. The report requires a review by Management.

4.4 How to Conduct an Accident Investigation

1. Immediate Actions Following an Accident a. Assist Injured Employee – When an employee is injured, take every action

to get immediate attention. If the employee can move freely, the supervisor should assist him/her to the dispensary or hospital emergency room. If in doubt about moving the injured, always keep the employee lying down, warm and comfortable, then get medical aid. A person having First Aid training should give immediate assistance while others get profession medical help.

b. Seal Off Area – It might be necessary to seal off an area until you are satisfied that a hazardous situation or hazardous piece of equipment has been corrected or secured. This can be done by locking out, barricading, placing a guard on duty, etc., to protect the area.

2. Who Investigates a. Management Function and Responsibility

i. A supervisor or manager has a personal interest in and responsibility for all assigned areas.

ii. It is the supervisor’s area, he makes the decisions. He has contact with the people, knowledge of people and events.

iii. Information is more readily available to the supervisor. iv. The supervisor and manager are in a position to correct hazardous

conditions and reduce safety deficiencies. b. Employee(s) Function and Responsibility

i. Employee involved with the incident will assist in the investigation. ii. Employee witnessing the incident will assist in the investigation.

3. When to Investigate Part of the success of an accident investigation depends on the initial immediate response to the accident. If possible, the injured employee and all witnesses should be interviewed as soon as possible following the accident while details are fresh in their minds. All accidents should be investigated no later than 24 hours after occurrence.

4. How to Investigate a. Interview the injured employee b. Interview witnesses


c. Inspect the area, draw your own conclusions d. Look beyond the obvious e. Determine direct causes f. Determine root causes g. Start accident investigation report

5. Interview Injured Employee If possible, get all pertinent details from the injured employee as to how and why the accident occurred.

6. Determine Witnesses Canvass the scene of the accident asking all employees if they observed what happened. Put them at ease. Let them know that you are only trying to find out what happened so steps can be taken to keep the accident from happening again.

7. Interview Witnesses Ask the witness (es) what they observed and have them complete witness section of accident investigation form. They should write down how the accident occurred and what equipment was being used.

8. Determine How Accident Occurred This determination can be made by interviewing the injured employee, witnesses and examining the area or the equipment.

9. Correct Problem if Possible Many times the immediate supervisor is in a position to take immediate action in rectifying problems which can cause a recurrence of an accident. This is definitely so with problems of a minimal nature. However, a supervisor is often able to obtain the assistance of others in correcting more serious and complex problems through his prior working relationships.

10. Record the Above Facts – Start Filling Out the Form Record on a pad of paper all details or information obtained from interviewing the injured employee and the witnesses. Including your own personal observations, then commence completing the accident investigation form.

11. Why Investigate Accidents? a. To identify causes and take corrective actions. b. To prevent similar occurrences. In doing so we:

i. Reduce cost resulting from Worker’s Compensation and loss of manpower;

ii. Increase employee morale. iii. Reduce legal ramifications iv. It’s the moral thing to do and just good business

12. What to Investigate for


The causes of all injuries can be divided into two categories: unsafe physical conditions and unsafe personal acts.

a. The following are the seven categories in which unsafe physical conditions may be grouped:

i. Inadequate mechanical guarding ii. Defective condition of equipment (i.e. rough, sharp, slippery,

decayed, corroded, frayed, inferior, composition, cracked), as ladder, floors, stairs, piping, and so forth.

iii. Unsafe design or construction iv. Hazardous process, operation or arrangement (i.e. unsafe pilling,

stacking, storage, congested aisle space, crowding, overloading, and so on.

v. Inadequate or incorrect illumination vi. Inadequate or incorrect ventilation vii. Unsafe dress or apparel (loose clothing, absence of or defective

gloves, aprons, shoes, respirators where use is required) b. The following are eight classifications of unsafe personal acts which have

resulted in injury: i. Working unsafely (i.e. improper lifting, hazardous placement,

incorrect mixing of material, performing maintenance or repairs on moving equipment, working under suspended loads, failure to take heed of warnings, and so on).

ii. Performing operations for which supervisory permission has not been granted.

iii. Removing safety devices or altering their operation so that they are ineffective.

iv. Operating at unsafe speeds. v. Use of unsafe or improper equipment (i.e. using a chisel with

“mushroomed” head). vi. Using equipment unsafely. vii. Horseplay, teasing, abusing and so forth. viii. Failure to use safe attire or personal protective devices.

13. Look Beyond the Obvious a. Don’t be satisfied with what appears to be the obvious. b. Dig deep to find the root cause of the accident. c. Look beyond employee carelessness. d. Do more than instruct the employee to be more careful. Try to find the

problem, and then solve it. e. Don’t be satisfied until you are sure it won’t happen again. f. Don’t settle for the easy solution.


4.5 Step-by-Step Use of Form, Parts I-V (See Appendix 4.1, 4.2, 4.3)

1. Part I a. Location: Give the name of the operating location b. Job No.: Give specific job number (if applicable). c. Employee: Print the full name of the injured employee including the

middle initial. d. Phone No.: Give employee’s home phone number e. Address: Give employee’s home address including city and zip code. f. Date of Birth: Give employee’s date of birth – month/day/year. g. Age: Give employee’s current age. h. Sex: Give appropriate sex of injured employee – M:Male, F:Female i. S.S#: Give the employee’s social security number j. Shift: Check the appropriate box: Day, Evening, Night k. Date of Hire: Give most recent date of hire – month/day/year. l. Occupation: Give injured employee’s occupation. m. Date of Injury: Give the date of injury – month/day/year. n. Time of Injury: Give the time the injury occurred. o. Location of Incident: (Be precise) – Describe in detail the location where

the accident occurred. Describe the location with such detail that a stranger could find the accident scene. Poor Example: Parking Lot Good Example: Extreme Northwest corner of the employee parking lot at Building 5000, Park Road, Detroit, MI

p. Date Reported: Give the date the accident was reported to Gribbins Insulation Company – month/day/year.

q. Time Reported: Give the time the accident was reported to Gribbins Insulation Company.

r. Reported to Whom?: Print the full name of the person who the injury was reported to.

2. Part II a. Was employee give First Aid: Check the appropriate box, Yes/No, to

indicate if the injured employee received First Aid on the jobsite. b. Sent To: Check the appropriate box if the employee was sent off site for

further treatment of his or her injury. c. Was employee placed on transitional duty?: Check the appropriate box,

Yes/No. d. Will employee lose time from work?: Check the appropriate box, Yes/No

(This information must be obtained from the medical provider).


e. If lost time, approximate days ____: Give the approximate expected lost days (this information must be obtained from the medical provider).

f. Was treatment refused?: Check the appropriate box, Yes/No if the employee refused medical treatment.

g. Name, Address and Telephone No. of Clinic: Self explanatory. 3. Part III

a. Name, Address and Telephone No. of Witness(es) (Witness statements should be written in section V): List the names, addresses and phone numbers of each witness to the accident. Every attempt must be made to poll those working in the vicinity of an accident to obtain witnesses. Other than the injured employee, witnesses are your best source of information regarding how the accident occurred. Witnesses should be put at ease and explained that their information is important in determining just what happened, so steps can be taken to keep the accident from reoccurring.

b. Describe in detail what the employee was doing at the time of injury: Describe in sequence how the accident occurred. Identify the equipment involved, what the operation was, etc. Tell a complete story. Poor example: Frank Smith was working on a scaffold and he fell. Good example: Frank Smith was working on a metal frame scaffold approximately 10’ in height. Frank was installing insulation on the No. 6 main steam line. The scaffold did not have handrails installed and Frank was not using the required fall protection device. Frank stepped backwards off the scaffold and fell 10’ to the concrete floor below. NOTE: This is one of the most important parts of this form. Placing all the details on paper will do much to help you and others in determining causal information.

c. Did employee wear personal protective equipment?: Check the appropriate box, Yes/No and then list the personal protective equipment being worn.

d. Part of Body: Check the appropriate box and write in what side of body, R:Right, L:Left

e. Type of Injury: Check the appropriate box. f. What type of training has been conducted to prevent recurrence? Self

explanatory. g. Describe the act/condition that contributed to the incident: This section

requires that you list the act(s) that caused the accident and/or the condition(s) that caused the accident. (The back of the accident investigation form has a list of choices for answering this question. These choices cover most but not all of the accident situations.)


h. Corrective action(s) taken: Describe the corrective actions you are taking. i. Investigated by: Name of the person who conducted the accident

investigation. j. Date: month/day/year the accident investigation was completed.

4. Part IV a. Employee’s Statement

Employees should describe in detail exactly was he/she was doing at the time of the incident and how the incident occurred. Employee should then sign and date this section.

5. Part V a. Witness Statement

Witness(es) should describe in detail exactly what the employee was doing at the time of the incident and how the incident occurred. Witness(es) should then sign and date this section.

4.6 Instruction for Management on Completing the “Manager Review”

1. When you receive an accident investigation report from the supervisor, give it your immediate attention and review it thoroughly.

2. Determine if the information on the report is accurate and complete. 3. Determine if the immediate supervisor has adequately transcribed the

information onto the Accident Investigation Report; assess if the causes have been thoughtfully determined and listed; and make a judgment as to whether the recommended corrective actions are practical. Evaluate the report; if you are not satisfied with the contents, give it back to the supervisor for further investigation.

4. If you are satisfied and you find your conclusions and recommendations to be similar to those of your supervisor, so indicate on the report and do the following:

a. Determine what corrective action(s) should be carried out. b. Determine who specifically should carry out your instructions. This

is your responsibility. No one is in a better position than you to initiate corrective actions.

c. Estimate the completion date for each. This should be reasonable, yet appropriate to the exposure to the hazard.

5. Use the comment section for any additions you might wish to make to the report.

6. Sign and date the report. Again this report could be used as a legal document.

7. You should establish some type of a follow up system to ensure that all corrective measures have been taken care of.


4.7 Step-by-Step Use of Form – Part VI (Management’s Review)

1. Are you satisfied with your review of Parts I-V that the accident has been thoroughly investigated?: If after your review and you own personal investigation, you find that the immediate supervisor did not perform a good investigation return it to him/her to secure more information.

2. As a result of your review have you identified any additional reasons why the accident occurred?: This is where you should list any reasons for the occurrence that were not discussed in the supervisors investigation.

3. Corrective Actions: List the corrective actions you are taking to keep this accident from happening again.

4. Who are you making responsible for corrections?: List the name(s) of those persons who will be responsible for carrying out the corrective actions.

5. Signature of Supervisor and Date Signed: Self explanatory. 6. Manager Comments: This comment section should include any additional

information relating to the accident, causes and/or corrective action from the manager’s perspective.

7. Signature of Manager and Date Signed: Self explanatory (Extremely important).

4.8 Guide for Identifying Root Causes

1. Once the accident investigation is completed the Guide for Identifying Root Causes shall be completed to determine the root cause. (See Appendix 4.4)

2. This step is extremely important to ensure that what really caused the accident can be corrected so the type of incident does not occur again.


Section Five

Governmental Regulation Compliance

In the event OSHA shows up on a jobsite, employees must inform the foreman immediately and then the foreman must contact the Safety Manager. The Safety Manager or Safety Coordinator shall make every attempt possible to be onsite during an OSHA inspection.

5.1 Role of Management Representative

While sharing OSHA’s goal of maintaining a safe place of employment, we should remain mindful that OSHA is a regulatory agency. The OSHA inspection is the first stage of the enforcement process which always presents the possibility of ripening into litigation.

In developing these guidelines, we address only involuntary inspections.

Highlights of the management representative’s responsibilities are as follows:

1. Be assured in advance that all members of management understand your role as Gribbins Insulation Company spokesman.

2. Consult Management before agreeing to the scope of the inspections. 3. Understand and comply with the guidance for responding to OSHA requests for

information. 4. Be most selective in permitting cameras onsite. Also, ask that the Compliance

Officer label his notes “CONFIDENTIAL”. 5. Take detailed notes. 6. Insist on being present during all interviews with salaried personnel. 7. Do not take any action in response to a citation without first consulting

Management.

5.2 Presenting Credentials

To begin a typical inspection, the OSHA Compliance Officer presents himself at the main entrance, displays his credentials and asks to meet the appropriate management representatives. Verify the Compliance Officer’s identity by closely scrutinizing his credentials, and if necessary, calling his local office. He should state the reason for the visit and outline in general terms the scope of the inspection. He will often provide copies of the applicable laws and safety and health standards and a copy of an employee complaint, if one is involved.


5.3 Scope of Inspection

An OSHA inspection may be limited or broad in scope, the latter often referred to as a “wall-to-wall” inspection. The limited inspection may be an employee complaint investigation, reportable accident investigation, or a follow-up visit to verify abatement for a prior citation. OSHA frequently will attempt to broaden what otherwise should be a limited inspection.

The scope of the inspection should be agreed to by the Compliance Officer at the outset. To aid in avoiding potential differences with OSHA, immediately telephone Management as soon as OSHA appears. Early telephone consultation has proven to be most helpful in getting organized.

For a limited inspection, escort the Compliance Officer as directly as possible to the area described in the complaint, site of the accident or site of the earlier violation. If he shows signs of wanting to broaden the inspection, tell him that Management approval is necessary and contact Management.

5.4 Employee Representative

The Compliance Officer will ask you to arrange for an employee representative to accompany him during the walk-through. Actual selection of the employee representative is made by the employees, usually through the union, if applicable. An employer can insist that only one employee representative accompany the Compliance Officer during the walk-through, which should be the case in the absence of special circumstances.

5.5 Employee Interviews

The Compliance Officer has the right and is encouraged by OSHA to confer privately with hourly employees. The Act grants this right of privacy in order to encourage employees to talk freely about safety conditions at your location without the hesitation that might exist if a management representative were present.

You should, however, ask to be present at any conversation with hourly employees. The burden should be placed on the Compliance Officer to determine whether the conversation should be a private one. If an hourly employee requests that the interview be held in private, that request should be honored. The interview should be scheduled to afford minimum interference with the duties of the employee.

You should be present at all conversations with salaried employees. If OSHA objects, immediately contact Management.


5.6 Note – Taking

Detailed inspection notes are most helpful should Gribbins Insulation Company later be involved in an OSHA hearing. Notes should include, but not necessarily be limited to the following:

1. Describing all areas inspected. 2. Rationale for all violations and “possible violations” noted by OSHA. 3. Highlights of all employee interviews (when possible) and any other information

conveyed to OSHA. 4. All requests for information beyond the OSHA log sheets and injury reports. 5. Any corrective actions taken during the inspection (see appropriate section of

guidelines). 6. Details of any hygiene sampling.

5.7 Trade Secrets / Photographs

Photographing the premises is not legitimate grounds for an objection unless there is a photograph of a trade secret. You should try to photograph every condition as photographed by the Compliance Officer. If the Officer seems to be taking photographs of conditions from misleading perspectives, then you should photograph the condition from both the proper perspective and the misleading perspective. If a statement made by the Compliance Officer demonstrates that he is misinterpreting a condition or situation, try to correct his understanding.

Section 15 of the Act requires OSHA to treat any trade secrets in confidence. The Compliance Officer is instructed to preserve the confidentiality of information and investigations which might reveal a trade secret. A Compliance Officer who discloses a trade secret is subject to fines and/or imprisonment. If the Compliance Officer wants to photograph or sketch a secret process, explain to him that it is a trade secret area and a company policy strongly prohibits photos of the area. Ask him to determine if he really needs the photograph. Often, in light of a request, he will determine it is not necessary. If the Compliance Officer insists on a photograph, determine exactly what he wants and tell him Gribbins Insulation Company will take a picture, have it approved and supplied to OSHA. If that is not acceptable, request Management to contact legal counsel for guidance and the attorneys will attempt to negotiate this item with an OSHA attorney. Do NOT, however, let the Compliance Officer take the picture or leave with the film if a picture is taken before you are aware it is a trade secret area.

5.8 Correcting Apparent Violations

If apparent violations may be corrected easily (blocked aisle, unsafe floor surfaces, extension cords, etc.), the inspector may suggest immediate correction. If this


is done, it should be noted and will help in judging the employer’s good faith and compliance. Even if corrected, the employer may still receive a citation and a proposed penalty. Clearly, you must be familiar with OSHA standards to understand and observe what constitutes and “apparent violation”. If the least bit in doubt, call Management before making changes.

5.9 Records Access / Information Requests

During a routine inspection, the Compliance Officer will ask for the following records:

1. Form #200: Log of Recordable Occupational Injuries and Illnesses 2. Form #101: Supplementary Records 3. Form #200S: The Annual Summary 4. Any records of exposure to toxic substances and harmful physical agents

which are required to be maintained by the standards and regulations.

Any requests from the Compliance Officer for records or information beyond those listed requires Management’s approval. The Compliance Officer may also request copies of specific programs from our Safety Manual (ie., respirator program, Hazard Communication Program) and prior to complying with the request you must contact Management for approval.

Often the Compliance Officer will ask to see the Safety Manual. We strongly oppose this. The Safety Manual would be considered by OSHA as setting a higher standard of safety for Gribbins Insulation Company compared to employers generally. Any departure from Gribbins Insulation Company Safety Manual might result in a citation for violating the “general duty clause”, the catch-all clause in the Federal Act for any condition OSHA thinks might be unsafe.

5.10 Industrial Hygiene Sampling

OSHA regulations contain exposure limits for a great number of airborne contaminants. Even so, OSHA will sometimes ask to conduct sampling for some airborne contaminant not presently covered by OSHA regulations. We strongly advise that you not permit OSHA to sample for any airborne contaminant without OSHA first supplying the following information:

1. The sampling method. 2. Sampling time. 3. Job functions to be sampled. 4. Specific regulatory exposure level.


If the Compliance Officer cannot, or will not, supply this information and still insist on sampling, immediately contact Management.

5.11 Closing Conference

Upon completion of the inspection, the Compliance Officer will request a closing conference with the employer. The designated employee representative will normally be invited to the closing conference.

Prior to attending the closing conference, you should converse with all salaried personnel who will be in attendance at the meeting. (We suggest limiting such attendance to reduce the possibility of confusion and to avoid the appearance of “leaning” on the Compliance Officer.) In any event, as the management representative, you should remind other salaried personnel of the importance of following your lead as spokesman for Gribbins Insulation Company.

The Compliance Officer will review all possible violations and determine the time Gribbins Insulation Company will be given to abate each alleged violation. For each item, ask the Compliance Officer to specify:

1. The hazard created, 2. The job functions exposed to the hazard, 3. The standard alleged to be violated, 4. What possible means of abatement he suggests.

In estimating time for abatement, be sure to make it clear that Gribbins Insulation Company is not admitting any violation other than those apparent violations corrected ruing the walk-through. Request as much time as is reasonably needed.

5.12 The Citation Arrives

You should immediately forward a copy of the citation to Management since there is a limited time period for filing a notice of contest. The citation is the first step of potential litigation. Therefore, you should NOT communicate with OSHA, and you should NOT take any corrective action without first securing at least telephone approval from Management.

At this point, Management will notify legal council (if necessary) and will coordinate all future actions pertaining to the citation including direction to be given to the location personnel. If you are contacted by the agency, you should refer them to Management and not discuss the citation or any actions with them.


5.13 Fatality

In case of a fatality at your facility, contact Management as soon as possible. Management will assist you in every way possible to assure that limited problems occur during a very difficult time.

5.14 Checklist of Employer Responsibilities (U.S. Dept. of Labor)

1. Be aware that you have a general duty responsibility to provide a place of employment free from recognized hazards and to comply with occupational safety and health standards promulgated under the Act.

2. Familiarize yourself with mandatory occupational safety and health standards. 3. Make sure your employees know about OSHA. 4. Examine conditions in your work place to make sure they conform to applicable

safety and health standards. 5. Remove or guard hazards. 6. Make sure your employees have and use safe tools and equipment, including

required personal protective gear, and that they are properly maintained. 7. Use color codes, posters, labels or signs to warn employees of potential

hazards. 8. Establish or update operating procedures and communicate them so that

employees follow safety and health requirements for their own protection. 9. Provide medical examinations when required by OSHA standard. 10. Keep required OSHA records of work related injuries and illnesses and post the

Annual Summary from February 1st through April 30th of each year. 11. The U.S. Department of Labor’s Occupational Safety and Health Administration

(OSHA) requires that within 8 hours of an accident which results in a fatality or the hospitalization of 3 or more employees, the employer must orally report the incident to the nearest OSHA Area Office or by using OSHA’s Toll-Free Hotline (1-800-321-OSHA).

12. Post in the workplace the OSHA poster informing employees of their rights and responsibilities.

13. Advise OSHA Compliance Officers of authorized employee representatives to permit their participation in the inspection walk-through. If there are not such representatives, allow a reasonable number of employees to confer with the Compliance Officer during the walk-through.

14. Do not attempt to discriminate against employees who properly exercise their rights under the Act (such as filing a complaint).

15. Post OSHA citations of violations of standards at the work site involved.


5.15 Types of OSHA Violations

1. De Minimis Where a violation of an OSHA standard is not immediately or directly related to safety or health, OSHA normally issues a notice of De Minimis violation. This is not a citation, and it involves no fine. There is no abatement and no further enforcement, even if the employer does not correct the De Minimis condition. An example of a De Minimis notice would be where the height of letters on an exit sign are not in strict conformity with the size requirements of a standard.

2. Other This type of citation is issued in situation where an accident or an occupational illness resulting from a violation of a standard would probably not cause death or serious physical harm, but which would have a direct or immediate relationship to the safety or health of employees. Examples of a non-serious violation would be the lack of guardrails at a height from which a fall would probably result only in mild sprains or cuts and abrasions.

3. Serious A serious violation exists if there is a substantial probability that death or serious physical harm could result from the condition which exits, or from one or more practices, operations or processes which have been adopted or are in use. The inspector need only prove that an accident which have resulted from violation of a regulation would have a substantial probability of resulting in death or serious physical harm; the inspector is not required to prove a substantial probability of an accident occurring.

4. Willful A willful violation exists under the Act where evidence shows that the employer committed an intentional and knowing violation of the Act and the employer is conscious of the fact that what he is doing constitutes a violation of the Act, or even though the employer was not consciously violating the Act, he was aware that a hazardous condition existed and made no reasonable effort to eliminate the condition.

5. Repeated A repeated violation exists, where, upon re-inspection, an employer is found in violation of a section of the standard, regulation, rule, or order violating the general duty clause for which he has previously been cited. Understandably, a repeated citation will assess considerably heavier penalties than the original citation.

6. Failure to Abate In this situation, an employer is found on re-inspection to have previously cited conditions uncorrected. As with repeated citations, failure to abate citations will assess heavy penalties.


Section Six

Emergency Medical Treatment

6.1 First Aid Kits

Items required in the First-Aid kit include:

1. Recordkeeping Form* 2. Small Scissors 3. Tweezers or Splinter Forceps 4. Towelettes 5. Gauze Squares (2” x 2”, 4” x 4”) 6. Large Gauze pad for compression 7. Roll gauze of Kling 8. Adhesive Tape 9. First-Aid Cream 10. Eye Wash Solution 11. Ammonia Inhalant 12. Assorted Band-Aids 13. Mouthpiece (for administering CPR) 14. Surgical Rubber Gloves 15. Closeable Container for contaminated items (Bloodborne pathogens)

*Where jobs are large enough to warrant a First-Aid station, either by us or others, a record shall be kept on all First-Aid cases. For each First-Aid case the following information should be recorded:

1. The date and time of the injury or illness

2. The name of the person

3. Treatment/Disposition

4. The person providing care

The equipment manager checks each First-Aid kit for its proper contents before it is sent out to a new job. It is the responsibility of the individual trained in First-Aid or foreman to weekly check the contents of the First-Aid kit to assure all items are replenished if used.

Commercial First-Aid kits are available and generally acceptable, but often contain too few items that are used often and many items which will never be


used at all. The materials must be individually sealed packages stored in a weatherproof container.

In areas where employees eyes or body many be exposed to injurious corrosive material, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.

6.2 Requirements for Personnel Trained in First-Aid

1. OSHA Standard 1926.50(c) states: In the absence of an infirmary, clinic, hospital or physician that is reasonably accessible in terms of time and distance to the work site, which is available for the treatment of injured employees, a person who has a valid certificate in First-Aid training from the U.S. Bureau of Mines, The American Red Cross or equivalent training that can be verified by documentary evidence, shall be available at the work site to render First-Aid.

2. If job site First-Aid services are provided by others, you can waive the above standard provided:

a. The personnel are available to you at all times for emergency treatment. b. That at all times you know the names of the personnel and how and where

to contact them. 3. Gribbins Insulation Company will at all times provide an employee that has been

trained in first aid and CPR at a jobsite. The majority of the time this employee will be the foreman of the job.

4. All foreman or potential foreman shall be trained in First-Aid every three years and CPR every year.

6.3 Use of Hospitals, Local Physicians and Ambulance Services for Transporting Injured Employees

Normally, the easiest means to procure medical care would be to use a local hospital emergency room or clinic. Before starting work at any job location, the supervisor/foreman should determine the closest source to be utilized, and the name and address, phone number, and directions must be posted at the jobsite.

If hospital care is not available, arrange for treatment from a local physician or clinic. Obtain the name, address, phone number and directions. Check to make sure services are available during the days and hours being worked. It is desirable to contact the doctor to explain the nature of the work and the type of injuries that are likely to occur. If the owner or prime contractor has arranged for treatment from a local physician or clinic, this also will be acceptable to us.


6.4 Procedure for Transporting Injured Employees

If an employee is ill or injured, the person best qualified must make the decision whether to call for a rescue squad/ambulance, or to transport the person by company or private vehicle to a source of medical care. The most conservative means of transportation should be used, and an ambulance or rescue squad should be called if there is any doubt at all about the advisability of transporting the employee.

Employees who are ill or injured, but are conscious and have only minor illnesses or injuries and are able to move about under their own power, can be transported to the local emergency room or clinic by whatever mode of transportation is available, including company vehicle or private automobile.

Use of Private Car or Job Truck: One or more personnel should be designated for this responsibility. Vehicles to be used must be in safe operating condition. Drivers must be legally licensed and know to be safe drivers. They should be cautioned to observe all road signs and traffic regulations while transporting the injured, and be previously knowledgeable of the location of the hospital, clinic or physician.

6.5 Occupational Exposure to Bloodborne Pathogens

OSHA standard 29 CFR 1910.1030 addresses employee exposure when employees are trained in First-Aid and designated to render First-Aid assistance as requirements of their job. Even though First-Aid trained personnel are not required to administer First-Aid treatment, we have included the following for the personal protection of these employees.

Gribbins Insulation Company’s Safety Manager is responsible for maintaining medical and training records and has the overall responsibility for the effectiveness of this program. This program shall be updated annually or when changes are made to the standard.

All bodily fluids will be considered potentially infectious.

1. Training and Medical Services a. Our employees will be trained in First-Aid by the U.S. Bureau of Mines,

The American Red Cross or equivalent before initial assignment. b. This training addresses the issue of bloodborne pathogens as it relates to

administering First-Aid. c. Bloodborne pathogen training will be provided thereafter on an annual

basis. Training records will be kept for at least 3 years.


d. A copy of Gribbins Insulation Company’s bloodborne pathogen program will be available at every jobsite for employee use. This is located in the Safety Manual.

e. The hepatitis B vaccine, post exposure evaluation and follow up visits are available to all employees, at no cost to the employee, if he/she has an occupational exposure. If employees decline this vaccine at the time of hire they shall complete the hepatitis B vaccine declination. (See Appendix 6.1)

2. Protective Equipment a. Gauze pads are provided as required items in our First-Aid kits. These

pads are required to be used as a barrier between the bleeding injured person and the person rendering First-Aid.

b. Surgical rubber gloves are required in all First-Aid kits and are required to be used whenever administering First-Aid on a bleeding person.

c. Mouthpieces are required in all First-Aid kits and are required to be used when administering CPR

d. This PPE will be provided to employees at no cost to the employee. 3. Hygiene Practices

a. After First-Aid is provided to a bleeding injured person, the person rendering First-Aid shall wash his/her hands with soap and water as soon as possible. If hand washing facilities are not available, we shall provide an antiseptic hand cleaner in conjunction with clean cloth/paper towels. (When hand cleaners are used, hands must still be washed with soap and water as soon as feasible.)

b. All equipment or environmental surfaces shall be cleaned and decontaminated after contact with blood or other infectious materials.

4. Medical Records a. A record will be kept on any employee with an occupational exposure in

accordance with CFR 1910.1020. These medical records will be kept for the duration of employment plus 30 years.

b. The record will include: dates and contents of training, names and job titles of persons attending.

c. Records will be available to the employee upon request. d. Transfer of records will only be done with the written consent of the

employee. 5. Housekeeping

a. Each First-Aid Kit must contain a closeable container for blood contaminated items. It must be constructed to prevent leakage, red in color and be affixed with a red-orange “Biohazard” label.


Section Seven

Safety Regulations and Procedures

7.1 General Safety Rules

1. Be sure you know how to do the job. 2. Be sure you know its hazards and how to protect yourself. If you aren’t sure or have

questions ask your supervisor! 3. Report all injuries/illnesses immediately. 4. Wear the required personal protective equipment necessary for the job. 5. Always work clear of suspended loads. 6. Never conduct work, unless trained. 7. Obey all warning signs. 8. Inspect all equipment, scaffolds, ladders, lifts, etc. for safety before using. 9. Report any unsafe tools, equipment or hazardous conditions to your supervisor. 10. See that good housekeeping is maintained in your work area. 11. Exercise proper lifting techniques. 12. Operate vehicles in a safe manner. 13. Do not perform work under unsafe conditions. 14. Horseplay of any kind will not be permitted. 15. Only authorized personnel shall repair company furnished tools or equipment. 16. Firearms on the job are prohibited. 17. Do not use ladders as scaffolds and never climb so high that it is impossible to hold the

top step for support. 18. Never use a step ladder as a straight ladder. 19. Don’t put yourself and your supervisor on the spot by not observing safety rules and

regulations! 20. If you see someone doing something unsafe or at risk say something to that employee!

7.2 Ladders

1. Ladders shall only be used on stable and level surfaces unless secured to prevent accidental displacement.

2. Ladders shall not be used on slippery surfaces or when hands, shoes or rungs are slippery.

3. Ladder rungs, cleats and steps shall be parallel, level and uniformly spaced when the ladder is in position for use.

4. Ladders placed in any location where they can be accidentally displaced by workplace activities or traffic, such as in passageways, doorways or roadways, shall be secured to prevent accidental displacement, warning signs and barricades should be posted and someone should be assigned to hold the ladder.

5. The area around the top and bottom of the ladder shall be kept clear. 6. Ladders shall not be moved, shifted or extended while occupied.


7. The top or top step of a ladder shall not be used. 8. Cross-bracing on the rear section of stepladders shall not be used for climbing. 9. Ladders shall be inspected prior to each use for structural defects, such as, but not

limited to, broken or missing rungs, cleats, or steps, broken or split rails, corroded components, or other faulty or defective components. Any ladder found to be defective shall be red tagged and removed from service. Ladder shall be inspected by a competent person at least quarterly using the ladder inspection checklist. (See Appendix 7.1)

10. No employee shall carry any objects, material, tools or loads up a ladder. 11. Never use a step ladder as a straight ladder. 12. All moveable ladders in use should be equipped with safety shoes and should be tied,

blocked or otherwise secured to prevent movement. 13. Place ladders with care. Do not lean them against a movable object. 14. Do not paint ladders. Paint can hide cracks, breaks and other defects. 15. Do not use metal ladders near electrical circuits, fixtures or power lines. 16. Straight ladders must extend 3 feet above the landing level and be tied off. 17. Ladders must maintain a 4:1 ratio. (Four feet vertical to one for horizontal) 18. Maintain three points of contact while climbing the ladder. 19. Only one employee is allowed on a ladder at one time. 20. Always face the ladder. 21. Keep yourself in the center of the ladder. (Belt buckle between ladder rails) 22. All job made ladders shall be constructed to the specification of CFR 1926.450 (b)(1)

though (12). 23. Stepladders shall not be over 20 feet long. 24. When not in use, all types of ladders should be stored under suitable covers for

protection from the weather. 25. Before using ladders employees shall be trained by a competent person to recognize

hazards related to ladders and in the procedures to be followed to minimize these hazards. This training shall include the following:

a. Fall hazards associated with climbing or working from a ladder. b. The correct procedures for erecting, maintaining and disassembling the fall

protection system to be used. c. The proper construction, use, placement and care in handling of all stairways and

ladders. d. The maximum intended load-carrying capacities of ladders

Retraining shall be provided for each employee as necessary so that the employee maintains the understanding and knowledge acquired through compliance with this section.

7.3 Scaffolds

1. Each employee shall be trained before setting foot on a scaffold.


2. Scaffolds shall only be erected, moved, dismantled or altered under the supervision of a competent person. No employee shall be allowed to adjust or modify a scaffold except under the direction of the competent person.

3. Scaffolds must be placed on solid footing. No barrels, blocks or boxes shall be used to support scaffolds.

4. Scaffolds and their components shall be capable of supporting, without failure, at least four (4) times their maximum intended load.

5. Guardrails shall be 2 x 4 inches or equivalent, 42 inches high plus or minus 3 inches and capable of withstanding 200 lbs.

6. Mid rails shall be halfway between the guardrail and the platform and capable of withstanding 150 of side force.

7. Toe boards shall be a minimum of 4 inches in height with an opening of no more than --- from the platform.

8. Access ladder shall be provided on all scaffolds for a means of safe access. Climbing on scaffold components is prohibited.

9. All planking shall be of Scaffold Plank Grade or equivalent. 10. Scaffold planks must be erected, tested and made secure to prevent slipping by using

cleats, tying or wiring. 11. Scaffold planks shall extend over their end supports not less than 6 inches and not more

than 12 inches. 12. Overhead protection shall be provided for employee on a scaffold exposed to overhead

hazards. 13. The height of a scaffold shall not exceed four (4) times the smallest base dimension

unless it is tied to the structure. 14. Free standing tubular towers must be guyed every 30 feet of height. 15. Scaffolds shall be provided with a screen of No. 18 gauge U.S. standard ½” mesh wire

suspended from the guardrail to the toe board extending along the entire opening where persons are required to work or pass directly under the scaffold.

16. Slippery conditions on scaffolds shall be eliminated as soon as possible after they occur. Employees shall not be permitted to work on slippery scaffolds until they are clean of ice or snow.

17. No welding, burning, riveting, or open flame work shall be performed on any scaffolding suspended by means of fiber or synthetic rope.

18. When there is danger of material being hoisted striking against the scaffold, a tag line shall be provided.

19. The use of shore or lean-to scaffolds is prohibited. 20. Numerous occasions arise on our job sites where other contractors request to borrow or

make use of our scaffolding and/or equipment. Although the process of loaning scaffolding/equipment may be common, it’s important to understand that this process creates a potential liability situation for Gribbins Insulation Company. Therefore, we have developed the “Scaffolding and Equipment Loan Agreement”. This agreement must be completed, signed and dated whenever we loan our scaffolding and/or equipment to other contractors. (See Appendix 7.2)


21. Scaffolds will be tagged by a competent person at each access point and will be inspected before each shift and signed. The following color codes will be used for scaffold tags:

a. Red Tag – This is an incomplete scaffold and access is not allowed by scaffold user. The scaffold is either being erected or taken down.

b. Yellow Tag – The scaffold is not 100% complete or other hazards are present. The scaffold user must read the tag and take the precaution noted on the tag.

c. Green Tag – Scaffold is 100% complete. Guardrails, midrails and toe boards are installed properly. This type of scaffold will not require fall protection.

22. Before the use of any of the following types of scaffolds the Safety Department shall be involved and a review of the specific safety requirement of the Federal Safety Standard shall be reviewed.

a. Wood Pole Scaffold b. Tube and Coupler Scaffold c. Tubular Welded Frame Scaffolds d. Manually Propelled Mobile Scaffolds e. Elevating and Rotating Work Platforms f. Outrigger Scaffolds g. Mason’s Adjustable Multiple-Point Suspension Scaffold h. Two-Point Suspension Scaffold i. Ladder-Type Platforms j. Plank-Type Platforms k. Light Metal-Type Platforms l. Stone Setters Adjustable Multiple-Point Suspension m. Single-Point Adjustable Suspension Scaffolds n. Boatswain’s Chairs o. Carpenter’s Bracket Scaffolds p. Horse Scaffolds q. Needle Beam Scaffolds r. Plasterer’s Decorator’s and Large Area Scaffolds s. Interior Hung Scaffolds t. Ladder Jack Scaffolds u. Window Jack Scaffolds v. Roofing Brackets w. Crawling Boards or Chicken Ladders x. Float or Ship Scaffold y. Pump Jack Scaffolds

23. Before an employee uses a scaffold they shall be trained by a person qualified in the subject matter to recognize the hazards associated with the type of scaffold being used and to understand the procedures to control or minimize those hazards. This training shall include the following:

a. The nature of any electrical hazards, fall hazards and falling object hazards in the work area.


b. The correct procedures for dealing with electrical hazards and for erecting, maintaining and disassembling the fall protection systems and falling object protection systems being used.

c. The proper use of the scaffold and the proper handling of materials on the scaffold.

d. The maximum intended load and the load-carrying capacities of the scaffold used.

e. Any other pertinent requirements of this subpart.

Employees who are involved in erecting, disassembling, moving, operating, repairing, maintaining or inspecting a scaffold shall be trained by a competent person to recognize hazards associated with the work in question. This training shall include the following:

a. The nature of scaffold hazards. b. The correct procedures for erecting, disassembling, moving, operating, repairing,

inspecting and maintaining the type of scaffold in question. c. The design criteria, maximum intended load-carrying capacity and intended use

of the scaffold. d. Any other pertinent requirements of this subpart.

When Gribbins Insulation Company has reason to believe that an employee lacks the skill or understanding needed for safe work involving the erection, use or dismantling or scaffolds, employees shall be retrained so that the requisite proficiency is regained. Retraining is required in at least the following situations:

a. Where changes at the worksite present a hazard about which an employee has not been previously trained.

b. Where changes in the types of scaffolds, fall protection, falling object protection or other equipment present a hazard about which an employee has not been previously trained.

c. Where inadequacies in an affected employee’s work involving scaffolds indicate that the employee has not retained the requisite proficiency.

7.4 Confined Spaces

1. Definitions

a. Confined Space – Any space that (1) has adequate size and configured that an employee can enter, (2) has limited means of access and egress and (3) is not designed for continuous employee occupancy

b. Permit Require Confined Space – Contains or has the potential to contain a hazard capable of causing death or serious physical harm, in addition to having the configuration of a confined space.

c. Entrant – The employees entering the confined space.


d. Attendant – The employees that are required to stay outside of the confined space to monitor the entrants and conduct air monitoring.

e. Entry Supervisor – The employee in charge of the confined space procedure. They will fill out the confined space permit, conduct atmospheric testing, make sure participants have the required training, and assure the procedure is performed correctly. The supervisor determine if acceptable entry conditions are present at the permit space where entry is planned, authorizes entry and oversees entry operation and terminates entry as required by this section

f. Rescue Personnel – The only authorized persons to enter a confined space to rescue an entrant.

2. Types of Confined Spaces

a. Confined spaces include, but are not limited to: storage tanks, boilers, ventilation ducts, stacks, tanker cars, process vessels, sewers, exhaust duct, underground utility vaults, hopper cars, bins, tunnels, pipelines, vaults, silos, degreasers, open top spaces or containers more than 4 feet in depth, such as pits, vessels, tubs, trenches, vaults.

3. Confined Space Hazards

a. Hazardous Atmosphere 1) The air may not have enough oxygen. The minimum oxygen level must be 19.5%.

At levels below this, no entry is permitted without being equipped with air supplied breathing equipment.

2) The air may be flammable or toxic, if so, entry is not permitted if the concentration of flammable is above 10% of the lower explosive limit, which is found on the MSDS. Test for toxic concentrations above the TLV, (as contained on the MSDS), entry into the space shall be discussed with and approved by Management.

b. Engulfment; being trapped in liquid or solid material. c. Danger from unexpected movement of machinery. d. Electrocution. e. Heat Stress. f. Physical dangers such as fall, debris, slipping ladders, and suffocation due to welding.

4. Preparation of Confined Spaces

The following steps are necessary to prepare the space before anyone enters. The entry supervisor shall check to see that each precautionary step has been taken.

a. All departments likely to be affected by service interruptions must be notified. b. Signs and barriers shall be posted at the confined space.

1) Barriers erected to prevent inadvertent entry. 2) Permit, properly completed, posted near entry. The permit is valid only until

completion of the job or end of the shift, whichever comes first. All permits shall be retained and filed with the permanent job records. (See Appendix 7.3)


c. Blind or disconnect and cap all input lines, so that no hazardous material can enter the space.

d. Complete lockout/tag out procedures. (See Section 7 – Lockout/Tag out Procedures) e. Empty the space of any material that may be hazardous. If necessary clean and purge

hazardous residue in the space. f. When ventilation is needed, begin long enough in advance so that the air will be safe

before anyone enters. Verify by air testing. g. Verify that the training of entry supervisor, attendant and entrants is documented and

current.

5. Entry Requirements

a. Atmospheric Testing – Test the air in all areas and elevations before entry. Monitor continuously or retest periodically for as long as the space is occupied and as is appropriate for the hazard involved. The safety manager, or a third party, will perform all atmospheric testing along with a participant, usually entry supervisor, to assure procedures are performed correctly.

1) Oxygen – Allowable limits are between 19.5% and 23.5% 2) Flammables – For gases, the lower flammable limit (LFL) must be lower than

10%. For dust, do not exceed the LFL 3) Toxicity – List and test for any toxic materials that could be present and their

permissible exposure limits (PEL). 4) If the air is unsafe according to any of these tests, the hazard must be controlled

before entry is allowed. The priority of controls is first engineering, e.g. fans, second administrative and last personal protective equipment.

b. Evaluate for heat stress potential. Mitigate as necessary. c. Appropriate personal protective equipment such as respirators, goggles, gloves, shoes

and coveralls shall be required. d. If continuous visual communication between the attendant and entrant will be difficult or

impossible, choose and list on the entry permit the devices to be used. Test this equipment before entry. List any special procedures necessary.

e. List any special light sources, spark-proof tools and other electrical equipment that must be on hand before entry begins. Flammable gas presence above 1% of LFL requires continuous monitoring of gas levels and elimination of any source of ignition.

f. Additional monitoring will be provided if requested at anytime by employees.

6. Duties and responsibilities of Confined Space entry team members.

a. Attendant i. Must know the hazards that may be faced during entry including the mode, signs

or symptoms and consequences of the exposure. ii. Must know the possible behavioral effects or hazard exposure in the authorized

entrants.


iii. Must maintain an accurate count of authorized entrants in the permit space with a sign in log. This log must have the authorized entrants signature and when they entered and exited the space.

iv. The attendant must remain outside the permit space. This means no part of their body can break the plane of the space. The attendants sole job responsibility is to monitor the space.

v. The attendant must communicate with the authorized entrants to monitor their status and alert them if evacuation is necessary.

vi. The attendant will monitor activities inside and outside of the space to determine the safety of the entrants and will order entrants to evacuate the space immediately if any of the following conditions occur:

The attendant detects a prohibited condition. The attendant detects the behavioral effects of hazard exposure in an

authorized entrant. The attendant detects a situation outside the space that could endanger

the authorized entrant; or The attendant detects they cannot effectively and safely perform all the

duties required under paragraph (i) of this section. vii. The attendant must summon rescue services as soon as they determine the

entrants may need assistance to escape from the space. viii. The attendant must take the following action when unauthorized person

approach or try to enter the space while entry is underway: Warn the unauthorized persons that they must stay away from the permit

space. Advise the unauthorized person that they must exit immediately if they

have entered the permit space. Inform the authorized entrants and the entry supervisor if unauthorized

persons have entered the permit space.

b. Entry Supervisor i. Must know the hazards that may be faced during entry, including information on

the mode, signs or symptoms and consequences of the exposure. ii. Must verify, by checking that the appropriate entries have been made on the

permit, that all test specified by the permit have been conducted and that all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry to begin.

iii. Terminates the entry and cancels the permits are required by paragraph (e)(5) of this section.

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

v. Removes unauthorized individual who enter or who attempt to enter the permit space during entry operations.

vi. Determines, whenever responsibility for a permit space entry operation is transferred and at intervals dictated by the hazards and operations performed


within the space, that entry operations remain consistent with terms of the entry permit and that acceptable entry conditions are maintained.

c. Authorized Entrant

i. Must know the hazards that may be faced during entry, including information on the mode, signs or symptoms and consequences of the exposure.

ii. Must properly use equipment as required by paragraph (d)(4) of this section. iii. Must communicate with the attendant as necessary to enable the attendant to

monitor entrant status and to enable the attendant to alert entrants of the need to evacuate the space as required by paragraph (i)(6) of this section.

iv. Must alert the attendant whenever the entrant recognizes any warning signs or symptoms of exposure to a dangerous situation or the entrant detects a prohibited condition.

v. Must exit from the permit space as quickly as possible whenever an order to evacuate is given by the attendant or entry supervisor, the entrant recognizes any warning signs or symptoms of exposure to a dangerous situation, the entrant detects a prohibited condition or an evacuation alarm is activated.

7. Emergency and Rescue Procedures

a. The safest ways of leaving a space when conditions deteriorate are: Self-rescue, when an entrant evacuates the space with no help at the first sign of trouble.

b. Only workers trained and certified in rescue can enter the space for the purpose of rescue. While entering and working in IDLH conditions rescue services must be onsite.

c. Attendant is not allowed to participate in more than one confined space entry procedure at a time.

d. Attendant personnel shall not leave their post unless the confined space entry operation is complete, all personnel have exited, and the space is secure. For rescue operations, they shall: 1) Notify rescue personnel via their radio, phone, voice or visual signal

communications. No communication links are permitted, which require leaving their attendant post.

2) Attempt rescue via established “non-entry” rescue procedures. 3) Maintain count of all personnel entering the confined space.

e. List on the entry permit all of the necessary emergency equipment or devices such as rescue and communication equipment and verify it is in working order prior to space entry.

f. Review the Emergency Response Plan prior to any entry.

8. Post Entry Considerations

a. The Supervisor who authorized the entry shall be responsible for: 1) Verifying all personnel are no longer in the confined space. 2) Determining that all equipment used during the entry has been removed from the

confined space.


3) Removal of entry permit and forwarding it to the office for filing. b. The permit shall be kept 1 year to facilitate and review problems and will be reviewed

when the program evaluation is performed.

9. Training

Gribbins Insulation Company shall provide training to each employee before they begin work in a confined space to ensure they have understanding, knowledge and skill necessary for the safe performance of the duties assigned under this section. Training shall be provided to each affected employee:

a. Before the employee is first assigned duties under this section. b. Before there is a change in assigned duties. c. Whenever there is a change in permit space operations that present a hazard

about which an employee has not previously been trained. d. Whenever Gribbins Insulation Company has reason to believe either that there

are deviations from the permit space entry procedures of this section or that there are inadequacies in the employee’s knowledge or use of these procedures.

The training shall establish employee proficiency in the duties required by this section and shall introduce new or revised procedures, as necessary, for compliance with this section.

Gribbins Insulation Company shall certify that the training required has been accomplished. The certification shall contain each employee’s name, the signature or initials of the trainers and the dates of training. The certification shall be available for inspection by employees and their authorized representatives.

Each authorized entrant shall be trained, able to recognize and complete the following:

a. To know the hazards that may be faced during entry, including information on the mode, signs or symptoms and consequences of exposure.

b. To properly use equipment required by paragraph (d)(4) of this section. c. To communicate with the attendant as necessary to enable the attendant to monitor

entrant status and to enable the attendant to alert entrants of the need to evacuate the space as required by paragraph (i)(6) of this section.

d. To alert the attendant whenever: i. The entrant recognizes any warning sign or symptom of exposure to a dangerous

situation. ii. The entrant detects a prohibited condition.

e. To exit from the permit space as quickly as possible whenever: i. An order to evacuate is given by the attendant or the entry supervisor. ii. The entrant recognizes any warning sign or symptom of exposure to a dangerous

situation. iii. The entrant detects a prohibited condition. iv. An evacuation alarm is activated.

Each attendant shall be trained, able to recognize and complete the following:


a. To know the hazards that may be faced during entry, including information on the mode, signs or symptoms and consequences of the exposure.

b. Is aware of possible behavioral effects of hazard exposure in authorized entrants. c. Continuously maintains an accurate count of authorized entrants in the permit space

and ensures that the mean used to identify authorized entrants under paragraph (f)(4) of this section accurately identifies who is in the permit space.

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

e. Communicates with authorized entrants as necessary to monitor entrant status and to alert entrant of the need to evacuate the space.

f. Monitors activities inside and outside of the space to determine if it is safe for entrants to remain in the space and orders the authorized entrants to evacuate the permit space immediately under any of the following conditions:

i. If the attendant detects a prohibited condition. ii. If the attendant detects the behavioral effects of hazard exposure in an

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

authorized entrants. iv. If the attendant cannot effectively and safely perform all the duties required

under this section. g. Summon rescue and other emergency services as soon as the attendant determines

that authorized entrants may need assistance to escape from permit space hazards. h. Takes the following action when unauthorized persons approach or enter a permit space

while entry is underway: i. Warn the unauthorized persons that they must stay away from the permit space. ii. Advise the unauthorized persons that they must exit immediately if they have

entered the permit space. iii. Inform the authorized entrants and the entry supervisor if unauthorized persons

have entered the permit space. i. Performs non-entry rescues as specified by Gribbins Insulation Company’s rescue

procedures. j. Performs no duties that might interfere with the attendant’s primary duty to monitor and

protect authorized entrants.

Each entry supervisor shall be trained, able to recognize and complete the following:

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

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

c. Terminates the entry and cancels the permit when operations covered by the permit have been completed or a condition that is not allowed under the permit arises in or near the permit space.


d. Removes unauthorized individuals who enter or who attempt to enter the permit space during entry operations.

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

10. Multi-Employer Confined Space Procedure

a. If more than one employer will be working in a confined space at any one time the following precautions must be taken.

1) A pre-entry meeting will be held between the different employers working in the confined space.

2) All potential hazards that each employers work may produce will be covered. 3) An overall rescue procedure will be discussed and implemented for all employers

involved in the entry.

11. Program Evaluation

a. This program will be evaluated after a confined space procedure to ensure all tasks are done correctly.

b. Training for each authorized participant will be reviewed with the program evaluation to see if all hazards and tasks are included.

7.5 Fall Protection

1. Definitions

a. Anchorage – A secure point of attachment for lifelines, lanyards or deceleration devices b. Body Harness – Straps which may be secured about the employee in a manner that will

distribute the fall arrest forces over at least the thighs, pelvis, waist, chest and shoulders with means for attaching it to other components of a personal fall arrest system.

c. Buckle – Any device for holding the body harness closed around the employee’s body. d. Connector – A device which is used to connect parts of the personal fall arrest system

and positioning device systems together. It may be an independent component of the system, such as a carabineer, or it may be an integral component of part of the system, such as a buckle or dee-ring sewn into a body harness, or a snap-hook spliced or sewn to a lanyard or self retracting lifeline.

e. Controlled Access Zone – An area in which certain work may take place without the use of guardrail systems, personal fall arrest systems, or safety net systems and access to the zone is controlled.

f. Deceleration Device – Any mechanism, such as a rope grab, rip-stitch lanyard, specially-woven lanyard, tearing or deforming lanyards, automatic self retracting lifelines/lanyards, etc., which serves to dissipate a substantial amount of the energy during a fall arrest, or otherwise limit the energy imposed on an employee during fall arrest.


g. Deceleration Distance – The additional vertical distance a falling employee travels, excluding lifeline elongation and free fall distance, before stopping, from the point at which the deceleration device beings to operate. It is measured as the distance between the location of an employee’s body harness attachment point at the moment of activation (at the onset of fall arrest forces) of the deceleration device during a fall, and the location of that attachment point after the employee comes to a full stop.

h. Failure – Load refusal, breakage or separation of component parts. Load refusal is the point where the ultimate strength is exceeded.

i. Free Fall – The act of falling before a personal fall arrest system begins to apply force to arrest the fall.

j. Free Fall Distance – The vertical displacement of the fall arrest attachment point on the employee’s body harness between onset of the fall and just before the system begins to apply force to arrest the fall. This distance excludes deceleration distance and lifeline/lanyard elongation, but includes any deceleration device slide distance or self-retracting lifeline/lanyard extension before they operate and fall arrest forces occur.

k. Guardrail System – A barrier erected to prevent employees from falling to lower levels. l. Hole – A gap or void 2 inches or more in its least dimension, in a floor, roof, or other

walking/working surface. m. Lanyard – A flexible line of rope, wire rope, or strap which generally has a connector at

each end for connecting the body harness to a deceleration device, lifeline or anchorage.

n. Leading Edge – The edge of a floor, roof or formwork for a floor or other walking/working surface (such as a deck) which changes location as additional floor, roof, decking or formwork sections are placed, formed or constructed. A leading edge is considered to be an “unprotected side and edge” during periods when it is not actively and continuously under construction.

o. Lifeline – A component consisting of a flexible line for connection to an anchorage at one end to hang vertically (vertical lifeline) or for connection to anchorages at both ends to stretch horizontally (horizontal lifeline) and which serves as a means for connecting other components of a personal fall arrest system to the anchorage.

p. Low-Slope Roof – A roof having a slope less than or equal to 4 in 12 (vertical to horizontal).

q. Lower Levels – Those areas or surfaces to which an employee can fall. Such areas or surfaces include, but are not limited to, ground levels, floors, platforms, ramps, runways, excavations, pits, tanks, material, water, equipment, structures or portions thereof.

r. Opening – A gap or void 30 inches or more high and 18 inches or more wide, in a wall or partition, through which an employee can fall to a lower level.

s. Personal Fall Arrest System – A system used to arrest an employee in a fall from a working level. It consists of an anchorage, connectors, a body harness and may include a lanyard, deceleration device, lifeline or suitable combinations of these. As of January 1, 1998, the use of a body belt for fall arrest is prohibited.

t. Positioning Device System – A body harness system rigged to allow an employee to be supported on an elevated vertical surface, such as a wall, and work with both hands free while leaning.


u. Rope Grab – A deceleration device which travels on a lifeline and automatically, by friction, engages the lifeline and locks so as to arrest the fall of an employee. A rope grab usually employs the principle of inertial locking, cam/level locking or both.

v. Roof – The exterior surface on the top of a building. This does not include floors or formwork which, because a building has not been completed, temporarily becomes the top surface of a building.

w. Roofing Work – The hoisting, storage, application and removal of roofing materials and equipment, including related insulation, sheet metal, and vapor barrier work, but not including the construction of the roof deck.

x. Safety Monitoring System – A safety system in which a competent person is responsible for recognizing and warning employees of fall hazards.

y. Self-Retracting Lifeline/Lanyard – A deceleration device containing a drum-wound line which can be slowly extracted from, or retracted onto, the drum under slight tension during normal employee movement, and which, after onset of a fall, automatically locks the drum and arrest the fall.

z. Snap hook – A connector comprised of a hook-shaped member with a normally closed keeper, or similar arrangement, which may be opened to permit the hook to receive an object and, when released, automatically closes to retain the object. Snap hooks are generally one of two types:

i. The locking type with a self-closing, self-locking keeper which remains closed and locked until unlocked and pressed open for connection or disconnection.

ii. The non-locking type with a self-closing keeper which remains closed until pressed open for connection or disconnection. As of January 1, 1998, the use of a non-locking snap hook as part of personal fall arrest system and positioning device system is prohibited.

aa. Steep Roof – A roof having a slope greater than 4 in 12 (vertical to horizontal). bb. Toe board – A low protective barrier that will prevent the fall of materials and equipment

to lower levels and provide protection from falls for personnel. cc. Unprotected Sides and Edges – Any side or edge (except at entrances to points of

access) of a walking/working surface, e.g., floor, roof, ramp or runway where there is no wall or guardrail system at least 39 inches high.

dd. Walking/Working Surface – Any surface, whether horizontal or vertical on which an employee walks or works, including, but not limited to, floors, roofs, ramps, bridges, runways, formwork and concrete reinforcing steel but not including ladders, vehicles or trailers, on which employees must be located in order to perform their job duties.

ee. Warning Line System – A barrier erected on a roof to warn employees that they are approaching an unprotected roof side or edge, and which designates an area in which roofing work may take place without the use of guardrails, personal fall arrest system or safety net system to protect employees in the area.

ff. Work Area – That portion of a walking/working surface where job duties are being performed.

2. Duty to have Fall Protection


a. Gribbins Insulation Company adheres to a 100% fall protection rule above 6 ft. b. Gribbins Insulation Company shall determine if the walking/working surfaces on which its

employees are to work have the strength and structural integrity to support employees safely.

c. Each employee on a walking/working surface with an unprotected side or edge which is 6 feet or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems or personal fall arrest systems.

d. Each employee who is constructing a leading edge 6 feet or more above lower levels shall be protected from falling by guardrail system, safety net system or personal fall arrest system. Exception: When Gribbins Insulation Company can demonstrate that it is infeasible or creates a greater hazard to use these systems, Gribbins Insulation Company shall develop and implement a fall protection plan which meets the requirements of 1926.502(K).

e. Each employee on a walking/working surface 6 feet or more above a lower level where leading edges are under construction, but who is not engaged in leading edge work, shall be protected from falling.

f. Each employee in a hoist area shall be protected from falling 6 feet or more to a lower level.

g. Each employee on a walking/working surface shall be protected from falling through holes more than 6 feet above lower levels by personal fall arrest systems, covers or guardrails.

h. Each employee engaged in roofing activities (low-sloop or steep-slope roofs) with unprotected sides or edges 6 feet or more above lower levels shall be protected from falling.

i. Each employee engaged in the erection or precast concrete members who is 6 feet or more above lower levels shall be protected from falling.

j. Each employee working on, at, above or near wall openings where the outside bottom edge of the wall opening is 6 feet or more above lower levels and the inside bottom edge of the wall opening is less than 39 inches above the walking/working surface, shall be protected from falling.

k. Each employee on a walking/working surface 6 feet or more above lower levels (not otherwise addressed) shall be protected.

3. Fall Protection System Criteria and Practices

a. Guardrail Systems - All guardrail systems and their use shall comply with the following provisions:

1) The top edge height of top rails or equivalent guardrails system members shall be 42 inches high plus or minus 3 inches above the walking/working surface.

2) Midrails, screens, mesh intermediate vertical members, or equivalent intermediate structural members shall be installed between the top edge of the guardrail system and the walking/working surface when there is no wall or parapet wall at 21 inches high.


3) Midrails shall be installed at a height midway between the top edge of the guardrail system and the walking/working surface.

4) Screens and mesh, when used, shall extend from the top rail to the walking/working surface.

5) Intermediate members when used between posts shall be no more than 19 inches apart.

6) Guardrail systems shall be capable of withstanding, without failure, a force of at least 200 pounds applied within 2 inches of the top edge, in any outward or downward direction, at any point along the top edge.

7) When a 200 pound test load is applied in a downward direction, the top edge of the guardrail shall not deflect to a height less than 39 inches above the walking/working surface.

8) Midrails shall be capable of withstanding, without failure, a force of at least 150 pounds applied in any downward or outward direction.

9) Guardrail systems shall be so surfaced as to prevent injury from punctures or lacerations.

10) If wire rope is used for top rails, it shall be flagged at not more than 6 foot intervals with high visibility material. Top rails and midrails shall be at least ¼ inch nominal diameter.

11) When guardrail systems are used at hoisting areas, a chain, gate or removable guardrail section shall be placed across the access opening between guardrail sections when hoisting operations are not taking place.

12) Manila, plastic or synthetic rope being used for top rails or midrails shall be inspected as frequently as necessary to ensure that it continues to meet the strength requirements.

4. Safety Net Systems

a. If a safety net system is required, the Safety Manager must be contacted for specific requirements.

5. Personal Fall Arrest Systems

a. Personal Fall Arrest Systems and their use shall comply with the following provisions: 1) All fall protection equipment will comply with ANSI & ASTM requirements. 2) Connectors shall be drop forged, pressed or formed steel, or made of equivalent

materials. 3) Connectors shall have a corrosion resistant finish, and all surfaces and edges

shall be smooth to prevent damage to interfacing parts of the system. 4) Dee-rings and snap hooks shall have a minimum tensile strength of 5,000

pounds and proof tested to a minimum tensile strength of 3,600 pounds without cracking, breaking or taking on permanent deformation.

5) Snap hooks shall be sized to be compatible with the member to which they are connected to prevent unintentional disengagement of the snap hook keeper by the connected member, or shall be a locking type snap hook designed and used


to prevent disengagement of snap hook by the contact of the snap hook keeper by the connected member.

6) Unless the snap hook is a locking type and designed for the following connections, snap hooks shall not be engaged:

i. Directly to webbing, rope, or wire rope ii. To each other iii. To a dee-ring to which another snap hook or other connector is attached iv. To a horizontal lifeline v. To any object which is incompatibly shaped or dimensioned in relation to

the snap hook such that unintentional disengagement could occur 7) On suspended scaffold or similar work platforms with horizontal lifelines which

may become vertical lifelines, the devices used to connect to a horizontal lifeline shall be capable of locking both directions on the lifeline.

8) Horizontal lifelines shall be designed, installed and used under the supervision of a qualified person, as part of a complete personal fall arrest system, which maintains a safety factor of at least 2.

9) Lanyards and vertical lifelines shall have a minimum breaking strength of 5,000 pounds when vertical lifelines are used, each employee shall be attached to a separate lifeline.

10) Lifelines shall be protected against being cut or abraded. 11) Self retracting lifelines and lanyards which do not limit free fall distance to 2 feet

or less, rip stitch lanyards, tearing and deforming lanyards shall be capable of sustaining a minimum tensile load of 5,000 pounds with the lifeline or lanyard in the fully extended position.

12) Anchorages used for attachment of personal fall arrest equipment shall be independent of any anchorage being used to support or suspend platforms and capable of supporting at least 5,000 pounds per employee attached.

13) Personal fall arrest systems, when stopping a fall shall: i. Limit maximum arresting force on an employee to 1,800 pounds. ii. Be rigged such that an employee can neither free fall more than 6 feet nor

contact any lower level. iii. Bring an employee to a complete stop and limit maximum deceleration

distance and employee travels to 3.5 feet. 14) The attachment point of the body harness shall be located in the center of the

wearer’s back near shoulder level. 15) Personal fall arrest systems and components subjected to impact loading shall

be immediately removed from service and shall not be used again for employee protection until inspected and determined by the manufacturer to be undamaged and suitable for reuse.

16) Personal fall arrest systems shall be inspected by the user prior to each use for wear, damage, deterioration and defective components. If wear, damage, deterioration or defective components are found it shall be immediately removed from service. A competent person shall inspect personal fall arrest equipment at


least quarterly and document of Gribbins Insulation Company’s fall protection inspection form. (See Appendix 7.4)

17) Personal fall arrest systems shall not be attached to guardrail systems or hoists. 18) When a personal fall arrest system is used at hoist areas, it shall be rigged to

allow the movement of the employee only as far as the edge of the walking/working surface.

6. Positioning Device Systems

a. Positioning device systems and their use shall conform to the following: 1) Positioning devices shall be rigged such that an employee cannot free fall more

than 2 feet. 2) Positioning devices shall be secured to an anchorage capable of supporting at

least twice the potential impact load of an employee’s fall or 3,000 pounds whichever is greater.

3) Connectors shall be drop forged, pressed, formed steel or made of equivalent materials.

4) Connecting assemblies shall have a minimum tensile strength of 5,000 pounds. 5) Dee-rings and snap hooks shall be proof tested to a minimum tensile load of

3,600 pounds. 6) Snap hooks shall be sized to be compatible with the member to which they are

connected to prevent unintentional disengagement of the snap hook by depression of the snap hook keeper by the connected member or shall be a locking type snap hook designed and used to prevent disengagement of the snap hook by the contact of the snap hook keeper by the connected member.

7) Unless the snap hook is a locking type and designed for the following connections, snap hooks shall not be engaged (1) directly to webbing, rope or wire rope, (2) to each other, (3) to a dee-ring to which another snap hook or other connector is attached, (4) to a horizontal lifeline or (5) to any object which is incompatibly shaped or dimensioned in relation to the snap hook.

8) Positioning device systems shall be inspected by the user prior to each use for wear, damage, deterioration and defective components. If wear, damage, deterioration or defective components are found equipment shall be immediately removed from service.

7. Warning Line Systems

a. Warning Line systems and their use shall comply with the following provisions: 1) The warning line shall be erected around all sides of the roof work area. 2) When mechanical equipment is not being used, the warning line shall be erected

not less than 6 feet from the edge. 3) When mechanical equipment is being used, the warning lines shall be erected

not less than 6 feet from the roof edge which is parallel to the direction of the mechanical equipment operation, and not less than 10 feet from the roof edge which is perpendicular to the direction of the mechanical equipment operation.


4) Points of access, material handling areas, storage areas and hoisting areas shall be connected to the work area by an access path formed by two warning lines.

5) When the path to a point of access is not in use, a rope, wire, chain, or other barricade shall placed across the path.

6) Warning lines shall consist of ropes, wires, or chains and supporting stanchions erected as follows:

i. The rope, wire or chain shall be flagged at not more than 6 foot intervals with high visibility material.

ii. The rope, wire or chain shall be rigged and supported in such a way that its lowest point is no less than 34 inches from the walking/working surface and its highest point is no more than 39 inches from the walking/working surface.

iii. After being erected the stanchions shall be capable of resisting a force of at least 16 pounds applied horizontally against the stanchion, 30 inches above the walking/working surface, perpendicular to the warning line and in the direction of the floor, roof or platform edge.

iv. The rope, wire or chain shall have a minimum tensile strength of 500 pounds.

v. The line shall be attached at each stanchion in such a way that pulling on one section of the line between stanchions will not result in slack being taken up in adjacent sections before the stanchion tips over.

7) No employee shall be allowed in the area between the roof edge and the warning line unless the employee is performing roofing work in that area.

8) Mechanical equipment on roofs shall be used or stored only in areas where employees are protected by a warning line system, guardrail system or personal fall arrest system.

8. Controlled Access Zones

a. Controlled access zones and their use shall conform to the following: 1) When used to control access to areas where leading edge and other operations

are taking place the controlled access zone shall be defined by a control line or by any other means that restricts access.

2) When control lines are used, they shall be erected not less than 6 feet nor more than 25 feet from the unprotected or leading edge, except when erecting precast concrete members.

3) When erecting precast concrete members, the control line shall be erected not less than 6 feet nor more than 60 feet or half the length of the member being erected, whichever is less, from the leading edge.

4) The control line shall extend along the entire length of the unprotected or leading edge and shall be approximately parallel to the unprotected leading edge.

5) The control line shall be connected on each side to a guardrail system or wall. 6) Control lines shall consist of ropes, wires, tapes or equivalent materials and

supporting stanchions as follows:


i. Each line shall be flagged at no more than 6 foot intervals with high visibility material.

ii. Each line shall be rigged and supported in such a way that its lowest point is not less than 39 inches from the walking/working surface and its highest point is not more than 45 inches from the walking working surface.

iii. Each line shall have a minimum breaking strength of 200 pounds.

9. Covers

a. Covers for holes in floors, roofs and other walking/working surfaces shall meet the following requirements:

1) Covers located in roadways and vehicular aisles shall be capable of supporting, without failure, at least twice the maximum axle load of the largest vehicle expected to cross over the cover.

2) All other covers shall be capable of supporting, without failure, at least twice the weight of employees, equipment and material that may be imposed on the cover at any one time.

3) All covers shall be secured when installed so as to prevent accidental displacement by the wind, equipment or employees.

4) All covers, except cast iron manhole covers or steel grates used on streets, shall be color coded or they shall be marked with the word “HOLE” or “COVER” to provide warning of the hazard.

10. Protection from Falling Objects

a. Falling object protection shall comply with the following provisions: 1) Toe boards, when used as falling object protection, shall be erected along the

edge of the overhead walking/working surface for a distance sufficient to protect employees below.

2) Toe boards shall be capable of withstanding, without failure, a force of at least 50 pounds applied in any downward or outward direction at any point along the toe board.

3) Toe boards shall be a minimum of 3 ½ inches in vertical heights and be installed in such a manner as not to have more than ¼ inch clearance above the surface on which they are installed.

4) Where tools, equipment or materials are piled higher than the top edge of a toe board, paneling or screening shall be erected from the toe board to the top of the mid rail or top rail.

5) No materials or equipment except masonry and mortar shall be stored within 4 feet of the working edge.

6) Canopies, when used as falling object protection, shall be strong enough to prevent collapse and to prevent penetration by any objects which may fall onto the canopy.

11. Fall Protection Plan


a. Fall Protection Plans shall be developed for each jobsite where fall hazards exist. These plans shall consist of a statement of company policy, where and when fall protection will be required, fall protection systems to be used, personal fall arrest system equipment, fall considerations, enforcement, rescue and evacuation plan, accident investigation, changes to plan and who is responsible for the implementing and overseeing the plan. Depending on the type of fall protection system being used more information may be need. This plan shall be documented on the Gribbins Insulation Company Fall Protection Plan Form and reviewed with all employees. (See Appendix 7.5)

12. Rescue

In the event that an employee falls, plant security or rescue team, if available, shall be notified immediately. If the employee can perform a self-rescue, assist the employee in any way possible. If the employee cannot perform a self-rescue and there is no rescue team, employees should perform the rescue. This can be achieved with the use of ladders, aerial lift or crane basket. It is imperative that employees performing a rescue use 100% fall protection and put no one at risk for injury. In any circumstance the employee should be rescued within 15 minutes.

The supervisor and employees performing the work should look at the work being performed and evaluate before work begins. Each employee in the crew shall be aware of the rescue plan for that job.

13. Incident Investigation

All incidents that result in injury to workers, a fall, a near miss or other serious incident, regardless of their nature, shall be investigated and reported immediately. It is an integral part of any safety program that documentation takes place as soon as possible so that the cause and means of prevention can be identified to prevent a reoccurrence.

In the event that an employee falls or there is some other related, serious incident occurring, the fall protection plan shall be reviewed to determine if additional practices, procedures, or training need to be implemented to prevent similar types of falls or incidents from occurring.

14. Training

a. Gribbins Insulation Company shall provide training for each employee who might be exposed to a fall hazard. This training shall enable each employee to recognize the hazards of falling and shall train each employee in the procedures to be followed in order to minimize these hazards.

Gribbins Insulation Company shall assure that each employee has been trained, as necessary, by a competent person qualified in the following areas:

i. The nature of fall hazards in the work area.


ii. The correct procedures for erecting, maintaining, disassembling and inspecting the fall protection systems to be used.

iii. The use and operation of guardrail systems, personal fall arrest systems, safety net systems, warning line systems, safety monitoring systems, controlled access zones and other protection to be used.

iv. The role of each employee in the safety monitoring system when this system is used.

v. The limitations on the use of mechanical equipment during the performance of roofing work on low-sloped roofs.

vi. The correct procedures for the handling and storage of equipment and materials and the erection of overhead protection.

vii. The role of employees in fall protection plans. viii. The standard contained in this subpart.

b. Gribbins Insulation Company shall verify compliance with a written certification record. The written certification record shall contain the name or other identity of the employee trained, the date of training and signature of the person who conducted the training. The latest training certification shall be maintained.

c. Retraining shall be conducted whenever Gribbins Insulation Company has reason to believe that a trained employee does not have the understanding and skill required. Circumstances where retraining is required include, but are not limited to, situation where:

i. Changes in the workplace render previous training obsolete. ii. Changes in the types of fall protection systems or equipment to be used render

previous training obsolete. iii. Inadequacies in an affect employee’s knowledge or use of fall protection systems

or equipment indicate that the employee has not retained the requisite understanding or skill.

15. Competent Person

a. A competent person will train all employees that are involved with the duty to have fall protection on the above program.

b. A competent person will assure each type of fall protection system is used correctly in the field.

c. A competent person will inspect personal fall arrest equipment at least quarterly. d. The corporate Safety Manager for Gribbins Insulation Company will assume the

competent person status unless another competent person has been designated for that particular job.

7.6 Electrical

1. General

a. Only employees trained and authorized may repair electrical equipment.


b. Inspect equipment before each use to ensure it is in good working order. If the equipment is defective tag it out and report to your supervisor immediately. Inspections shall be conducted by a competent person at least quarterly.

c. Do not use extension cords or power tools if the ground prong is missing. d. Never overload electrical receptacles. e. Never mix electricity and water. f. Even low voltages can cause severe injury or even death. g. Personal protective equipment shall be used when it is possible to come in contact with

exposed electrical parts. It shall be inspected before each use and if found to be defective taken out of service.

h. Non-conductive head protection shall be worn if there is a change of electrical burns or shock from contact with exposed energized parts. Protective eye or face equipment shall be used if the employee is exposed to electrical arcs/flashes or from flying objects due to electricity.

i. Electrical equipment shall be double insulated or grounded in accordance with subpart K.

j. All temporary lighting must have cage guards over them to prevent breakage of the bulbs and shall be hung by its insulators.

k. Extension cords shall be run so they do not run through doorways, walkways, window, road, unless they are protected and shall be placed to avoid becoming a tripping hazard.

l. A minimum clearance of 10 feet will be maintained from any uninsulated overhead power line and 3 feet from insulated lines less than 300 volts. No work shall be conducted within 10 feet of an overhead power line unless the line has been de-energized and visibly grounded.

m. All 120-volt, single-phase, 15 and 20 ampere receptacle outlets on construction sites, which are not part of the permanent wiring of the building or structure and which are in use by employees, shall have approved ground-fault circuit interrupters (GFCI) for personnel protection. Receptacles on a two-wire single phase portable or vehicle-mounted generator rated no more than 5KW, where the circuit conductors of the generator are insulated from the generator frame and all other grounded surfaces, need not be protected with GFCI. GFCI protection at the receptacle is required only when the receptacle is being used by employees for cord and plug connected equipment. The GFCI protection may be provided by a circuit breaker type GFCI or the receptacle type GFCI (portable type GFCI). The employee must remember to unplug the portable GFCI and take it with him or her when finished using the equipment. Each job site should establish a program of control to ensure that all GFCIs are returned to a designated jobsite location by the end of each scheduled work shift. It is the responsibility of the Safety Manager to implement this program. The Safety Manager and Safety Coordinator is the competent person for training, implementation and monitoring of this program. This program is available at all jobsites in this Safety Manual. If the plant, owner, construction manager or general contractor has another grounding conductor program it shall over take ours.

n. Non Qualified Employees shall be trained in and familiar with electrically related safety practices necessary for their safety.


7.7 Lock Out / Tag Out

a. It is the responsibility of the Safety Manager to implement this program. The Safety Manger will annually assess the program to ensure all requirements and procedures are being followed.

b. This program is to be initiated only if a job site lock out program by the Owner, Construction Manger or General Contractor is not in effect.

c. Pulling fuses is not a substitute for locking out. Anyone could replace it. d. Locking out one source of power may not be enough. Many machines use a

combination of power supplies. e. Don’t guess at what controls apply to what equipment. Your life may depend on it. f. Do not ever assume that the job is too small to merit lock out. Even if the equipment is

deenergized, consider it live until it has been locked and tagged out. Each employee must protect himself and protect others by utilizing proper lock out procedures. No one other than the person who’s signature is on the tag shall remove the lock or tag. Violators of this lock out program will be subject to disciplinary action which may include immediate termination.

g. Before turning equipment back on that has been locked out verify that isolation and deenergization of the machine or equipment has been accomplished.

h. The following lock out procedure should be observed for power sources including, but not limited to, hydraulic, pneumatic, electrical and thermal equipment.

1) The foreman or designated person is to oversee lock-out procedure to assure compliance.

2) The Safety Manager will perform a final evaluation before the lock out procedures begins.

3) Locks and danger tags are to be used for all lock out procedures. The danger tag shall include:

i. Foreman’s signature ii. Employees doing the job iii. Equipment locked out iv. Date initiated and removed

4) Turn off the point-of-operation controls. Disconnected switches should never be pulled while under load, because of the possibility of arching or even explosion.

5) Turn the main power controls (switch, breakers or valve) “OFF”. Where high voltages are involved this responsibility should be assumed by a qualified electrician.

6) After the switch has been opened or the valve closed, the authorized in charge of the employees who are to work on the equipment should place the lock on the control lever or on the multiple lock adapter. At this point the danger tag should be completed and hung on the lock. The tag shall be securely attached and able to endure environmental conditions at the job site. Once the authorized person has placed his lock on the equipment, the authorized person shall place his key in a satellite lock box and all other employees shall lock off on it to ensure the equipment stays locked out until all employees are completed with their work.


7) Try the disconnect or valve to make sure it cannot be moved to “ON”. 8) Try the machine controls themselves, as a test that the main controls are really

“OFF”. 9) As the employees complete the work assignment, their foreman or designated

person shall remove the supplemental “Danger Tag”. 10) The proper person should be notified that the work is finished and the equipment

is operational. i. Employees conducting LOTO shall be trained to ensure that the purpose and function of

the LOTO program are understood by employees and that the knowledge and skills required for the safe application, usage and removal of the energy controls are acquired by employees. All training shall be documented, signed and certified and include the following:

1) Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace and the methods and means necessary for energy isolation and control.

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

3) All other employees whose work operations are or may be in an area where energy control procedures may be utilized, shall be instructed about the procedure and about the prohibition relating to attempts to restart or reenergize machines or equipment which are locked out or tagged out.

4) Retraining shall be conducted for all authorized and affected employees whenever there is a change in their job assignments, a change in machines, equipment or processes that present a new hazard, or when there is a change in the energy control procedure. Retraining shall also take place whenever the employer has reason to believe that there are deviations from or inadequacies in the employee’s knowledge or use of the energy control procedures.

7.8 Hot Work – Welding, Burning, Cutting, Grinding

a. General 1) Only experienced and trained persons shall be allowed to do any type of welding,

burning, cutting or grinding with authorization from a trained supervisor. 2) No one is to do any type of hot work in a hazardous area without proper

instruction and a written permit from the proper authority. 3) Safety concerning hot work is of vital importance. Improper processes can result

in loss of life and property by fire and/or explosions. Therefore, it is essential that safety precaution be observed during all phases of hot work. The use of permits for hot work in a hazardous location is one method of reducing a potentially serious situation from developing. As stated above, no one is to do any type of welding or burning in a hazardous area without a written permit. These permits should be issued by either the owner, general contractor or Safety Department on your particular jobsite. (See Appendix 7.6)


4) Do not conduct hot work so that hot sparks, hot metal or severed sections fall on cylinders, hoses, machinery, legs or feet, flammable material or where they may strike personnel working below.

5) Always wear the proper personal protective equipment: (welder and helper) i. Goggles with proper filter lens ii. Head shield/hood with proper filter lenses iii. Fire retardant gauntlet gloves iv. Shirts with long sleeves, trousers without cuff and high top shoes or boots v. Respirator when burning material that gives off fumes.

6) A fire watch should be established to patrol all exposed areas of the hot work if the potential for a fire exist. The fire watch shall conduct a final inspection 30 minutes have hot work is completed. The fire watch shall be trained in the use of fire extinguishers, how to fight incipient stage fires and how to summon help.

7) Mechanical or local exhaust ventilation shall be provided whenever welding or burning is performed in a confined space. Provide adequate ventilation while torch cutting, welding, and soldering working on galvanized material. Cutting coated steel and rebar may require the use of respirators depending on coating content.

8) Never burn on any closed container that may have held flammable substances without thoroughly purging the container.

9) All exposed combustible materials located below or in the vicinity of the welding and cutting area must be removed to a safe location. If removal is impractical or impossible, the combustible materials should be covered with a fire-retardant material or protected by an approved spark catcher to contain all sparks and slag.

10) Portable fire extinguishers shall be located at each work site. 11) Locate screens around all welding and burning operations, where possible, to

protect fellow employees against burns or flashes. 12) All welding must have a separate and adequate ground cable pulled from the

welding machine and connected to the item being welded and in close proximity to the weld.

13) The frames of all welding machines shall be grounded, using a metal stake of sufficient length that can be driven into solid ground to a depth that will satisfy industry code standards. Alternately, a power company ground may be used.

14) No welding machines shall be in operation within 50 feet of either a control room or field control panel; damage may occur to sensitive equipment through their grounding systems.

15) At the end of each shift or when not in use for extended periods all welding machines shall be turned off.

16) Leads, grounds, clamps, welding machines, hoses, gauges, torches and cylinders shall be inspected before each use. Any faulty or defective equipment shall be reported to the supervisor and the use of the equipment shall be discontinued until its safety has been assured.

b. Gas Welding and Cutting Procedures


1) Valve protection caps shall be in place and secured. 2) Oxygen and acetylene cylinders must be stored and secured in an upright

position. When in storage they must be separated by a 5’ high, 1 hour fire rated wall or 20’ in distance.

3) When cylinders are hoisted they shall be secured on a cradle, sling board or pallet. They shall not be hoisted by means of magnets or choker slings.

4) Never use matches to light torches. Always use a spark lighter. 5) When cylinders are turned off and not in use, remove gauges and roll up hoses. 6) Always inspect the torch, hose and regulators prior to use to ensure each is in

good working order. 7) All fitting, couplings and connections are to be “leak free”. Due to potential leaks,

torches should never be placed in a vessel. 8) Keep oil and grease away from properly cleaned oxygen regulators, hoses and

fittings. Do not store wrenches, dies, cutters or other grease covered tools in the same compartment with oxygen equipment.

9) Cylinders and hoses shall be placed where they are not exposed to sparks and slag from a welding or cutting operation.

10) All torch regulators must contain internal check valves for backflow protection. 11) Welding lead terminals should be protected from accidental electrical contact. 12) Electrode lead cables should be frequently inspected for wear and damage. 13) Connecting cable lugs shall be insulated adequately for the service conditions. 14) Printed rules and instructions covering operations of equipment supplied by the

manufacturers shall be strictly followed. c. Arc Welding and Cutting Procedures

1) Only properly designate electrode holders shall be used. 2) Do not overload welding cables or operate with poor connections. 3) All arc welding and cutting cables shall be completely insulated and free from

repair or splices within 10 feet from the electrode holder. 4) Never strike an arc on cylinders. 5) Always ensure proper grounding of welding machines. 6) When electrode holders are left unattended, remove electrode and protect holder

against electrical contact. 7) Welding lead terminals should be protected from accidental electrical contact. 8) Electrode lead cables should be frequently inspected for wear and damage. 9) Connecting cable lugs shall be insulated adequately for the service conditions. 10) Printed rules and instructions covering operation of equipment supplied by the

manufacturers shall be strictly followed. d. Compressed Gas Cylinders

1) Valve protection caps shall be in place and secured. 2) When compressed gas cylinders are hoisted, they shall be secured on a cradle,

sling board or pallet. They shall not be hoisted or transported by means of magnets or choker slings.


3) Cylinders shall be moved by tilting and rolling them on their bottom edges. They shall not be intentionally dropped, struck or permitted to strike each other violently.

4) When cylinders are transported by powered vehicles, they shall be secured in a vertical position.

5) Valve protection caps shall not be used for lifting cylinders from one vertical position to another. Bars shall not be used under valves or valve protection caps to pry cylinders loose when frozen. Warm, not boiling, water shall be used to thaw cylinders loose.

6) Unless cylinders are firmly secured on a special carrier intended for this purpose, regulators shall be removed and valve protection caps put in place before cylinders are moved.

7) A suitable cylinder truck, chain or other steadying device shall be used to keep cylinders from being knocked over while in use.

8) When work is finished, when cylinders are empty or when cylinders are moved at any time, the cylinder valve shall be closed.

9) Compressed gas cylinders shall be secured in an upright position at all time. 10) Oxygen cylinders in storage shall be separated from fuel gas cylinders or

combustible materials, a minimum distance of 20 feet or by a noncombustible barrier at least 5 feet high having a fire resistance rating of at least one half hour.

11) Inside of buildings, cylinders shall be stored in well protected, well ventilated, dry locations at least 20 feet from highly combustible materials such as oil or excelsior. Cylinders should be stored in definitely assigned places away from elevators, stairs or gangways. Assigned storage places shall be located where cylinders will not be knocked over or damaged by passing or falling objects or subject to tampering by unauthorized persons. Cylinders shall not be kept in unventilated enclosures such as lockers or cupboards.

12) The in plant handling, storage and utilization of all compressed gas cylinders, portable tanks, rail tank cars or motor vehicle cargo tanks shall be in accordance with Compressed Gas Association Pamphlet P-1-1965.

13) Cylinders shall be kept far enough away from the actual welding or cutting operation so that sparks, hot slag or flame will not reach them. When this is impractical, fire resistant shields shall be provided.

14) Cylinders shall be placed where they cannot become part of an electrical circuit. Electrodes shall not be struck against cylinders to strike an arc.

15) Fuel gas cylinders shall be placed with valve end up whenever they are in use. They shall not be placed in a location where they would be subject to open flame, hot metal or other sources of artificial heat.

16) Cylinders containing oxygen or acetylene or other fuel gas shall not be taken into confined spaces.


7.9 Personal Protective Equipment

a. General 1) All PPE shall be provided, used and maintained in a sanitary and reliable

condition. If found to be defective or damaged, PPE shall be immediately removed from service.

2) Each employee shall be trained on when PPE is necessary, what PPE is necessary, how to properly, don, doff, adjust and wear the PPE, the limitation of the PPE and the proper care, maintenance, useful life and proper disposal of the PPE. This training shall be documented for each employee. When Gribbins Insulation Company has determined that workplace changes make previous training obsolete, the type of PPE changes or when an employee demonstrates lack of use, improper use or insufficient skill or understand of the PPE retraining will be conducted.

3) Gribbins Insulation is responsible for the assurances of the adequacy, maintenance, and sanitation of any employee-owned equipment.

4) Selected PPE must be fitted to each affected employee, as detailed in the specific sections below.

b. Respiratory Protection 1) Responsibilities

i. Program Administrator – The Program Administrator is responsible for administering the respiratory protection program. The Program Administrator for Gribbins Insulation is the Safety Manager. Duties of the Program Administrator include: indentifying work areas, processes or task that require workers to wear respirators, and evaluating hazards, selection of respiratory protection options, monitoring respirator use to ensure that respirators are used in accordance with their certifications, arranging for and/or conducting training, ensuring proper storage and maintenance or respiratory protection equipment, conducting qualitative fit testing, administering the medical surveillance program, evaluating the program annually, updating the written program, as needed.

ii. Supervisors – Supervisors are responsible for ensuring that the respiratory protection program is implemented in their particular areas. In addition to being knowledgeable about the program requirements for their own protection, supervisors must also ensure that the program is understood and followed by the employees under their supervision. Duties of the Supervisor include: ensuring that employees under their supervision, including new hires, have received appropriate training, fit testing and annual medical evaluation, ensuring the availability of appropriate respirators and accessories, being aware of task requiring the use of respiratory protection, enforcing the proper use of respiratory protection when necessary, ensuring that respirators are properly cleaned, maintained and stored according to the respiratory protection


plan, ensuring that respirators fit well and do not cause discomfort, continually monitoring work areas and operations to identify respiratory hazards and coordinating with the Program Administrator on how to address respiratory hazards or other concerns regarding the program.

iii. Employees – Each employee has the responsibility to wear his or her respirator when and where it is required and in the manner in which they were trained. Employees must also: care for and maintain their respirator as instructed and store them in clean sanitary location, inform their supervisor if the respirator no longer fits well and request a new one that fits properly and inform their supervisor or the Program Administrator of any respiratory hazards that they feel is not adequately addressed in the workplace and of any other concerns that they have regarding the program.

2) Program Elements i. Selection Procedures

The Program Administrator will select respirators to be used on site, based on the hazards to which workers are exposed and in accordance with all OSHA standards. The Program Administrator will conduct a hazard evaluation for each operation, process, or work area where airborne contaminants may be present in routine operations or during an emergency. The hazard evaluation will include: identification and development of a list of hazardous substances used in the work place, by department, or work process, review of work processes to determine where potential exposure to these hazardous substance may occur. This review shall be conducted by surveying the workplace, reviewing process records, and talking with employees and supervisors, exposure monitoring to quantify potential hazardous exposures. Monitoring will be contracted out

ii. Updating the Hazard Assessment The Program Administrator must revise and update the hazard assessment as needed (i.e., any time work process changes may potentially affect exposure). If an employee feels that respiratory protection is needed during a particular activity, he/she is to contact his or her supervisor or the Program Administrator. The Program Administrator will evaluate the potential hazard, arranging for outside assistance as necessary. The Program Administrator will then communicate the results of the assessment back to the employees. If it is determined that respiratory protection is necessary, all other elements of the program will be in effect for those tasks and this program will be updated accordingly. The program will also be updated per jobsite if different hazards are found not included in the listed program. The Program Administrator will be notified and an assessment will be made on the new hazard then listed in the program.

3) NIOSH Certification


All respirators must be certified by the National Institute for Occupational Safety and Health (NIOSH) and shall be used in accordance with the terms of that certification. Also, all filter, cartridges and canisters must be labeled with the appropriate NIOSH approval label. The label must not be removed or defaced while it is in use. The Program Administrator will evaluate the type of respirator to be worn for the specific hazard. A NIOSH certified respirator will be chosen on the types of protection that is listed by the manufacturer. The Program Administrator will provide all employees who voluntarily choose to wear either of the above respirators with a copy of Appendix D of the standard. Appendix D details requirements for voluntary use of respirators by employees. Employees choosing to wear a half face piece APR must comply with the procedures for Medical Evaluation, Respirator Use and Cleaning, Maintenance and Storage. The Program Administrator shall authorize voluntary use of respiratory protective equipment as requested by all other workers on a case-by-case basis, depending on specific workplace conditions and the results of the medical evaluations.

4) Medical Evaluation Employees who are either required to wear respirators or who choose to wear an APR voluntarily must pass a medical exam before being permitted to wear a respirator on the job. Employees are not permitted to wear respirators until a physician has determined that they are medically able to do so. Any employee refusing the medical evaluation will not be allowed to work in an area requiring respirator use. All examinations and questionnaires are to remain confidential between the employee and the physician. A licensed physician at a location determined by Gribbins Insulation, where all company medical services are provided, will provide the medical evaluations. Medical evaluation procedures are as follows:

i. The medical evaluation will be conducted using the questionnaire provided in Appendix C of the respiratory protection standard. (See Appendix 7.7) The Program Administrator will provide a copy of this questionnaire to all employees requiring medical evaluations.

ii. To the extent feasible, the company will assist employees who are unable to read the questionnaire, by providing help in reading the questionnaire. When this is not possible, the employee will be sent directly to the physician for medical evaluation.

iii. All affected employee will be given a copy of the medical questionnaire to fill out, along with a stamped and addressed envelope for mailing the questionnaire to the company physician. Employee will be permitted to fill out the questionnaire on company time.

iv. Follow up medical exams will be granted to employees as required by the standard, and/or as deemed necessary by the medical clinic physician.


v. All employees will be granted the opportunity to speak with the physician about their medical evaluation, if they so request.

vi. The Program Administrator has provided the medical clinic physician with: a copy of this program, a copy of the respiratory protection standard, the list of hazardous substances by work area and for each employee requiring evaluation, his or her work area or job title, proposed respirator type and weight, length of time required to wear respirator, expected physical work load (light, moderate or heavy), potential temperature and humidity extremes, and any additional protective equipment or clothing required.

vii. Any employee required for medical reasons to wear a positive pressure air purifying respirator shall be provided with one.

viii. After an employee has received clearance and begun to wear his or her respirator, additional medical evaluation will be provided under the following circumstances: employee reports signs and/or symptoms related to their ability to use a respirator, such as shortness of breath, dizziness, chest pains, or wheezing, the medical clinic physician or supervisor informs the Program Administrator that the employee needs to be reevaluated, information from this program, including observations made during fit testing and program evaluation, indicates a need for reevaluation, a change occurs in workplace conditions that may result in an increased physiological burden on the employees.

5) Fit Testing Fit testing is required for employees wearing respirators. Employee voluntarily wearing half face piece APRs may also be fit tested upon request. Employees who are required to wear respirators will be fit tested prior to being allowed to wear any respirator with a tight fitting face piece, when there are changes in the employee’s physical condition that could affect respiratory fit (e.g., obvious change in body weight, facial scarring, etc.) or at least annually. Employees will be fit tested with the make, model and size of respirator that they will actually wear. Employees will be provided with several models and sizes of respirators so that they may find an optimal fit. Fit testing of PAPRs is to be conducted in the negative pressure mode. Fit testing procedures shall be used when conducting all fit test. (See Appendix 7.8) Fit Testing shall be documented on Gribbins Insulation Company’s Fit Testing Form by a competent person. (See Appendix 7.9)

6) General Use Employees will use their respirator under conditions specified by this program, and in accordance with the training they receive on the use of each particular model. In addition, the respirator shall not be used in a manner for which it is not certified by NIOSH or by it manufacturer.


All employees shall conduct user seal checks each time that they wear their respirator. Employees shall use either the positive or negative pressure check specified in Appendix B-1 of the Respiratory Standard. All employees shall be permitted to leave the work area to go to the locker room to maintain their respirator for the following reasons: to clean their respirator if the respirator is impeding their ability to work, change filters or cartridges, replace parts or to inspect respirator if it stop functioning as intended. Employees should notify their supervisor before leaving the area. Employees are not permitted to wear tight fitting respirators if they have any condition, such as facial scaring, facial hair or missing dentures, that prevents them from achieving a good seal. Employees are not permitted to wear headphones, jewelry, or other articles that may interfere with the face piece-to-face seal.

7) Use in IDLH Atmospheres The use of respirators in IDLH atmospheres requires special requirements as follows:

i. One employee or, when needed, more than one employee shall be located outside the IDLH atmosphere.

ii. Visual, voice or signal line communication shall be maintained between the employee (s) in the IDLH atmosphere and the employee(s) located outside the IDLH atmosphere.

iii. The employee(s) located outside the IDLH atmosphere are trained and equipped to provide effective emergency rescue.

iv. The employer or designee is notified before the employee(s) located outside the IDLH atmosphere enter the IDLH atmosphere to provide emergency rescue.

v. The employer or designee authorized to do so by the employer, once notified, provides necessary assistance appropriate to the situation.

vi. Employee(s) located outside the IDLH atmospheres are equipped with: 1. Pressure demand or other positive pressure SCBAs, or a pressure

demand or other positive pressure supplied-air respirator with auxiliary SCBA.

2. And either appropriate retrieval equipment for removing the employee(s) who enter these hazardous atmospheres where retrieval equipment would contribute to the rescue of the employee(s) and would not increase the overall risk resulting from entry or equivalent means for rescue where retrieval equipment is not required under paragraph (g)(3)(vi)(B).

8) Respirator Malfunction

For any malfunction of an APR (e.g., such as breakthrough, face piece leakage or improperly working valve), the respirator wearer should inform his or her supervisor that the respirator no longer functions as intended and go to the designated safe area to maintain the respirator. The supervisor must ensure that


the employee receives the needed parts to repair the respirator or is provided with a new respirator.

9) Cleaning, Maintenance, Change Schedules and Storage i. Cleaning

Respirators are to be regularly cleaned and disinfected at the designated respirator cleaning station located in the employee locker room. Respirators issued for the exclusive use of an employee shall be cleaned as often as necessary. Atmosphere supplying and emergency use respirators are to be cleaned and disinfected after each use. The following procedure is to be used when cleaning and disinfecting respirators: disassemble respirator removing any filters, canisters or cartridges, wash the face piece and associated parts in a mild detergent with warm water (do not use organic solvents), rinse completely in clean warm water, wipe the respirator with disinfectant wipes (70% Isopropyl Alcohol) to kill germs, air-dry in a clean area, reassemble the respirator and replace any defective parts and place in a clean, dry plastic bag or other airtight container. Note: The Program Administrator will ensure an adequate supply of appropriate cleaning and disinfecting material at the cleaning station. If supplies are low, employees should contact their supervisor, who will inform the Program Administrator.

ii. Maintenance Respirators are to be properly maintained at all times in order to ensure that they function properly and adequately protect the employee. Maintenance involves a thorough visual inspection for cleanliness and defects. Worn or deteriorated parts will be replaced prior to use. No components will be replaced or repairs made beyond those recommended by the manufacturer. The manufacturer will conduct repairs to regulation or alarms of atmosphere-supplying respirators. The following checklist will be used when inspecting respirators:

Face piece: cracks, tears or holes, facemask distortion, cracked or loose lenses or facesheild

Head straps: breaks or tears, broken buckles Valves: residue or dirt, cracks or tears in valve material Filter/Cartridges: approval designation, gaskets, cracks or dents

in housing, proper cartridge for hazard Air Supply System: breathing air quality/grade, condition of supply

hoses, hose connection, setting on regulators and valves

Employees are permitted to leave their work area to perform limited maintenance on their respirator in a designated area that is free of respiratory hazards. Situation when this is permitted include to wash their face and respirator face piece to prevent any eye or skin irritation, to


replace the filter, cartridge or canister and if they detect vapor or gas breakthrough or leakage in the face piece or if they detect any other damage to the respirator or its components.

iii. Storage Respirators must be stored in a clean, dry area and in accordance with the manufacturer’s recommendations. Each employee will clean and inspect their own air purifying respirator in accordance with the provisions of this program and will store their respirator in a plastic bag in a secure location. Each employee will have his/her name on the bag and that bag will only be used to store that employee’s respirator.

iv. Defective Respirators Respirators that are defective or have defective parts shall be taken out of service immediately. If, during and inspection, an employee discovers a defect in a respirator, he/she is to bring the defect to the attention of his or her supervisor. Supervisors will give all defective respirators to the Program Administrator. The Program Administrator will decide whether to temporarily take the respirator out of service until it can be repaired, perform a simple fix on the spot such as replacing a head strap or dispose of the respirator due to an irreparable problem or defect. When a respirator is taken out of service for an extended period of time, the respirator will be tagged out of service and the employee will be given a replacement of similar make, model and size.

10) Training The Program Administrator will provide training to respirator users and their supervisor on the contents of the Gribbins Insulation Respiratory Protection Program and their responsibilities under it and the OSHA Respiratory Protection Standard. Workers will be trained prior to using a respirator in the workplace. Supervisors will also be trained prior to using a respirator in the workplace or prior to supervising employees that must wear respirators. See section 9 for training requirements.

11) Costs Respirators, training and medical costs will be provided to the employees at no cost.

12) Program Evaluation The Program Administrator will conduct annually evaluations of the workplace to ensure that the provisions of this program are being implemented. The evaluations will include regular consultations with employees who use respirators and their supervisors, site inspections, air monitoring and a review of records. Problems identified will be noted in an inspection log and addressed by the Program Administrator. These findings will be reported to Gribbins Insulation management and the report will list plans to correct deficiencies in the respirator program and target dates for the implementation of those corrections.


13) Documentation and Recordkeeping A written copy of this program and the OSHA standard is kept in the Program Administrator’s office and is available to all employees who wish to review it. Also maintained in the Program Administrator’s office are copies of training and fit test records. These records will be updated as new employees are trained, as existing employee receive refresher training and as new fit tests are conducted. The Program Administrator will also maintain copies of the medical records for all employees covered under the respirator program. The completed medical questionnaire and the physician’s documented findings are confidential and will remain at the Medical Clinic chosen by Gribbins Insulation. The company will only retain the physician’s written recommendation regarding each employee’s ability to wear a respirator.

c. Eye and Face Protection OSHA requires eye and face protection where there is a reasonable probability of preventing injury when such equipment is used. Gribbins Insulation must provide an ANSI Z87.1 approved type of protector suitable for work to be performed and all employees, including supervisors and management, must use the protectors. Employees must make the necessary effort to keep their protective eyewear in good condition. This includes cleaning and protecting your eyewear when not in use. If your protective eyewear is inadequate or defective turn it in to your foreman for a new pair. The following are different types of eye protection that must be worn in certain situations:

1) Safety Glasses – Required on all jobsites. Additional eye protection maybe required.

2) Goggle Gear – Required when working with Calcium Silicate, Foamglas, Urethane, Perlite, removing exiting insulation or when working in dusty conditions.

3) Face Shield with Safety Glasses/Goggles – Required when grinding or shooting pins.

d. Head Protection 1) Employees working in areas where there is a possible danger of head injury from

impact, falling or flying objects or from electrical shock and burns, shall be protected by protective helmets.

2) Helmets for the protection of employees against impact and penetration of falling and flying objects shall meet the specification contained in ANSI Z89.1-1969. (This should be indicated on a sticker adhered to the inside of the helmet.)

3) Hard hat shall be worn on all jobsites. 4) Hard hats shall be worn with the brim facing forward.

e. Foot Protection Safety-toe footwear for employees shall meet the requirements of ANSI Z41.1. Gribbins Insulation Company will reimburse employee’s $50 on the purchase of a pair of steel toed boots. Employees must work for Gribbins Insulation for one month before they are eligible for this program.

f. Hand Protection


Employees working with metal, sharp materials, pins, corrosives, heat or other conditions that may cause hand injuries shall be protected from those injuries. The following is a list of gloves required for each hazard:

1) Cut Resistant or Kevlar Gloves – Shall be worn when working with metal, using a razor knife or box knife. Safety straight edges shall also be used when cutting metal to ensure that the utility knife does not come over the straight edge and lacerate your fingers. If a safety straight edge is not available, metal and straight edge shall be secured to the cutting table and fingers shall be kept above the blade.

2) Puncture Resistant Gloves – Shall be worn when pushing insulation over weld pins.

3) Heat Resistant Gloves and/or Sleeves – Shall be worn when working around exposed hot equipment or piping and heat tracing.

4) Leather Gloves – Maybe worn during normal material handling. g. Hearing Protection

1) It is the responsibility of the Safety Manager to implement this program. The Safety Manager will oversee training, implementation and monitoring of this program.

2) Training will be provided for all employees that will be required to wear hearing protection. Retraining will be conducted annually.

3) Each jobsite and task will be monitored for noise exposure limits above the requirements of the table below.

4) Protection against the effects of noise exposure shall be provided to all employees, at no cost to the employee, when the sound levels are at or exceed 85 decibels.

5) When our employees are subjected to sound levels exceeding those listing in the table below, feasible administrative or engineering controls shall be utilized. If such controls fail to reduce sound levels within the levels of the table, personal protection equipment shall be provided and used to reduce sound levels within the levels in the table. Hearing protection will be re-evaluated for employee’s that have been exposed and a standard threshold shift has occurred and the employee will be referred for a clinical audiological evaluation or an ontological examination, as appropriate.

6) The hearing protection will be evaluated after worn for the specific noise that the protector was administered.

Permissible Noise Exposures

Duration Per Day, Hours Sound Level DBA Slow Response 8 90 6 92 4 95 3 97 2 100

1 ½ 102


1 105 ½ 110

¼ or less 115 7) Audiometric Testing and Records

i. Gribbins Insulation Company will maintain an audiometric testing program held through a third party testing company for employees who’s exposures equal or exceed and 8 hour time weighted average that meets or exceeds 85 decibels.

ii. This program will include baseline testing after 6 months of the employee’s first exposure and will continue with an audiogram at least 14 hours without exposure to the workplace noise.

iii. Annual testing will be performed for employee’s that have had exposure and will be notified if the comparison of the annual audiogram reflects a standard threshold shift from the previous test. If a standard threshold shift occurs, the employee will be notified in writing within 21 days of the determination.

iv. Records will be kept and made available to all employees exposed to limits over the above table.

7.10 Fire Protection and Prevention

a. Where required and not provided by others Gribbins Insulation will supply 15 lbs. or 25 lbs. ABC Fire Extinguishers.

b. This equipment shall be inspected monthly and maintained in operating condition. Defective equipment shall be immediately replaced.

c. Extinguishers shall be annually inspected for charge and pressure by a third party vendor.

d. A record shall be maintained for each extinguisher to include date of purchase, date used when necessary, inspection dates, recharging dates and repair dates.

e. Employees shall be trained in the method of operation and the hazards involved in fighting incipient stage fires prior to initial assignment. This training shall be provide annually. PASS Pull out the pin, Aim at the base of the fire, Squeeze the handle and Sweep side to side at the base of the fire.

f. Flammable and Combustible Liquids 1) Inside Storage

i. No more than 25 gallons stored in a room outside of an approve cabinet. ii. No more than 60 gallons of flammable or 120 gallons of combustible

liquids shall be stored in any one storage cabinet. iii. No more than three storage cabinets in a single storage area. iv. Four of more cabinets can be stored in a storage room.

2) Outside Storage i. Containers shall not exceed 1,100 gallons in any one pile or area. ii. Piles shall be separated by a 5 foot clearance. iii. Piles and tanks must be at least 20 feet away from buildings. iv. Tanks that exceed 2,200 gallons shall be separated by a 5 foot clearance.


v. Individual tanks that exceed 1,100 gallons shall be separated by a 5 foot clearance.

g. Some form of containment must be used when dispensing liquids whether it be drainage or other means.

h. Flammable liquids shall only be kept in closed containers when not in use. i. Any spill or leak of flammable or combustible liquid shall be disposed of immediately and

safely. j. Do not use flammable liquids when there is an open flame or ignition source within 50

feet. k. Only approved containers and portable tanks shall be used. l. All containers shall be labeled indentifying the flammable or combustible liquid within.

These labels must have the appropriate hazard warning, words, pictures, symbols or a combination of these to warn others.

7.11 Crane and Derricks

a. Any contractor hired by Gribbins Insulation shall comply with the manufacturer’s specification and limitations applicable to the operation of any and all cranes and derricks. Attachments used with cranes shall not exceed the capacity, rating or scope recommended by the manufacturer. A copy of the crane manufacturer’s operating manual shall be available at all times in the cab of each crane. The manufacturer’s load rating plates, in view of the operator, shall be attached to all load hoisting equipment.

b. The contractor shall develop and maintain an inspection program. Rigging equipment shall be certified, inspected and tagged by qualified state, manufacturer or owner representative prior to use, annually and as necessary during use to ensure that equipment is safe.

c. All hoisting machinery shall be inspected monthly by an OSHA recognized competent person using Gribbins Insulation Company’s Crane Inspection Form. (See Appendix 7.14) All inspection forms must be kept for a six month period. A competent person must inspect the machinery prior to each shift.

d. Cranes must not be operated unless all of the devices listed in this section are in proper working order. If a device stops working during operation, the operator must safely stop operation. If any of the devices list in this section are not in proper working order, the equipment must be taken out of service and operation must not resume until the device is again in working properly.

e. Only personnel qualified by training, experience and formal certified testing shall operate cranes and derricks. Upon request, the contractor shall provide qualification and experience resumes for all operators. Operators will be required to wear hard hat identification.

f. Equipment erection and heavy lifts will require a written procedure that must be approved by the Gribbins Insulation representative.

g. When making a lift with a crane, the contractor shall have the area cleared, roped or barricade off and shall have someone supervising the lift. No one shall stand or pass under suspended loads. Tag lines shall be used for controlling loads. Lifting multiple


loads with a single crane is not allowed. Avoid shock loads on cables. Crane booms shall not be subjected to side loads.

h. One person shall be designated to perform signaling either with hand signals or voice communication equipment.

i. Outriggers must be fully extended for any lift. Where cribbing is used under the outrigger, it must only be used under the pedestal. The crane should be properly leveled, as only a few degrees out-of-level will result in a large reduction in the crane’s capacity.

j. Cranes and derricks not in use shall be properly secured. k. During assembly and disassembly of crane booms and derrick section, all components

shall be adequately supported so that these components will not shift or fall. The increased load capacity of tubular crane boom construction results largely from the improved alloy steels used which, in turn, permits the use of thin walled tubing which substantially reduces the weight of the boom. However, such booms are very susceptible to seemingly minor damage, which can and has resulted in failure under load. Any wrinkle or dent in the main chords of such booms or mast shall be reason to have them removed from service until the boom sections are replaced. A competent and qualified employee must direct all assembly and disassembly work.

l. All repairs made to boom and jib lattice section should be performed under the manufacturer’s recommendation and guidelines and by their authorized representative. Unrecorded field repairs shall never be permitted.

m. Operating cranes or equipment in the vicinity of overhead power lines should not start without the special, written approval of the Gribbins Insulation Safety Manager. Approval will include an action plan implemented to ensure safe operation. All equipment must maintain a minimum distance of twenty feet from overhead power lines. Determine the line’s voltage and minimum approach distance permitted in Table A. This plan may include building barricades, warning signs, a limiting device for boom extension, deenergizing and visibly grounding of equipment, use of nylon slings, wearing insulated gloves and boots, and/or limiting access. These are preventive measures. First consideration shall be given to alternative methods and routes that will keep equipment away from these areas or de-energize the power lines. When working near energized lines and equipment, the crane shall be grounded or isolated.

n. Whenever possible with heavy lifts or lifts that are over or into hazardous operating areas, a trial lift shall be performed. This shall entail lifting the load until slightly airborne and then slowly booming out to slightly more than the set radius.

o. A fire extinguisher shall be kept in the crane’s cab or close by. p. The riding of crane hooks and/or “headache balls” is prohibited. q. The use of a crane or derrick to hoist employees in a personnel hoist basket is prohibited

except when the erection, use and dismantling or conventional means of reaching the work site, such as a personnel hoist, ladder, stairway, aerial lift, elevating work platform, or scaffold would be more hazardous or is not possible because of structural design or worksite conditions. If used to hoist personnel hooks on overhaul ball assemblies, lower load blocks, or other attachment assemblies shall be of a type that can be closed and locked, eliminating the hook throat from opening. Alternatively, an alloy anchor type


shackle with a bolt, nut and retaining pin may be used. When it is determined that a personnel hoist basket would be the least hazardous option to reach the work area or other means of access are not possible due to structural design or worksite conditions, the use of a personnel hoist basket must be approved by the Safety Department. Before a personnel hoist basket is used, a Crane Basket Pre Job Worksheet must be completed by the Safety Department, Crane Operator, Supervisor, and employees that are going to be in the basket or involved with the lift. (See Appendix 7.15)

7.12 Rigging

a. Rigging equipment for material handling shall be inspected prior to use on each shift and as necessary during its use to ensure that it is safe. Defective rigging equipment shall be removed from service immediately.

b. Rigging equipment shall not be loaded in excess of its recommended safe working load, as prescribed in Table H-1 through H-20 in this subpart, following 1926.252 (e) for the specific equipment.

c. Rigging equipment, when not in use, shall be removed from the immediate work area so as not to present a hazard to employees.

d. Special custom design grabs, hooks, clamps or other lifting accessories, for such units as modular panels, prefabricated structures and similar materials, shall be marked to indicate the safe working loads and shall be proof-tested prior to use to 125 percent of their rated load.

e. This section applies to slings used in conjunction with other material handling equipment for the movement of material by hoisting. The types of slings covered are those made from alloy steel chain, wire rope, metal mesh, natural or synthetic fiber rope and synthetic web.

f. Each day before being used, the sling and all fastenings and attachments shall be inspected for damage or defects by a competent person designated by Gribbins Insulation Company. Additional inspections shall be performed during sling use, where service conditions warrant. Damage or defective slings shall be immediately removed from service.

g. Natural rope and synthetic fiber: 1) When using natural or synthetic fiber rope slings, Tables H-15, 16, 17 and 18

shall apply. 2) All splices in rope slings provided by Gribbins Insulation Company shall be made

in accordance with fiber rope manufacturer’s recommendations. i. In manila rope, eye splices shall contain at least three full tucks and short

splices shall contain at least six full tucks (three on each side of the center line of the splice).

ii. In layered synthetic fiber rope, eye splices shall contain at least four full tucks and short splices shall contain at least eight full tucks (four on each side of the center line of the splice).

iii. Strand end tails shall not be trimmed short (flush with the surface of the rope) immediately adjacent to the full tucks. This precaution applies to both eye and short splices and all types of fiber rope. For fiber ropes


under 1 inch diameter, the tails shall project at least six rope diameters beyond the last full tuck. For fiber ropers 1 inch diameter or larger, the tails shall project at least 6 inches beyond the last full tuck. In applications where the projecting tails may be objectionable, the tails shall be taped and spliced into the body of the rope using at least two additional tucks (which will require a tail length of approximately six rope diameters beyond the last full tuck).

iv. For all eye splices, the eye shall be sufficiently large to provide an include angle of not greater than 60 degrees at the splice when the eye is placed over the load or support.

v. Knots shall not be used in lieu of splices. 3) Natural and synthetic fiber rope slings, except for wet frozen slings, may be used

in a temperature range from minus 20 degrees F to plus 180 degrees F without decreasing the working load limit. For operations outside this temperature range and for wet frozen slings, the slings manufacturer’s recommendations shall be followed.

4) Spliced fiber rope slings shall not be used unless they have been spliced in accordance with the following minimum requirements and in accordance with any additional recommendations of the manufacturer:

i. In manila rope, eye splices shall consist of at least three full tucks and short splices shall consist of at least six full tucks, three on each side of the splice center line.

ii. In synthetic fiber rope, eye splices shall consist of at least four full tucks and short splices shall consist of at least eight full tucks, four on each side of the center line.

iii. Strand end tails shall not be trimmed flush with the surface of the rope immediately adjacent to the full tucks. This applies to all types of fiber rope and both eye and short splices. For fiber rope under 1 inch in diameter, the tail shall project at least six rope diameters beyond the last full tuck. For fiber rope 1 inch in diameter and larger, the tail shall project at least 6 inches beyond the last full tuck. Where a projecting tail interferes with the use of the sling, the tail shall be tapered and spliced with the use of the sling, the tail shall be tapered and spliced into the body of the rope using at least two additional tucks.

iv. Fiber rope slings shall have a minimum clear length of rope between eye splices equal to 10 times the rope diameter.

v. Knots shall not be used in lieu of splices. vi. Clamps not designed specifically for fiber ropes shall not be used for

splicing. vii. For all eye splices, the eye shall be of such size to provide an included

angle of not greater than 60 degrees at the splice when the eye is placed over the load or support.

5) Fiber rope slings shall not be used if end attachments in contact with the rope have sharp edges or projections.


6) Natural and synthetic fiber rope slings shall be immediately removed from service if any of the following conditions are present: abnormal wear, powdered fiber between strands, broken or cut fibers, variation in the size or roundness of strands, discoloration or rotting or distortion of hardware in the sling.

h. Synthetic webbing (nylon, polyester and polypropylene) 1) Gribbins Insulation Company shall have each synthetic web sling marked or

coded to show: name or trademark of manufacturer, rated capacities for the type of hitch and type of material.

2) Rated capacity shall not be exceeded. 3) Synthetic webbing shall be of uniform thickness and width and selvage edges

shall not be split from the webbing’s width. 4) Fitting shall be:

i. Of a minimum breaking strength equal to that of the sling; and ii. Free of all sharp edges that could in any way damage the webbing.

5) Stitching shall be the only method used to attach end fittings to webbing and to form eyes. The thread shall be in an even pattern and contain a sufficient number of stitches to develop the full breaking strength of the sling.

6) When synthetic web slings are used, the following precautions shall be taken: i. Nylon web slings shall not be used where fumes, vapors, sprays, mists or

liquids of acids or phenolics are present. ii. Polyester and polypropylene web slings shall not be used where fumes,

vapors, sprays, mists or liquids of caustic are present. iii. Web slings with aluminum fittings shall not be used where fumes, vapors,

sprays, mists or liquids of caustic are present. 7) Synthetic web slings of polyester and nylon shall not be used at temperatures in

excess of 180 degrees F. Polypropylene web slings shall not be used at temperatures in excess of 200 degrees F.

8) Synthetic web slings shall be immediately removed from service if any of the following conditions are present: acid or caustic burns, melting or charring of any part of the sling surface, snags, punctures, tears or cuts, broken or worn stitches or distortion of fittings.

i. Shackles and Hooks 1) Table H-19 shall be used to determine the safe working loads of various sizes of

shackles, except that higher safe working loads are permissible when recommended by the manufacturer for specific, identifiable products, provided that a safety factor of not less than 5 is maintained.

2) The manufacturer’s recommendations shall be followed in determining the safe working loads of the various sizes and types of specific and identifiable hooks. All hooks for which no applicable manufacturer’s recommendations are available shall be tested to twice the intended safe working load before they are initially put into use. Gribbins Insulation Company shall maintain a record of the dates and results of such tests.


7.13 Excavation, Trenching and Shoring

a. The area must be cleared, approved and a site specific safety plan must be completed by the Gribbins Insulation representative prior to the start of an excavation. An excavation may be considered a confined space, therefore atmospheric testing may be required.

b. All excavation must have safe access ways, be properly barricaded and shall have a flashing light barricade at night. Spoil dirt may be used to barricade one side of a ditch or similar excavation. All dirt must be piled at least three feet back from the edge of an excavation and must be at least three feet high when used as a barricade.

c. All excavations four feet or deeper into which personnel may be allowed to enter, no matter how brief, shall be shored, benched and/or sloped to comply with OSHA requirements.

d. Access and egress ladders are required in any excavation at a minimum of every 25 feet of lateral travel per OSHA regulation.

e. Gribbins Insulation will have a competent person, as defined by OSHA, supervising all excavation work. The competent person shall inspect the excavation daily before work begins and after significant amount of rain or other conditions that may increase hazards. The competent person shall complete annual refresher training.

f. All soils are to be considered Class “C” unless a soil laboratory determines and documents otherwise.

g. All excavations shall be inspected daily using Gribbins Insulation Excavation Inspection form. (See Appendix 7.10)

h. All walkways over a trench/excavation shall have guardrails, if they are 6 feet or more above the bottom of the trench/exaction.

i. All adjacent structures shall be supported to prevent a collapse. j. Check all excavation walls before entering and after a heavy rain or thaw. Inspect

shoring daily or more often in extremely wet weather. k. Nobody is permitted in an excavation while equipment is being used next to the edge. l. All excavations within three feet of a known active underground pipeline, conduit or

cable shall be hand probed and dug using insulated tools. If the underground utility cannot be found, all work shall stop at this location and the Gribbins Insulation field representative shall be notified.

m. No employee is permitted to enter a trench or excavation without being properly trained.

7.14 Signs, Signals and Barricaded

a. At locations where potential hazards exist, the foreman shall be responsible for posting, installing, maintaining and enforcing signs, signals and barricaded to direct personnel or vehicles.

b. Barricades must be 42 inches high, square and level. Barricades should be kept four feet back from the edge or excavations, holes, platforms and roofs.

c. The foreman shall be responsible for attaching danger tags to a piece of equipment or part of structure to warn of potential or immediate hazards.


d. When flag people are used, they must wear red or orange. The signal flags must be red and at least eight inches square. Crane and hoist signal used will be the same as approved by ANSI.

e. Hard, rigid barricade should be installed any time there is an open hole or potential of a fall.

7.15 Hand and Power Tools

a. All tools that are designed to have guards shall have these guards in place while in use. b. Any belts, gears, pulleys, spindles, shafts, sprockets, drums, fly wheels, chains or other

rotating, reciprocated or moving parts shall be guarded if they present a hazard. c. Methods of machine guarding shall be provided to protect the operator and other

employees in the area from hazards associated with the point of operation, rotating parts, flying chips or sparks, etc. Examples of guarding would be barrier guards, two hand tripping devices, electronic safety devices, etc.

d. Point of operation is the area of the machine where work is actually performed upon the material being processed. Any of these points that expose employees to hazards shall be guarded.

e. Power saws, portable power tools, guillotine cutters, shears, power presses are all examples of machines which require point of operation guarding.

f. Hand tools for placing and removing materials shall be such as to permit easy handling of material without the operator placing a hand in the danger zone.

g. Any fan with the periphery of the blades is less than 7 feet above the floor or working level, the blades shall be guarded. These guards shall have openings no larger than ½ inch.

h. Machines that are designed for a fixed location shall be securely anchored to prevent walking or moving.

i. Safety guards of the types where the operator stands in front of the opening shall be constructed so that the peripheral protection member can be adjusted to the constantly decreasing diameter of the wheel. The maximum angular exposure above the horizontal plane of the wheel spindle.

j. All hand and power tools shall be inspected daily prior to use for defects. Any equipment that is found to be defective shall be red tagged and removed from service. The piece of equipment shall not return to service unless repaired and documented by a qualified repair man.

k. All electric power operated tools shall be of the approved double insulated type or grounded in accordance with subpart K.

l. Never use electrical cords for hoisting or lowering a tool. m. Each tool shall be looked at before and during use to determine what PPE is necessary

for that tool.

7.16 Powder Actuated Tools

a. No employee shall operate a powder actuated tool unless they have been trained and certified on operating each specific tool.


b. Tools shall be tested each day before loading in accordance with the manufacturer’s recommendations to insure all safety devices are working properly.

c. Never use powder actuated tools in an explosive or flammable atmosphere. d. Before each use check the tool to insure that all manufacturer’s recommended shields,

guards and attachment are in place. e. Never drive fasteners into very hard or brittle materials such as cast iron, glazed tile,

glass block, hollow tile, etc. f. Never drive into easily penetrated materials unless the material is backed by a

substance that will prevent the pin or fastener from passing completely through and creating a flying missile hazard on the other side.

g. Fasteners shall not be driven into a spalled area caused by an unsatisfactory fastening. h. PPE shall be in accordance with Subpart E of this section.

7.17 Pneumatic Tools

a. Pneumatic tools shall be secured to the hose or whip by some positive means to prevent the tool from becoming accidentally disconnected.

b. Safety clips or retainers shall be securely installed and maintained on pneumatic impact tools to prevent attachments from being accidentally expelled.

c. All pneumatically driven nailers, staplers and other similar equipment provided with automatic fastener feed, which operate at more than 100 p.s.i. pressure at the tool shall have a safety device on the muzzle to prevent the tool from ejecting fasteners unless the muzzle is in contact with the work surface.

d. Compressed air shall not be used for cleaning purposes. e. The manufacturer’s safe operating pressure for hoses, pipes, valves, filters and other

fittings shall not be exceeded. f. The use of hoses for hoisting or lowering tools shall not be permitted. g. All hoses exceeding ½ inch inside diameter shall have a safety device at the source of

supply or branch line to reduce pressure in case of hose failure. h. Airless spray guns of the type which atomize paints and fluids at high pressure (1,000

pounds or more per square inch) shall be equipped with automatic or visible manual safety devices which will prevent pulling of the trigger to prevent release of the paint or fluid until the safety device is manually released.

i. In lieu of the above, a diffuser nut which will prevent high pressure, high velocity release, while the nozzle tip is removed, plus a nozzle tip guard which will prevent the tip from coming into contact with the operator or other equivalent protection, shall be provided.

j. The blast cleaning nozzles shall be equipped with an operating valve which must be held open manually. A support shall be provided on which the nozzle may be mounted when it is not in use.

k. Employees shall be properly trained before operating any pneumatic tool. l. Tools shall be inspected before each use and if found to be defective immediately

tagged and removed from service.


7.18 Housekeeping

a. All extension cords, hoses, equipment, materials, debris, etc. shall be place out of walkways and off of stairs.

b. Work areas shall be kept in a sanitary condition. c. Work areas shall be free of loose boards, holes, protruding nails and splinters. d. Waste, trash, oily and used rags and other refuse shall be separated in provided

containers. e. Waste containers holding garbage, oily, flammable or hazardous waste shall be covered. f. Garbage, scrap material and other waste shall be disposed of at frequent regular

intervals. The amount of containers needed for waste removal shall be determined before work begins.

g. All loose material that could become airborne shall be secured. h. Housekeeping shall be completed at frequent, regular intervals. It should not be

completed once a day.

7.19 Asbestos Awareness

a. Purpose To make our employees aware of the health effects caused by asbestos and how to identify potential sources of asbestos fiber. Gribbins Insulation does not engage in asbestos removal and employees are prohibited from handling asbestos containing materials (ACM) or entering controlled areas where ACM is being removed. Employees who work in areas that contain asbestos or may contain asbestos will be asbestos awareness trained and this training documented.

b. Recognition Asbestos is a mineral fiber mined from natural deposits. The most common form of asbestos used in construction is Chrysotile, a whitish mineral fiber. Other types used include Amosite, used in elbows and around boilers, and Crocidolite. In construction, asbestos was used prominently in fire protection, insulation, wrapping of boilers, hot water and steam pipes, textiles, plasters, ceiling tile, floor tile, siding and roofing materials. Asbestos was a popular building material because of its natural fire retardant properties. Asbestos is found in the majority of building built or remodeled between 1930 and 1976 such as schools, hospitals, offices, homes, power plants, refineries and chemical plants. It is most dangerous when disturbed, sending microscopic fibers into the air to be inhaled by workers. Materials are considered to be ACM when they contain more than 1% of asbestos fiber by weight and shall be handled in accordance with applicable OSHA and EPA standards. Gribbins Insulation does not engage in asbestos removal and employees are prohibited from handling ACM. Employees will follow all warning signs and labels and will not disturb any ACM. Employees who suspect that ACM is present shall notify their supervisor immediately. The Safety Manager or other person competent in the recognition of asbestos shall inspect the suspected ACM. If the material is found to be ACM, work will cease in that area immediately and the property owner will be notified. Gribbins Insulation Company will take steps to protect our workers from exposure


including, notify the contractor conducting the work, removing employees from the area and notifying the General Contractor, Construction Manager or Owner.

c. Health Affects Diseases related to asbestos exposure include:

1) Asbestosis – Scarring of lung tissue that may become so severe that the lungs are unable to get enough oxygen to the bloodstream and vital organs. Symptoms include coughing, shortness of breath and a tightness or pain in the chest. Causes of death include heart failure, respiratory infections or the later development of lung cancer.

2) Lung Cancer – Malignant tumors may grow in the lungs. Symptoms include cough or change in cough habit and chest pain.

3) Pleural Mesothelioma – Malignant tumors may grow in the lining of the chest or abdominal cavity. Symptoms include shortness of breath, pain in the chest wall, weight loss and cough. Death usually occurs one year after diagnosis.

4) Gastrointestinal Cancer – Tumors may grow in parts of the digestive tract, esophagus, stomach, colon or pancreas.

Risk of getting asbestos related diseases depends upon the following: level of asbestos exposure, which is the primary consideration, length of exposure and smoking habits, smokers are more susceptible than non-smokers. Symptoms could occur as much as 10-40 years after exposure.

Asbestos fibers get into the lungs by being inhaled through the mouth or nose. The fibers are so small, that they body’s natural defense against inhalation of dusts are ineffective. Asbestos fibers reach all parts of the lungs and injure the lungs by scarring the tissue. As scar tissue develops, the lungs are less able to transfer oxygen from the air to the bloodstream and transfer carbon dioxide from the bloodstream to the air. Some scarring may also result in the growth of cancerous tumors. The smallest fibers of asbestos are smaller than human cells and the fibers can migrate into other parts of the body. Ingested asbestos fibers may damage the stomach and intestinal tract.

7.20 Warehouse Safety

a. Where mechanical handling equipment is used, sufficient safe clearances shall be allowed for aisle, at loading docks, through doorways and wherever turns or passages must be made.

b. Aisles and passages shall be kept clear. c. Permanent aisles and passageways shall be appropriately marked. d. Storage of materials shall not create a hazard. Storage of materials shall be limited in

height so that it is stable and secure against sliding or collapse. e. Proper housekeeping shall be maintained. f. Steel chocks shall be provided and employees instructed to place them under the rear

wheels to prevent highway type trucks and trailers from rolling while they are being loaded or unloaded with powered industrial trucks.


g. Lift truck nameplates and marking shall be affixed in place and maintained in legible condition.

h. Lift trucks shall be equipped with overhead protection. i. Lift trucks equipped for lifting personnel shall have a platform with standard guardrails,

intermediate rails and toe boards and a mast 72 inches in height, all securely fastened to the lifting carriage or forks.

j. In battery changing and servicing areas the employer shall: 1) Provide facilities for quick drenching or flushing of the eyes and body to

neutralize spilled electrolyte. 2) Provide fire protection. 3) Provide protection to charging apparatus to prevent damage by trucks. 4) Provide adequate ventilation for exhaust fumes. 5) Provide signs prohibiting open flames or smoking.

k. When a powered industrial truck is left unattended, load engaging means shall be fully lowered, controls shall be neutralized, power shut off and brakes set.

l. Only trained and authorized operators shall be permitted to operate a powered industrial truck. Documentation is required.

m. All exits shall be marked by a readily visible sign. Every exit sign shall be suitably illuminated by a reliable light source giving a value of not less than 5 foot candles on the illuminated surface. “WAY TO EXIT” signs should be displayed for ease of locating exits.

n. All automatic sprinkler systems shall be continuously maintained, periodically inspected and tests shall be made to assure proper maintenance.

o. Portable fire extinguishers shall be maintained in a fully charged and operable condition, and kept in their designed location at all times. Extinguishers shall be conspicuously located where they will be readily accessible and immediately available in the event of a fire. Extinguisher location shall be marked. Extinguishers shall be inspected monthly to insure they have not been actuated or tampered with, and to detect any obvious physical damage, corrosion or other impairments. A record of this inspection must be maintained.

p. Warehouse storage of flammable and combustible liquids shall be in accordance with the attached table for Class A, B, C, II, III class liquids.

1) Class A – Includes liquids having a flashpoint below 73 degrees Fahrenheit and having a boiling point below 100 degree Fahrenheit.

2) Class B – Includes liquids having a flashpoint below 73 degrees Fahrenheit and having a boiling point at or above 100 degree Fahrenheit.

3) Class C – Includes liquids having a flashpoint at or above 73 degrees Fahrenheit and a boiling point below 100 degrees Fahrenheit.

4) Class II – Includes liquids having a flashpoint at or above 100 degrees Fahrenheit and a boiling point below 140 degrees Fahrenheit.

5) Class III – Includes liquids having a flashpoint at or above 140 degrees Fahrenheit.


7.21 Metal Fabrication Facilities

a. All metal fabrication equipment shall be maintained per the manufacturer’s recommended preventative maintenance program. Documentation of the preventative maintenance performed and the maintenance schedule is to be maintained.

b. Each person qualified or certified to operate such equipment must be trained by a competent person and this training must be documented and filed in the employee’s personnel file.

c. All equipment shall have safety protective guards/devices to insure against an inadvertent maiming injury or accident.

d. Lighting shall be provided equal to or greater than 10 foot candles for all machinery operation areas.

e. Strict adherence to Gribbins Insulation lockout/tagout procedures shall be implemented whenever maintenance on equipment is conducted.

f. Housekeeping must be maintained at the level that eliminates the potential for related injury or accidents.

g. The Hazard Communication Program must be implemented and maintained per the requirements of Section 7 of this manual.

h. Fire extinguisher locations, exit markings and ways to exit shall be marked in accordance with OSHA regulation.

i. The storage of flammable and combustible liquids shall be in accordance with the standard as indicated on the table under warehouse safety in this section.

j. All welding operations must be in accordance with the requirements of the welding program in this section.

k. Oxygen and acetylene cylinders must be stored and secured in an upright position. When in storage, they must be separated by a 5 foot high, 1 hour rated wall or 20 feet in distance.

l. All employees are required to wear the appropriate personal protective equipment as the specific job assignment may dictate. This includes, but is not limited to hard hat, safety glasses, hearing protection, respiratory protection, gloves, welding shield, gauntlet gloves/sleeves, work boots and goggles.

7.22 Insulation Fabrication Facilities

a. Protection against the effects of exposure to fibrous material shall be provided for all workers for nuisance dust and abrasives. Engineering controls must be implemented to the extent feasible (i.e. proper ventilation of work areas.)

b. Air samples shall be taken in the work area and the reports maintained on file. If there is a significant change in equipment, procedures, environmental control system, etc., new air samples shall be taken. Air sampling results should be kept below the specific OSHA PEL Standard through engineering controls whenever and wherever feasible.

c. Work station design shall be adjusted to suit individual requirements to the extent feasible, while meeting the functional requirements of the operation. Appropriate ergonomic factors include, but are not limited to: proper chair lumbar support, chair


height, swivel or stationary seat, optimum standing, working height for work tables and lighting. These ergonomic factors must be considered to maintain optimum work conditions, create the least amount of injury exposure.

d. When possible mechanized material handling equipment shall be used. All employees required to operate any mechanized equipment must be fully trained by a competent person. All training must be documented and that documentation filed in the employee’s personnel file.

e. Fire extinguisher locations, exit markings and ways to exits shall be marked in accordance with OSHA regulations. See Warehouse Safety in this section.

f. Housekeeping must be maintained at a level that eliminates the potential for related injury accidents.

g. The Hazard Communication Program must be implemented and maintained per the requirements of Section 7 of this manual.

7.23 Hazard Communication Program

a. Objectives Gribbins Insulation’s Hazard Communication Program shall be implemented and maintained at all locations. This program explains the procedures used to:

1) Ensure that our employees are provided with necessary information regarding hazardous products to which they may be exposed in the work place.

2) Provide adequate training for their safe handling and use, including emergency procedures in the case of explosion, fire, leak or spill, and training for hazards associated with non-routine tasks.

3) Provide a list of the hazardous products known to be present. 4) Maintain appropriate Material Safety Data Sheets, making copies available to

employees. 5) Inform other employees at the job site of hazardous products that we use,

including labeling system used, any precautionary measures that need to be taken to protect employees during normal and emergency conditions and making available copies of Material Safety Data Sheets.

6) Making available this written Hazard Communication Program to employees and Department of Labor Personnel upon request.

b. Labels and Other Forms of Warning 1) Each container or hazardous product received from a Manufacturer, Importer or

Distributor shall be delivered with a hazardous warning label affixed. This warning label must identify the hazardous product(s) contained, contain appropriate hazard warnings and contain the name and address of the Manufacturer, Importer or other responsible party.

2) These labels must remain intact at all times. If the label is destroyed or defaced in any manner that renders it unreadable, we must immediately provide a new label for the container or package. The new label shall contain the same information as the Manufacturer’s label.


3) If we put the contents of an original container or package into another container or package, we must label that container or package also. Example: Pouring glue into a glue gun. The glue gun must have the same type of label as the original container. Exception: It is not required to label portable containers into which hazardous products are transferred from labeled containers and which are intended only for the immediate use of the employee who performs the transfer.

4) All labels or other forms of warning must be legible and prominently displayed on the container(s). All labels and warnings shall be in the English language. In areas where we have employees who speak other languages, the label or warning information may be presented in their language in addition to the required English language information.

5) At any location in which Gribbins Insulation acts in the capacity of a Distributor, supplying products to other Distributors or employees, the person preparing the order for shipment shall ensure each container of hazardous products leaving our facility is labeled, tagged or marked with the following information: identity of the hazardous product, appropriate hazard warnings and name and address of the product Manufacturer, Importer or other responsible party.

6) Manufacturers warning labels shall not be damaged or defaced. If labels are illegible, we must immediately affix a new label which has all the information contained on the original label. Care shall be taken to label in the same manner as the manufacturer so as not to conflict with the requirements of the Hazardous Materials Transportation Act or a substance-specific health standard regulated by OSHA.

7) Stationary process containers may be labeled by use of signs, placards, process sheets, batch tickets, operating procedures or other written material in lieu of affixing labels to each stationary container as long as the label identifies the hazardous product and contains the appropriate hazard warning. Such written material shall be readily available to employees during each work shift.

c. Material Safety Data Sheets (MSDS) 1) Gribbins Insulation installs products which are manufactured or imported by

others. Each product purchased must be delivered with a corresponding Material Safety Data Sheet (MSDS). If the MSDS is not provided, one must be obtained immediately. This can be done by requesting a copy from the supplier. MSDS(s) should be requested at the time we initially order the product.

2) Each MSDS shall be in English and include the following data as a minimum: Manufacturers name, address and emergency telephone number Trade name used on the label The product and common name(s) of the product The product and common name(s) of all hazardous ingredients Physical and chemical characteristics (such as appearance, vapor

pressure, solubility, etc.) Fire and explosion hazard data (such as flash point, extinguishing media,

special fire fighting procedures and unusual hazards)


Health hazard data (such as symptoms and effects of overexposure, primary route(s) of entry, exposure limit, whether the hazardous product has been identified as a potential carcinogen)

Emergency and first aid procedures Reactivity (such as incompatibility with other materials, conditions to

avoid and hazardous decomposition products) Procedures for spills or leaks, including waste disposal method Special protection information (such as appropriate engineering controls,

work practices, personal protective equipment and appropriate hygiene practices)

Precautions for safe handling and storage Date of preparation of the MSDS

3) Each MSDS will be maintained on file and be readily accessible at the job site during the work shift.

4) When employees are required to work at more than one job site during their shift, MSDS information shall be made immediately available to them in any emergency situation.

5) At any location in which Gribbins Insulation shall act in the capacity of a Distributor, supplying products to other Distributors or Employers, appropriate MSDS(s) shall be provided with the initial product shipment and with the first shipment after a MSDS is updated.

d. Employee Information and Training 1) Gribbins Insulation shall provide its employees with information and training on

hazardous products in their work area at the time of their assignment to the job site and whenever a new product is introduced into their work area.

2) Training shall be included as part of the job site orientation program for all personnel. Each employee shall be informed by his or her Foreman, Superintendent or other qualified person of any operations in the work area where hazardous products are present, be provided a list of the hazardous products and MSDS(s) when requested.

3) See section 9 for training requirements. 4) Additional information shall be provided when any new hazardous product(s) are

introduced into the work place. 5) Each training session shall be documented on the standard “Weekly Safety

Meeting Report” form. The documentation shall list the products/chemicals discussed, names(s) of employee(s) present, date and trainer signature.

e. Jobsite Inventory List of Hazardous Products The lead Foreman or other designated person at large job sites shall maintain a Job Site Inventory List of the hazardous products know to be present using an identity that is referenced on the appropriate MSDS. This reference will then make each MSDS(s) readily accessible for each product listed on the inventory list. The on-site inventory and MSDS(s) shall be made available to our employees upon request. (See Appendix 7.11)

f. Multi-Employer Job Sites


We regularly work on job sites with several other employers. It is the responsibility of our job site supervision to inform other contractors of the hazardous products that we will be using at that jobsite. A letter shall be sent to each contractor (unless contract responsibilities mandate that all correspondence between sub-contractor be sent through the General Contractor or Construction Manager, in which case we will request the letter be forwarded to each contractor) informing them of our Hazard Communication Program. Note: Sample letter should be copied onto company letterhead. The sample letter includes: a Job Site Inventory List of our hazardous products, MSDS(s) availability and location, all precautionary measures and labeling requirements. (See Appendix 7.12)

g. Responsibilities 1) It is the responsibility of our Management to ensure that this program is

implemented at each job site. 2) The Lead Supervisor (Project Manager, Superintendent or Foreman) at each job

site shall be responsible for field implementation. The Supervisor shall ensure compliance with product labeling, MSDS(s), Employee Training, Job Site Inventory list, notification of other contractors at multi-employer job sites, and keeping all records required. The Supervisor shall ensure that all employees have received training.

h. Hazardous “Non-Standard” (Non-routine) Task 1) Prior to beginning a non-routine task the foreman (supervisor) shall instruct the

employees about the hazards of the products/chemicals to which they may be exposed. The training shall be conducted on a Tool Box Safety Meeting Report forms.

2) The training will include: specific product/chemical hazards (review of MSDS), safety measures that will be taken, measures taken to reduce the hazard (ventilation, respirators, etc.) and emergency procedures if different from standard job site procedures.

7.24 Process Safety Management (PSM)

a. Background The Department of Labor PSM Standard, 29 CFR 1910.199 established procedures for PSM that will protect employees by preventing or minimizing the consequences of chemical accidents involving catastrophic releases of toxic, reactive, flammable, or explosive chemicals. A portion of this Standard, 29 CFR Part 1910.119(h) applies to Contractors performing maintenance or repair, turnaround, major renovations or specialty work on or adjacent to operations covered by this Standard.

b. Owner Responsibilities 1) The Owner, when selecting a Contactor, shall obtain and evaluate information

regarding the Contractor’s safety performance and programs. Information that may be requested:

A written Safety Policy endorsed by top management A copy of the Contractor’s Safety Program Manual An on-site staffing plan for Safety Program Implementation


The Contractor’s Experience Modification Rate The Contractor’s Disciplinary Procedures A copy of the Contractor’s Orientation Program. A description of the Contractor’s Safety Incentive Program A copy of the Contractor’s program/policy related to alcohol/controlled

substances A list of the Contractor’s experience on similar projects A description of the Contractor’s Inspection Procedures A description of how the Contractor’s Supervisors are held accountable

for safety performance.

(This list is not all-inclusive, rather, it provides examples of the kind of information that prospective customers may seek to acquire before they begin the Contractors selection process.)

2) The Owner is required to inform the Contractor of the known potential fire, explosion or toxic release hazards related to the Contractor’s work and the process.

3) The Owner is required to explain to the Contractor’s the applicable provisions of the facilities emergency action plan.

4) The Owner is required to develop and implement procedures to control the entrance, presence and exit of the Contractor’s employees in the work area covered by this Standard.

5) The Owner is required to periodically evaluate the Contractor’s performance in fulfilling the requirements of this Standard.

6) The Owner shall maintain a construction employee injury and illness log related to the Contractor’s work in the process areas covered by this Standard.

c. Contractor Responsibilities 1) Gribbins Insulation is responsible to assure that each employee is trained in the

work practices necessary to safely perform the job. This training shall be provided in conjunction with the Owner’s site Safety Program.

2) Gribbins Insulation is responsible/required to assure that each employee is instructed in the known potential fire, explosion or toxic release hazards related to his/her job and the process and applicable provisions of the Owner’s site emergency action plan.

3) Gribbins Insulation shall document that each employee has received and understood the training as described under General Safety Rules and Standards Common to the Construction Industry of this Section. This documentation must contain employee’s name, date of training and means used to verify that the employee understood the training. *Gribbins Insulation is required to develop a written test regarding the training described under General Safety Rules and Standards Common to the Construction Industry in this Section. This test must be administered by and the Safety Department and graded. It is required that the employee pas this test


because the Standard requires the employees understanding the information discussed in the training. For purposes of testing, a 70% test score or above will be needed for a passing grade. The written test will be developed for each job with the appropriate questions related to the specific requirements of each job.

4) Gribbins Insulation is responsible to assure that our employees are following general and specific safety rules and safe practices. This will be accomplished by conducting a formal Safety Inspection. (Use the Safety Inspection Checklist form to document compliance with this requirement.)

i. The Owner’s safe work practices must be followed during operations such as lockout/tagout, confined space entry, opening process equipment or piping, and controls over entrance to facility.

5) Gribbins Insulation is responsible to advise the Owner or Customer of any unique hazards presented by our work or found by our employees. This notification must be documented. (Suggestion: Notification must be in letter form on Company letterhead stationary.)

6) Gribbins Insulation employees shall not perform hot work until a hot work permit is obtained from the owner. The permit shall document that the fire prevention and protection requirements have been implemented prior to beginning the hot work operations.

7) Employees must immediately report all accidents, injuries, and near misses. An incident investigation will be initiated within 48 hours. Resolutions and corrective actions will be documented and maintained for 5 years.

8) Gribbins Insulation is responsible for respecting the confidentiality of trade secret information when the process safety information is released to us.

7.25 Equipment Tagging Procedures

a. A qualified person (s) shall be designated to assume the responsibility for maintaining all job site equipment and tools. (Not to include “heavy equipment”.)

b. Employees shall inspect tools and/or equipment prior to each use to ensure safe and proper working conditions.

c. If tool or equipment is found to be damaged or fails during operation, return it to the designated job site location (tool room) to be red tagged for repair or disposal.

d. A green tag on equipment verifies the equipment is 100% safe and usable. e. A yellow tag on equipment will have precaution listed. Employees of Gribbins Insulation

must abide by these precautions while using that equipment. f. A red tag on equipment verifies that the equipment is out of service and shall not be

used or worked on. g. Equipment and tools shall be properly maintained at all times to ensure a safe work

condition. Properly maintained equipment will benefit everyone.


7.26 Lead

a. These requirements apply to all construction activities where an employee may be occupationally exposed to lead. Construction activities include, but are not limited to the following: demolition or salvage of structures where lead or materials containing lead are present, removal or encapsulation of materials containing lead, new construction, alteration, repair or renovation of structures, substrates or portions thereof that contain lead, installation of products containing lead, lead contamination, emergency clean up, transportation, disposal, storage or contaminant of lead or materials containing lead on the construction site or maintenance operation associated with construction activities.

b. Definitions 1) Action Level – Employee exposure, without regard to the use of respirator, to an

airborne concentration of lead of 30 micrograms per cubic meter of air (30 ug/m3) calculated as an 8 hour time weighted average (TWA).

2) Competent Person – One who is capable of identifying existing and predictable lead hazards in the surrounding or working conditions and who has authorization to take prompt corrective measures to eliminate them.

3) Lead – Metallic lead, all inorganic lead compounds, and organic lead soaps. Excluded from this definition are all other organic lead compounds.

c. Permissible Exposure Limit The employer shall assure that no employee is exposed to lead at concentrations greater than fifty micrograms per cubic meter of air (50 ug/m3) averaged over and 8 hour period. When respirators are used to limit employee exposure, then the employee exposure may be considered to be at the level provided by the protection factor of the respirator for those periods the respirator is worn.

d. Exposure Assessment 1) Initially we shall determine if any employee may be exposed to lead at or above

the action level. 2) Under the monitoring requirements, we shall collect personal samples

representative of a full shift, including at least one sample for each job classification in each work area either for each shift or for the shift with the highest exposure level.

3) With respect to lead related tasks, until the employer performs an employee exposure assessment and documents that the employee performing the task is not exposed above the PEL, the employer shall treat the employee as if he/she were exposed above the PEL and not in excess of ten times the PEL, shall implement employee protective measures prescribed as follows: appropriate respiratory protection, appropriate personal protective clothing and equipment, change area, hand washing facility, biological monitoring to consist of blood sampling and analysis for lead and zinc protoporphyrin levels and training required for hazard communication, respirator and personal hygiene.

4) Where the employer has previously monitored for lead exposure, and the data was obtained within the past 12 months during work operations conducted under


workplace conditions closely resembling the processes, type of material, control methods, work practices and environmental conditions used and prevailing in the employer’s current operation, the employer may rely on such earlier monitoring results. Where the employer has objective data, demonstrating that a particular product or material containing lead or a specific process, operation or activity involving lead cannot result in employee exposure to lead at or above the action level during processing, use or handling, the employer may rely upon such data instead of implementing initial monitoring.

e. Positive Initial Determination and Initial Monitoring 1) Where a determination shows the possibility of any employee exposure at or

above the action level the employer shall conduct monitoring which is representative of the exposure for each employee in the workplace who is exposed to lead.

2) Where a determination is made that no employee is exposed to airborne concentrations of lead at or above the action level the employer shall make written record of such determination. This record shall include: location within the work site, name and social security number of each employee monitored, any information, observation or calculation which would indicate employee exposure to lead, any previous measurements of airborne lead and any employee complaints of symptoms which may be attributed to exposure to lead.

f. Frequency If the initial determination or subsequent determination reveals employee exposure to be at or above the action level, but at or below the PEL, the employer shall perform monitoring at least every six months. If the initial determination reveals that employee exposure is above the PEL, the employer shall perform monitoring quarterly.

g. Additional Exposure Assessments Whenever there has been a change of equipment, process, control, personnel or a new task has been initiated that may result in employees being exposed above the PEL, the employer shall conduct additional monitoring.

h. Employee Notification Within five working days after completion of the exposure assessment the employer shall notify each employee in writing of the results which represent that employee’s exposure. Whenever the results indicate that the representative employee’s exposure, without regard to the use of a respirator, is at or above the PEL the employer shall include in the written notice a statement that the employee’s exposure was at or above that level and a description of the corrective action taken or to be taken to reduce exposure to below that level.

i. Method of Compliance Engineering and work practice controls shall be implemented to reduce and maintain employee exposure to lead below the PEL to the extent that such controls are feasible. Whenever these controls are not sufficient to reduce employee exposure, the employer


shall, nonetheless use them to reduce employee exposure to the lowest feasible level and shall supplement them by the use of proper PPE.

j. Compliance Program Prior to the commencement of the job, the employer shall establish and implement a written compliance program to achieve compliance with this standard. Written plans for these job compliance programs shall include as a minimum: A description of each activity in which lead is emitted, equipment used, material involved, controls in place, crew size, employee job responsibilities, operating procedures and maintenance practices. A description of the specific means that will be employed to achieve compliance and where engineering controls are required engineering plans and studies used to determine methods selected for controlling exposure to lead. Air monitoring data which documents the source of lead emissions. A detailed schedule for implementation of the program, including documentation such as copies of purchase orders for equipment, construction contracts, etc. A description of arrangements made among contractors on multi-contractors sites with respect to informing affected employees of potential exposure to lead. The compliance program shall provide for frequent and regular inspection of the job site, materials and equipment to be made by a competent person. This written program shall be submitted upon request to any affected employee or authorized representative, to the assistant secretary and the director and shall be available at the worksite for examination and copying by the assistance secretary and the director. Written job programs shall be revised and updated at least every six months to reflect the current status of the program.

k. Administrative Controls If administrative controls are used as a means of reducing employees’ exposure to lead, the employer shall establish and implement a job rotation schedule which includes names or identification number of each affected employee and the duration and exposure levels at each job or work station where each affected employee is located.

l. Respiratory Protection (See Appendix 7.13) 1) General

Where the use of respirators is required the employer shall provide, at no cost to the employee, and enforce the use of the respirator. Respirators shall be sued in the following circumstances: whenever an employee’s exposure to lead exceeds the PEL, in work situations in which engineering controls and work practices are not sufficient to reduce exposure to below the PEL and whenever and employee request a respirator.

2) Respirator Selection Where respirators are used the employer shall select the appropriate respirator or combination of respirator. The employer shall provide a powered, air purifying respirator whenever an employee chooses to use this type of respirator or when it is needed to provide adequate protection. The employer shall select respirators from those approved for protection against lead, dust, fume and mist.

3) Respirator Usage/Program


Adhere to the program requirements established under Respirator Program in this section of the manual.

m. Protective Work Clothing and Equipment Where employees are exposed to lead above the PEL without regard to the use of respirators and/or where employees are exposed to lead compounds the employer shall provide at no cost to the employee and assure that the employee used appropriate protective work clothing and equipment that prevents contamination of the employee and employee’s garments such as, but not limited to coveralls or similar full body work clothing, gloves, hats, shoes or disposable shoe coverlets, face shield, vented goggles or other appropriate protective equipment.

n. Cleaning and Replacement 1) The employer shall provide the protective clothing in a clean and dry condition. 2) The employer shall provide for the cleaning, laundering and disposal of protective

clothing and equipment. 3) The employer shall repair or replace protective clothing and equipment as

needed to maintain their effectiveness. 4) The employer shall assure that contaminated protective clothing is placed in a

closed container in the change area which prevents dispersion of lead outside the container.

5) The employer shall inform in writing any person who cleans or lauders protective clothing or equipment of the potentially harmful effects of exposure to lead.

6) The containers of contaminated protective clothing and equipment shall be labeled as follows:

CAUTION: CLOTHING CONTAMINATED WITH LEAD. DO NOT REMOVE DUST BY BLOWING OR SHAKING. DISPOSE OF LEAD CONTAMINATED WASH WATER IN ACCORDANCE WITH APPLICABLE LOCAL, STATE OR FEDERAL REGULATION.

o. Housekeeping 1) All surfaces shall be maintained as free as practicable of accumulations of lead. 2) Clean up of floors and other surfaces where lead accumulates shall whenever

possible, be cleaned by vacuuming or other methods that minimize the likelihood of lead becoming airborne.

3) Shoveling, dry or wet sweeping and brushing may be used only where vacuuming or other equally effective methods have been tried and found not to be effective.

4) Where vacuuming methods are selected, the vacuums shall be equipped with HEPA filters and used and emptied in a manner which minimizes the reentry of lead into the workplace.

5) Compressed air shall not be used to remove lead from any surface unless the compressed air is used in conjunction with a ventilation system designed to capture the airborne lead dust created by the compressed air.

p. Hygiene Facilities and Practices 1) General


The employer shall assure that in areas where employees are exposed to lead above the PEL without regard to the use of a respirator, food or beverage is not present or consumed, tobacco products are not present or used and cosmetics are not applied.

2) Change Areas The employer shall provide clean change areas for employees whose airborne exposure to lead is above the PEL. The change areas shall be equipped with separate storage facilities for protective work clothing and equipment and for street clothes which will prevent cross-contamination. The employer shall assure that employees do not leave the work place wearing any protective clothing or equipment that is required to be worn during the work shift.

3) Showers Shower facilities shall be provided, where feasible, for use by employees whose airborne exposure to lead is above the PEL. The employer shall assure, where shower facilities are available, that employees shower at the end of the work shift and shall provide an adequate supply of cleaning agents and towels.

4) Eating Facilities Lunchroom facilities or eating areas shall be provided for employees whose airborne exposure to lead is above the PEL. The employer shall assure that lunchroom facilities or eating areas are as free as practicable from lead contamination and are readily accessible to employees. Employees shall be required to wash their hands and face prior to eating, drinking, smoking or applying cosmetics. The employer shall assure that employees do not enter lunchroom facilities or eating areas with protective work clothing or equipment unless surface lead dust has been removed by vacuuming.

5) Hand Washing Facilities The employer shall provide adequate hand washing facilities where showers are not provided.

q. Medical Surveillance 1) The employer shall make available initial medical surveillance to employees

occupationally exposed to lead at or above the action level. Initial medical surveillance consist of biological monitoring in the form of blood sampling and analysis for lead and zinc protoporphyrin levels.

2) The employer shall assure that all medical examinations and procedures are performed by or under the supervision of a licensed physician.

3) The medical examinations shall be made available without cost to employees and at a reasonable time and place.

r. Biological Monitoring 1) Blood Lead and ZPP Level Sampling and Analysis


The employer shall make available biological monitoring in the form of blood sampling and analysis for lead and zinc protoporphyrin level. Blood sampling shall take place at least every two months for the first six months and every six months thereafter. For each employee who is removed from exposure to lead due to an elevated blood lead level shall have blood sampling at least monthly until two consecutive blood samples and analysis indicate a blood lead level below 40 ub/dl.

2) Employee Notification Within five working days after the receipt of biological monitoring results, the employer shall notify each employee in writing of his or her blood lead level.

s. Medical Examination and Consultation The employer shall make available, medical examinations and consultations at least annually for each employee for whom a blood sampling test conducted at any time during the preceding 12 months indicated a blood lead level at or above 40 ug/dl.

1) Content i. The content of medical examinations shall be determined by an

examining physician and, if request by an employee, shall include pregnancy testing or laboratory evaluation of male fertility

ii. Medical examinations shall include the following elements. A detailed work history and a medical history, with particular attention to past lead exposure (occupational and non-occupational), personal habits (smoking) and past gastrointestinal, hematological, renal, cardiovascular, reproductive and neurological problems. The examination shall pay particular attention to teeth, gums, hematological, gastrointestinal, renal, cardiovascular and neurological systems. Pulmonary status should also be evaluated if respiratory protection will be used. A blood pressure measurement. A blood sample and analysis which determines the blood lead level, hemoglobin and hematocrit determinations, red cell indices and examination of peripheral smear morphology, zinc protoporphyrin, blood urea nitrogen and serum creatininine. A routine urinalysis with microscopic examination. Any laboratory or other test relevant to lead exposure which the examining physician deems necessary by sound medical practice.

2) Multiple Physician Review Mechanism i. When the employer selects the initial physician who conducts any

medical examination or consultation related to lead exposure, the employee may designate a second physician to review any findings, determination or recommendation of the initial physical and conduct such examinations, consultants and laboratory test as the second physician deems necessary to facilitate this review.

ii. The employer shall notify each employee of the right to seek a second medical opinion after each occasion that an initial physician conducts a


medical examination or consultation. Gribbins Insulation is not obligated to pay for the second opinion.

iii. If the findings, determinations or recommendations of the second physician differ from those of the initial physician, then the employer and the employee shall assure that efforts are made for the two physicians to resolve any disagreement.

iv. If the two physicians cannot resolve their disagreement, then the employer and employee through their respective physicians shall designate a third physician to review any findings, determinations or recommendation of the prior physicians and to conduct such examinations, consultations, laboratory test and discussions with the prior physicians to resolve the disagreement.

v. Information to be provided to physicians includes a copy of the OSHA Standard, 29 CFR 1926.62 including all appendices, a description of the affected employee’s duties as they relate to the employee’s exposure, the employee’s exposure level or anticipated exposure level to lead, a description of any personal protective equipment used or to be used, prior blood lead level determinations and all prior written medical opinion concerning the employee.

This information shall be provided to a second or third physician conducting a medical examination or consultation upon request either by the second or third physician or by the employee.

vi. Written Medical Opinions The employer shall obtain and furnish the employee with a copy of a written medical opinion from each examining or consulting physician which contains only the following information. The physician’s opinion as to whether the employee has any detected medical condition which would place the employee at increased risk of material impairment of the employee’s health from exposure to lead. Any recommended special protective measures to be provided to the employee, or limitations to be placed upon the employee’s exposure to lead. Any recommended limitation upon the employee’s use of respirators. And the results of the blood lead level.

vii. The employer shall instruct each physician to not reveal either in the written opinion or orally with the employer, findings including laboratory results or diagnoses unrelated to an employee’s occupational exposure to lead and advise the employee of any medical condition, occupational or non-occupational, which dictates further medical examination or treatment.

t. Medical Removal Protection Temporary medical removal and return of an employee due to elevated blood lead level.


1) The employer shall remove an employee from work having an exposure to lead

at or above the action level on each occasion that a periodic and/or a follow-up blood sampling test that indicates the employee’s blood lead level is at or above 50 ug/dl.

2) The employer shall return an employee to his or her former job status when two consecutive blood sampling tests indicate that the employee’s blood lead level is at or below 40 ug/dl.

3) Medical removal protection benefits include the employee shall provide an employee up to 18 months of medical removal protection benefits on each occasion that an employee is removed from exposure to lead. Medical removal protection benefits means that, as long as the job the employee was removed from continues, the employee shall maintain the total normal earning, seniority and other employment rights and benefits of an employee, including the employees right to his or her former job status as though the employee had not been medically removed from the employee’s job.

4) Worker’s Compensation Claims If the removed employee files a claim for Worker’s Compensation payments for a lead related disability, then the employer shall continue to provide medical removal protection benefits pending disposition of the claim. To the extent that an award is made to the employee for earnings lost during the period of removal, the employer’s medical removal protection obligation shall receive no credit for Worker’s Compensation payments received by the employee for treatment related expenses.

u. Employee Information and Training 1) The employer shall communicate information concerning lead hazards according

to the requirements of OSHA’s Hazard Communication Standard, including but not limited to the requirements concerning warning signs and labels, Material Safety Data Sheets, employee information and training and in addition, employers shall comply with the following requirements: the employer shall provide the training as initial training prior to the time of job assignment and the employer shall also provide the training program at least annually for each exposure at or above the actual level on any day.

2) All employees shall be properly trained before engaging in work processes with lead. See Section 9 for training requirements.

3) Access to information and training material The employer shall make readily available to all affected employees a copy of the OSHA standard and its appendices. The employer shall provide, upon request, all materials relating to the employee’s information and training program to affected employees and their designated representatives and to the assistance secretary and the director.

v. Signs The employer shall post the following warning signs in each work area where an employee’s exposure to lead is above the PEL


WARNING LEAD WORK AREA

POISON NO SMOKING OR EATING

The employer shall assure that the signs are illuminated and cleaned as necessary so that the legend is readily visible.

w. Recordkeeping 1) The employer shall establish and maintain an accurate record of all monitoring

and other data used in conducting employee exposure assessments. 2) Exposure monitoring records shall include the dates, number, duration, location

and results of each of the samples taken including a description of the sampling procedure used to determine representative employee exposure, a description of the sampling and analytical methods used and evidence of their accuracy, the type of respiratory protection devices worn and name, social security number, and job classification of the employee monitoring and of all other employees whose exposure measurements is intended to represent.

3) Medical surveillance The employer shall establish and maintain an accurate record for each employee subject to medical surveillance. This record shall include the name, social security number and description of the duties of the employee, a copy of the physician’s written opinions, results of any airborne exposure monitoring done on or for that employee and provided to the physician and any employee medical complaints related to exposure to lead.

4) The employer shall keep the following records, or assure that the attending physician keeps the following records a copy of the medical examination results including medical and work history, a description of the laboratory procedures and a copy of any standards or guidelines used to interpret the test results, a copy of the results of biological monitoring and all medical records related to lead exposure.

5) Medical Removals The employer shall establish and maintain an accurate record for each employee removed from current exposure to lead. Each record shall include the name and social security number of the employee, the date of each occasion that the employee was removed from current exposure to lead as well as the corresponding date on which the employee was returned to his or her former job status, an explanation of how each removal was or is being accomplished and a statement about each removal indicating whether or not the reason for the removal was an elevated blood lead level. This information shall be maintained on file and/or in the job file indefinitely.

6) Availability The employer shall make available upon request all records required to be maintained.

7) Transfer of Records


Whenever the employer ceases to do business, the successor employer shall receive and retain all records as required to be maintained. If there is no successor employer, the records are to be sent to the local OSHA director.

x. Observation of Monitoring The employer shall provide affected employees or their designated representative an opportunity to observe any monitoring of employee exposure to lead.

y. Affected Project Type for Miscellaneous Special Trade Contractors These type of projects include, but are not limited to, underground storage tank demolition, housing (lead abatement, in place management), industrial facility maintenance and renovation, industrial process equipment maintenance and repair, installation of radiation shielding, installation of sound barriers, commercial and institutional remodeling, reinsulation over existing mineral wool and removal of existing mineral wool. Older forms of mineral wools contained lead.

z. Primary Sources of Lead Exposure The primary sources of lead exposure include lead based paint and paint debris, lead oakum pipe joint material, lead bricks, lead mortar and lead sheets, metallic lead dust, lead containing construction materials, mineral wool insulation with lead contaminants, lead pipes and lead solder.

7.27 Lead – Renovation, Repair and Painting a. The Environmental Protection Agency’s (EPA) Renovation, Repair and Painting Rule (40

CFR 745) requires that renovation conducted for compensation, must be performed by Certified Forms, supervised by Certified Renovators an d trained employees using safe work practices.

b. Rule This rule addresses lead-based paint hazards created by renovation, repair and painting activities that disturb lead-based paint in target housing and child occupied facilities.

1. Target Housing – is a home or residential unit built on or before December 31, 1977, except housing designated for the elderly or persons with disabilities (unless any child who is less than 6 years of age resides or is expected to reside in such housing) or any zero-bedroom dwelling (e.g. studio apartments, hotel, dormitories, etc).

2. A Child Occupied Facility – is a pre-1978 building that meets these three criteria 1) visited regularly by the same child, under 6 years of age, 2) the visits are on at least two different days within any week, provided that each day’s visit lasts at least 3 hours and 3) combined weekly visits last at least 6 hours and the combined annual visits last at least 60 hours.

3. Exclusions – Exclusions to this rule include renovation activities where affected components do not contain lead-based paint, emergency renovations (still require cleanup and cleaning verification), minor repair and maintenance activities disturbing less than 6 ft2 per room of painted surface for interior work and less than 20 ft2 per side of painted surface for exterior work. This exclusion does not apply to window replacement, demolition or activities involving prohibited practices.


c. Responsibilities 1. Certified Firms

i. Ensure overall compliance with the RRP Rule ii. Ensure that all employees participating in renovations are Certified

Renovators or have been trained by the Certified Renovator. iii. Assign a Certified Renovator to all renovation jobs. iv. Meet the pre-renovation education requirements. v. Responsible for recordkeeping requirement including pre-renovation

education documentation, documentation of lead-based paint, training and certification records and cleaning verification records.

2. Certified Renovators i. Perform work and direct the work of non-certified renovation workers. ii. Train all non-certified workers on-the-job in lead-safe work practices. iii. Maintain copies of initial and/or refresher training certifications onsite. iv. Conduct testing for lead-based paint using EPA- recognized test kits and

report findings. v. Remain onsite during the sign posting, work area setup and clean up

phases of work. vi. When not onsite, be available by telephone. vii. Make sure that the containment is maintained in a way that prevents the

escape of dust and debris. viii. Conduct the cleaning verification procedures to make sure that the work

is complete and that the work area is ready to reoccupy. ix. Prepare a summary of the work, maintain training and certification

records and certify that all work was done in lead safe manner. d. Before Work Begins

1. Education of Owners and Residents i. Firm must give homeowners/residents and child occupied facility

owners/adult representatives copies of the Renovate Right pamphlet. ii. Firm must let parents/guardians of children using a child-occupied facility

know about the renovation and how to get a copy of the Renovate Right pamphlet.

iii. Firm must get confirmation of receipt of the Renovate Right pamphlet from owners, or evidence that the pamphlet was delivered to tenants/residents.

iv. Firm must keep these records for at least 3 years. 2. Testing

i. Determine if lead-based paint is present using an EPA recognized testing kit.

e. Dust Containment 1. Containment is a system of temporary barriers used to isolate a work area so

that no dust or debris escapes while the renovation is being performed. 2. Interior Containment


i. Access to containment area shall be limited and warning signs must be posted.

ii. All belongings shall be removed from the containment area. If objects are immovable the covered with protective sheeting and all seams and edges must be sealed.

iii. Floors must be covered with plastic sheeting a minimum of 6 feet in all directions around the paint being disturbed

iv. Depending on the work being done, close all windows, close and seal all doors, close and seal all HVAC vents in the work area.

v. Entry door must be covered with two layers of protective sheeting. 3. Exterior Containment

i. Ground shall be covered with protective sheeting a minimum of 10 feet in all directions around the paint being disturbed. Special attention shall be paid to nearby vegetable gardens and children’s play areas.

ii. A 20 foot perimeter shall be established around the work area and warning signs must be posted.

iii. All nearby doors and windows that are within 20 feet of the work area shall be closed.

iv. Two layers of plastic sheeting on doors in the work area that are being used during the job.

f. During Work 1. Prohibited Practices

i. Open flame burning or torching. ii. Heat gun above 1100o F. iii. Power sanding, power grinding, power planning, needle guns, abrasive

blasting and sandblasting, without HEPA vacuum attachment. 2. Specialized Tools

i. Large jobs may require special consideration to get the job done. This includes power sanders, grinders and planers, needle guns, and abrasive and sand blasters, each with required HEPA-filtered capture attachments, pneumatic and battery powered tools to protect against shock hazards and specialized planning and containment.

3. Protecting Yourself i. Employees should follow all OSHA regulation regarding work practices

described in this section. 4. Control Spread of Dust

i. Before leaving work site remove shoe coverings and HEPA vacuum or wipe shoes, walk on disposable tack pads to remove dust from your soles, HEPA vacuum and remove coveralls and HEPA vacuum your clothes, remove gloves if used and carefully was your hands and face, dispose of all used disposable clothing in plastic bags and clean tools.

ii. At the end of the day don’t take lead home to your family. HEPA vacuum clothes, shoes, etc, change your clothes and dispose of or place dusty


work clothes in a plastic bag to wash separately from household laundry, wash your hand and face and shower as soon as you get home.

5. Cleaning During the Job i. Clean worksite reduces the spread of dust and paint chips. ii. Clean as you work, HEPA vacuum horizontal surfaces, remove debris

frequently, remove paint chips as they are created and as building components are removed, wrap and dispose of them immediately.

iii. Clean frequently. g. Cleaning Activities and Checking Your Work

1. Interior Cleaning Requirements i. Collect all paint chips and debris and seal in heavy duty trash bags. ii. Mist, remove, fold (dirty side in) and tape or seal protective sheeting and

dispose of as waste. iii. Plastic sheeting between non-contaminated rooms and work areas must

remain in place until after cleaning and removal of other sheeting. iv. HEPA vacuum or wet wipe wall from high to low, then HEPA vacuum

remaining surfaces and wipe with a damp cloth. v. Clean 2 feet beyond the contained work area. vi. Use disposable wipes or change cloths frequently. vii. For carpet or rug, use HEPA vacuum with beater bar. viii. HEPA vacuum and wet mop uncarpeted floors – two bucket mopping

method or wet mopping system. 2. Visual Inspection Procedure

i. Must be conducted by Certified Renovator ii. Disposable foot covers must be worn before entering work area. iii. Work area must have adequate lighting. iv. Systematically look for dust and debris on every horizontal surface in the

work area and two feet beyond. Work from the farthest area from the entry to the entry. Closely examine each surface.

v. If you find visible dust or debris, the re-clean the work are and repeat step 4.

vi. Once you have carefully looked at all of the surfaces and found no dust or debris, proceed to the cleaning verification procedures or clearance.

3. Cleaning Verification Procedure i. Wipe each window sill within the work area. Use a single wet disposable

cleaning cloth per window sill. ii. Wipe uncarpeted floors and all countertops with wet disposable cleaning

cloths. Wipe up to a maximum of 40 ft2 per cloth. iii. Compare each wipe to the Cleaning Verification Card. If the cloth

matches or is lighter than the Cleaning Verification Card, the surface has passed cleaning verification and no further action is required. If the cloth is darker than the Cleaning Verification Card, reclean and repeat the CV process.


iv. If the second wet cloth fails, wait one hour or until surfaces are dry, and then wipe with an electrostatically charged white disposable cleaning cloth designed to be used for cleaning hard surfaces. This completes the cleaning verification.

4. Dust Clearance Examination i. A dust clearance examination may be performed instead of cleaning

verification. ii. A clearance examination must be conducted by a Certified Lead

Inspector, Risk Assessor or Dust Sampling Technician. iii. If the clearance fails, the renovation firm must reclean the work area until

dust standards comply with applicable state, territorial, tribal and local standards.

5. Exterior Cleanup Requirements i. Clean all surfaces in the work area until no visible dust, debris or residue

remains. ii. Remove all dust and debris without dispersal and seal in heavy plastic

bags. iii. Remove protective plastic sheeting and mist before folding it dirty side

inward. iv. Check your work, focus on areas such as window sills, bare soil and

children’s play areas. Look for dust, debris and paint chips. 6. Exterior Check for Effectiveness Cleaning

i. Visual Inspection – A Certified Renovator conducts a visual inspection after any cleaning to determine if any visible dust and debris are present in and beyond the boundaries of the work area.

ii. If visible dust or debris are found, collect and dispose of all paint chips, dust and debris indentified during the visual inspection.

iii. After recleaning, the Certified Renovator conducts another visual inspection.

iv. When all areas pass, warning signs may be removed. 7. Disposal

i. Waste should be placed in heavy duty plastic bags. ii. “Gooseneck seal” the bag with duct tape. iii. Carefully dispose of waste in accordance with Federal and other

regulations. iv. HEPA vacuum the exterior of the waste bag before removing it from the

work area. v. Store waste in a secure area.

h. Recordkeeping 1. On The Job Records

i. Copies of Certified Firm and Certified Renovator certifications must be kept onsite.

ii. Lead based paint testing results when and EPA recognized test kit is used.


iii. Proof of owner/occupant pre renovation education. iv. Non certified worker training documentation must be kept onsite.

7.28 Mold Prevention and Reporting Policies

With the rapidly growing problem of mold court claims we are forced to create a policy on correct and prompt procedures to ensure Gribbins Insulation Company’s protection. One of the concerns in our industry is that mold can develop from wet insulation. There are many different scenarios that can result in wet insulation for example: missing insulation causing condensation, installing pipe insulation on condensating pipes, installing wet insulation or insulation getting wet after installation. There are many different ways that our industry can be susceptible to mold therefore we must take precaution to prevent our exposure. Often we are faced with situations that pipe and duct are installed but the building is not “dried in”. We are placed in a vulnerable situation to choose not to insulate until “dried in” resulting in lost time due to other trades continuing with their work or to insulate these systems and cover with plastic to prevent the insulation from getting wet. We no longer can choose the option to cover the insulation with plastic without authorization in writing. If this situation arises on our job we must immediately contact our superintendent who will contact the estimator about this problem. The estimator will contact the customer notifying them that we will not be responsible for possible mold growth due to the inadequate scheduling of trades. We must make an effort to coordinate with our customer on the installation of our scope of work before allowing the system to run causing condensation. If we are required to install insulation on pipes that have been condensating we must contact our superintendent first to receive authorization. The estimator will again notify the customer that we will not be held responsible for possible mold growth. Installing wet material can later cause mold growth. Take special precautions to keep material in dry areas that are not susceptible to water or high humidity. Sometimes materials might have to be stacked on pallets or placed into a storage trailer but we will no longer allow material to become wet. If mold is seen while working on the job that pertains to our work immediately contact the superintendant or estimator so this issue can be taken care of.

7.29 Silica a. Silica is found naturally in almost all rock, sand and soil. It can be found in concrete,

brick and sandblasting grit. b. Health Effects

Inhaled silica dust scars the lungs and can cause silicosis. Scarring of the lung tissue reduces the lung’s ability to extract oxygen from the air. The amount of exposure and


the amount of time you are exposed increase your chances of developing this disease. Early stages may go unnoticed, but as exposure continues you will start to have shortness of breath.

c. Exposure

Silica exposure may occur when abrasive blasting, rock drilling, concrete and masonry building construction or demolition, earthwork, rock crushing and road construction and repair. The permissible exposure limit for Silica is 10 mg/m3 (micrograms per cubic meter of air) averaged over an 8 hour work day.

d. Control Methods Workers involved in these work activities shall control dust to reduce exposures. Exposures shall be monitored to ensure they do not exceed the PEL. The following are ways to reduce exposure for these type of work activities: use dust suppression systems when feasible, do not use dry sweeping or compressed air as methods of clean up, establish environmental controls in enclosed areas, provide water to the blade when sawing concrete or masonry materials, and if engineering controls and administrative controls do not work as a last line of defense a respirator should be worn. Although we do not do this type of work it is important that employees know the hazards that may be faced in the workplace. If you have concerns about possible exposure to Silica at the jobsite contact the Safety Department.

7.30 Inorganic Arsenic

a. Gribbins Insulation shall ensure that no employee is exposed to inorganic arsenic at concentrations greater than 10 micrograms per cubic meter of air (10 ug/m3) averaged over an 8 hour period.

b. Exposure Monitoring 1. General

i. Determinations of airborne exposure levels shall be made from air samples that are representative of each employee’s exposure to inorganic arsenic over an eight hour period.

ii. Gribbins Insulation Company shall perform monitoring for each workplace or work operation covered by this standard shall monitor each such workplace and work operation to accurately determine the airborne concentration of inorganic arsenic to which employees may be exposed.

2. Frequency i. If the initial monitoring reveals employee exposure to be below the action

level the measurements need not be repeated except when there has been a production, process, control or personal change which may result in new or additional exposure to inorganic arsenic, or whenever the employer has any other reason to suspect a change which may result in new or additional exposure to inorganic arsenic.

ii. If the initial monitoring or subsequent monitoring reveals employee exposure to be above the permissible exposure limit, Gribbins Insulation Company shall repeat monitoring at least quarterly.


iii. If the initial monitoring or subsequent monitoring reveals employee exposure to be above the action level and below the permissible exposure limit Gribbins Insulation Company shall repeat monitoring at least every six months.

iv. Gribbins Insulation Company shall continue to monitoring at the required frequency until at least two consecutive measurements, taken at least seven days apart, are below the action level at which time the employer may discontinue monitoring for the employee until such time as any of the events occurring additional monitoring occur.

3. Employee Notification i. Gribbins Insulation Company shall notify employees in writing of the

results within five working days after the receipt of monitoring results. ii. Whenever the results indicate exposures exceeds the PEL, Gribbins

Insulation Company shall include in the written notice a statement that the PEL was exceeded and a description of the corrective action taken to reduce exposure to or below the PEL.

4. Accuracy of Measurement i. Gribbins Insulation Company shall use a method of monitoring and

measurement which has an accuracy of not less than plus or minus 25% for concentrations of inorganic arsenic greater than or equal to 10 ug/m3.

ii. Gribbins Insulation Company shall use a method of monitoring and measurement which has an accuracy of not less than plus or minus 35% for concentrations of inorganic arsenic greater than 5 ug/m3 but less than 10 ug/m3.

c. Regulated Area 1. Gribbins Insulation Company shall establish regulated areas where worker

exposure to inorganic arsenic exceed the permissible limit. 2. These regulated areas shall be segregated and demarcated from the rest of the

workplace in any manner that minimized the number of persons who will be exposed.

3. Access to regulated areas shall be limited to authorized persons supplied with a respirator.

4. Gribbins Insulation Company shall assure that in regulated areas, no food or beverages are consumed, smoking products, chewing tobacco and gum are not used and cosmetics are not applied. Drinking water may be consumed in the regulated areas.

d. Methods of Compliance 1. Controls

i. Engineering and work practice controls shall be implemented to reduce exposures to or below the PEL, except to the extent that the Gribbins Insulation Company can establish that such controls are not feasible.

ii. Where engineering and work practices controls are not sufficient to reduce exposures to or below the PEL, they shall nonetheless be used to reduce exposure to the lowest levels achievable by these controls and


shall be supplemented by the use of respirators and other necessary personal protective equipment. Employee rotation is not required as a control strategy before respiratory protection is instituted.

2. Compliance Program i. Gribbins Insulation Company shall establish and implement a written

program to reduce exposures to or below the PEL by means of engineering and work practice controls.

ii. Written plans for compliance programs shall include at least the following; a. A description of each operation in which inorganic arsenic is

emitted; b. Engineering plans and studies used to determine methods

selected for controlling exposure to inorganic arsenic; c. A report of the technology considered in meeting the PEL; d. Monitoring data; e. A detailed schedule for implementation of the engineering controls

and work practice that cannot be implemented immediately and for the adaption and implementation of any additional engineering and work practices necessary to meet the PEL;

f. Plans shall be revised and updated at least every 6 months. e. Respiratory Protection

1. Respirators must be used during periods necessary to install or implement feasible engineering or work practice controls, work operation, such as maintenance and repair activities, for which the employer establishes that engineering and work practice controls are not feasible, work operations for which engineering and work-practice controls are not yet sufficient to reduce employee exposure to or below the permissible exposure limit and emergencies.

2. Gribbins Insulation must use Table 1 (Appendix) to select the appropriate respirator or combination of respirator for inorganic arsenic compounds without significant vapor pressure and Table 2 (Appendix) to select the appropriate respirator or combination of respirators for inorganic arsenic compounds that have significant vapor pressure.

3. When employee exposure exceeds the PEL and also exceed the relevant limit for other gases (for example, sulfur dioxide), an air purifying respirator provided must have a combination high-efficiency filter with an appropriate gas sorbent. (See footnote in Table 1, Appendix.)

4. Employees required to use respirators may choose, and Gribbins Insulation Company must provide, a powered air-purifying respirator if it will provide proper protection. In addition, Gribbins Insulation Company must provide a combination dust and acid-gas respirator to employees who are exposed to gases over the relevant exposure limits.

f. Protective Work Clothing and Equipment 1. Where the possibility of skin or eye irritation from inorganic arsenic exists and for

all workers in regulated areas shall use appropriate and clean protective work clothing and equipment such as, but not limited to: coveralls or similar full-body


work clothing, gloves, shoes or coverlets, face shield or vented goggles when necessary to prevent eye irritation and impervious clothing for employees subject to exposure to arsenic trichloride.

2. Gribbins Insulation Company shall provide protective clothing in a freshly laundered and dry condition at least weekly and daily if the employee works in areas where exposures are over 100 ug/m3 or in areas where more frequent washing is needed to prevent skin irritation.

3. Gribbins Insulation Company shall clean, launder or dispose of protective clothing.

4. Protective clothing shall be repaired or replaced as needed to maintain their effectiveness.

5. All protective clothing shall be removed at the completion of a work shift only in change rooms.

6. Contaminated protective clothing shall be placed in a closed container in the change room which prevents dispersion of inorganic arsenic outside the container.

7. Gribbins Insulation Company shall inform in writing any person who cleans or launders clothing of the potential harmful effects including carcinogenic effects of exposure to inorganic arsenic.

8. All containers of contaminated protective clothing and equipment in the workplace or which are to be removed from the workplace shall be labeled as follows:

CAUTION: Clothing contaminated with inorganic arsenic;

Do not remove dust by blowing or shaking. Dispose of inorganic arsenic contaminated was water in

accordance with applicable local, State or Federal Regulations. 9. Inorganic arsenic shall not be removed from protective clothing or equipment by

blowing or shaking. g. Housekeeping

1. All surfaces shall be maintained as free as practicable of accumulation of inorganic arsenic.

2. Floors and other accessible surfaces contaminated with inorganic arsenic may not be cleaned by the use of compressed air and shoveling and brushing may be used only where vacuuming or other relevant methods have been tried and found not to be effective.

3. Where vacuuming methods are selected, the vacuums shall be use and emptied in a manner to minimize the reentry of inorganic arsenic into the workplace.

4. A written housekeeping and maintenance plan shall be kept which shall list appropriate frequencies for carrying out housekeeping operations and for cleaning and maintaining dust collection equipment.

5. Periodic cleaning of dust collection and ventilation equipment and checks of their effectiveness shall be carried out to maintain the effectiveness of the system and a notation kept of the last check of effectiveness and cleaning or maintenance.


h. Hygiene Facilities and Practices 1. Gribbins Insulation Company shall provide employees working in regulated areas

or subject to the possibility of skin or eye irritation, clean change rooms equipped with storage facilities for street clothes and separate storage facilities for protective clothing and equipment.

2. Employees working in regulated areas or subject to the possibility of skin or eye irritation shall shower at the end of the work shift, these showers shall be provided in accordance with 1910.141 (d)(3)

3. Gribbins Insulation Company shall provide employees working in regulated areas, lunchroom facilities which have a temperature controlled, positive pressure, filter air supply, and which are readily accessible to employees working in regulated areas. These employees shall wash their hands and face prior to eating.

4. Lavatory facilities shall be provide in accordance with 1910.141 (d)(1) and (2). 5. Facilities shall be provided for and used by any employees working in areas

where exposure exceeds 100 mg/m3 to vacuum their protective clothing and clean or change shoes worn in such areas before entering change rooms, lunchrooms or shower rooms.

6. No employee shall be exposed to skin or eye contact with arsenic trichloride or to skin or eye contact with liquid or particulate inorganic arsenic which is likely to cause skin or eye irritation.

i. Medical Surveillance 1. Gribbins Insulation Company shall institute a medical surveillance program for

the following employees: i. All employees who are or will be exposed above the action level without

regard to the use of respirator, at least 30 days per year; and ii. All employees who have been exposed above the action level for 30 days

or more per year for a total of 10 years or more combined employment with the employer or predecessor employers prior to or after the effective date of this standard.

2. All medical examinations and procedures shall be performed by or under the supervision of a licensed physician.

3. At the time of initial assignment to an area where the employee is likely to be exposed over the action level at least 30 days per year, the employer shall provide each affected employee and opportunity for a medical examination, including at least the following elements:

i. A work history and a medical history which shall include a smoking history and the presence and degrees of respiratory symptoms such as breathlessness, cough, sputum production and wheezing.

ii. A medical examination which shall include at least the following: a 14” by 17” posterior-anterior chest X-ray and ILO U/C rating, a nasal and skin examination and other examinations which the physician believes appropriate because of the employees exposure to inorganic arsenic or because of required respirator use.


4. Employees who are under 45 years of age with fewer than 10 years of exposure over the action level shall be medically examined at least annually.

5. All other employees shall be medically examined semiannually and have an x-ray at least annually.

6. If an employee is terminated and has not received and examination within the previous six months, they shall be examined upon termination of employment.

7. If the employee for any reason develops signs or symptoms commonly associated with exposure an appropriate examination and emergency medical treatment shall be provided.

8. Gribbins Insulation Company shall provide the following information to the examining physician:

i. A copy of this standard and its appendices; ii. A description of the affected employee’s duties as they relate to the

employee’s exposure; iii. The employee’s representative exposure level or anticipated exposure

level; iv. A description of any personal protective equipment used or to be used;

and v. Information from previous medical examinations of the affected employee

which is not readily available to the examining physician. 9. Gribbins Insulation Company shall obtain a written opinion from the examining

physician which shall include: i. The results of the medical examination and tests performed; ii. The physician’s opinion as to whether the employee has any detected

medical conditions which would place the employee at increased risk of material impairment of the employee’s health from exposure;

iii. Any recommended limitations upon the employee’s exposure or upon the use of protective clothing or equipment such as respirators; and

iv. A statement that the employee has been informed by the physician of the results of the medical examination and any medical conditions which require further explanation or treatment.

v. No written opinion on specific finding or diagnoses unrelated to occupation exposure.

vi. Affected employee shall receive a copy of the written opinion. j. Employee Information and Training

1. All employees who are subject to exposure to inorganic arsenic levels above the action level or for whom there is the possibility of skin or eye irritation from inorganic arsenic shall be trained.

2. The training program shall be provided on the time of initial assignment and at least annually thereafter for covered employees. Each employee shall be trained in the following:

i. The information contained in Appendix A;


ii. The quantity, location, manner of use, storage, sources of exposure and the specific nature of operations which could result in exposure to inorganic arsenic as well as any necessary protective steps;

iii. The purpose, proper use and limitations of respirators; iv. The purpose and description of the medical surveillance program as

required by this section; v. The engineering controls and work practices associated with the

employee’s job assignment; and vi. A review of this standard

3. Gribbins Insulation Company shall make readily available to all affected employees a copy of this standard and its appendices.

k. Signs and Labels

1. Signs must be posted demarcating regulated areas bearing the legend: DANGER

INORGANIC ARSENIC CANCER HAZARD

AUTHORIZED PERSONNEL ONLY NO SMOKING OR EATING RESPIRATOR REQUIRED

2. Signs shall be illuminated and cleaned as necessary so that the legend is readily visible.

3. Precautionary labels shall be applied to all shipping and storage containers of inorganic arsenic and to all products containing inorganic arsenic except when the inorganic arsenic in the product is bound in such a manner so as to make unlikely the possibility of airborne exposure to inorganic arsenic. The labels shall bear the following:

DANGER CONTAINS INORGANIC ARSENIC

CANCER HAZARD HARMFUL IF INHALED OR SWALLOWED

USE ONLY WITH ADEQUATE VENTILATION OR RESPIRATORY PROTECTION

l. Recordkeeping 1. Monitoring records shall be established and maintained for at least 40 years or

for the duration of employment plus 20 years, whichever is longer and shall include:

i. The dates, number, duration, location and the results of each sample taken, including a description of the sampling procedure used to determine representative employee exposure where applicable;

ii. A description of the sampling and analytical methods used and evidence of their accuracy;

iii. The type of respiratory protective devices worn, if any;


iv. Name, social security number, and job classification of the employees monitored and of all other employees whose exposure the measurement is intended to represent; and

v. The environmental variables that could affect the measurement of the employee’s exposure.

2. Medical surveillance records shall be established and maintained for at least 40 years, or for the duration of employment plus 20 years whichever is longer. This record shall include:

i. The name, social security number and description of duties of the employee;

ii. A copy of the physician’s written opinions; iii. Results of any exposure monitoring done for that employee and the

representative exposure levels supplied to the physician; and iv. Any employee medical complaints related to exposure to inorganic

arsenic.

Gribbins Insulation Company shall also keep, or assure that the examining physician keeps the following medical record:

i. A copy of the medical examination results including medical and work history required under paragraph (n) of this section;

ii. A description of the laboratory procedures and a copy of any standard or guidelines used to interpret the test results or references to that information;

iii. The initial X-ray; iv. The X-rays for the most recent 5 years; and v. Any X-rays with a demonstrated abnormality and all subsequent X-

rays. 3. Records shall be provided upon request to employees or designated

representative. m. Observation of Monitoring

1. Employees or their designated representative shall be provided the opportunity to observe any monitoring of employee exposure.

2. Whenever observation of the monitoring of employee exposure requires entry into an area where the use of respirators, protective clothing or equipment is required, Gribbins Insulation Company shall provide the observer with and assure the use of such respirators, clothing and such equipment and shall require the observer to comply with all other applicable safety and health procedures.

3. Without interfering with the monitoring, observers shall be entitled to: i. Receive an explanation of the measurement procedures; ii. Observe all steps related to the monitoring of inorganic arsenic performed

at the place of exposure; and iii. Record the results obtained or receive copies of the results when

returned by the laboratory.


7.31 Hexavalent Chromium This standard applies to occupational exposure to chromium (VI) in all forms and compounds in construction expect: exposures that occur in the application of pesticides, exposures to portland cement or where Gribbins Insulation Company has objective data demonstrating that a material containing chromium or a specific process, operation or activity involving chromium cannot release dust, fumes or mists of chromium (VI) in concentrations at or above 0.5 ug/m3 as an 8 hour TWA under any expected conditions of use.

a. Definitions 1. Action Level – A concentration of airborne chromium (VI) of 2.5 micrograms per

cubic meter of air (2.5 ug/m3) calculated as an 8 hour time weighted average (TWA).

2. Chromium (VI) [Hexavalent Chromium or Cr(VI)] – chromium with a valence of positive six, in any form and in any compound.

3. Emergency – Any occurrence that results, or is likely to result, in an uncontrolled release of chromium (VI). If an incidental release of chromium (VI) can be controlled at the time of release by employees in the immediate release area, or by maintenance personnel, it is not an emergency.

4. Employee Exposure – The exposure to airborne chromium (VI) that would occur if the employee were not using a respirator.

5. Historical Monitoring Data – Data from chromium (VI) monitoring conducted prior to May 30, 2006, obtained during work operations conducted under workplace condition closely resembling the processes, types of materials, control methods, work practices, and environmental conditions in the employer’s current operations.

6. Objective Data – Information such as air monitoring data from industry-wide surveys or calculation based on the composition or chemical and physical properties of a substance demonstrating the employees exposure to chromium (VI) associated with a particular product or material or a specific process, operation or activity. The data must reflect workplace conditions closely resembling the processes, types of material, control methods, work practices and environmental conditions in the employer’s current operations.

7. Permissible Exposure Limit (PEL) – The employer shall ensure that no employee is exposed to an airborne concentration of chromium (VI) in excess of 5 micrograms per cubic meter of air (5 ug/m3), calculated as an 8 hour TWA.

b. Exposure Determination 1. Gribbins Insulation Company shall determine the 8 hour TWA exposure for each

employee exposed to chromium (VI) in workplaces or work operations covered by this section.

2. Initial monitoring shall be conducted to determine the 8 hour TWA exposure for each employee on the basis of a sufficient number of personal breathing zone air samples to accurately characterize full shift exposure on each shift, for each job classification, in each work area. When representative sampling is conducted instead of sampling all employees in order to meet this requirement, Gribbins


Insulation Company shall sample the employee(s) expected to have the highest chromium (VI) exposures.

3. If initial monitoring indicates that employee exposures are below the action level, Gribbins Insulation may discontinue monitoring for those employees whose exposures are represented by such monitoring.

4. If monitoring reveals employee exposures to be at or above the action level, the employer shall perform periodic monitoring at least every six months.

5. If monitoring reveals employee exposure to be above the PEL, the employer shall perform periodic monitoring at least every three months.

6. If periodic monitoring indicates that employee exposures are below the action level, and the result is confirmed by the result of another monitoring taken at least seven days later, Gribbins Insulation Company may discontinue the monitoring for those employees whose exposures are represented by such monitoring.

7. Gribbins Insulation Company shall perform additional monitoring when there has been any change in the production process, raw materials, equipment, personnel, work practices, or control methods that may result in new or additional exposure to chromium (VI), or when the employer has any reason to believe that new or additional exposures have occurred.

8. Gribbins Insulation Company shall determine the 8 hour TWA exposure for each employee on the basis of any combination of air monitoring data, historical data or objective data sufficient to accurately characterize employee exposure to chromium (VI).

c. Employee Notification of Determination Results 1. Within 5 work days after making an exposure determination Gribbins Insulation

Company shall individually notify each affected employee in writing of the results of that determination or post the results in an appropriate location accessible to all affected employees.

2. Whenever the exposure determination indicates that employee exposure is above the PEL, Gribbins Insulation Company shall describe in the written notification the corrective action being taken to reduce employee exposure to or below the PEL.

d. Accuracy of Measurement 1. Where air monitoring is performed to comply with the requirement of this section,

Gribbins Insulation Company shall use a method of monitoring and analysis that can measure chromium (VI) to within an accuracy of plus or minus 25% and can produce accurate measurements to within a statistical confidence level of 95% for airborne concentrations at or above the action level.

e. Observation of Monitoring 1. Where air monitoring is performed to comply with this standard, Gribbins

Insulation shall provide affected employees or their designated representatives an opportunity to observe any monitoring of employee exposure to chromium (VI).


2. When observation of monitoring requires entry into an area where the use of protective clothing or equipment is required, Gribbins Insulation Company shall provide the observer with clothing and equipment and shall ensure that the observer uses such clothing and equipment and complies with all other procedures.

f. Methods of Compliance 1. Gribbins Insulation Company shall use engineering and work practice controls to

reduce and maintain employee exposure to chromium (VI) to or below the PEL unless the employer can demonstrate that such controls are not feasible. Whenever feasible engineering and work practice controls are not sufficient to reduce employee exposure to or below the PEL, Gribbins Insulation Company shall use them to reduce employee exposure to the lowest levels achievable, and shall supplement them by the use of respiratory protection.

2. Where Gribbins Insulation Company can demonstrate that a process or task does not result in any employee exposure to chromium (VI) above the PEL for 30 days per year, the requirement to implement engineering and work practice controls to achieve the PEL does not apply to that process or task.

3. Gribbins Insulation Company shall not rotate employees to different jobs to achieve compliance with the PEL.

g. Respiratory Protection 1. Where respiratory protection is required, Gribbins Insulation Company must

provide each employee an appropriate respirator that complies with the requirements of this paragraph. Respiratory protection is required during:

i. Periods necessary to install or implement feasible engineering and work practice controls;

ii. Work operations for which engineering and work practice controls are not feasible;

iii. Work operations for which Gribbins Insulation Company has implemented all feasible engineering and work practice controls and such controls are not sufficient to reduce exposure to or below the PEL;

iv. Work operations where employees are exposed above the PEL for fewer than 30 days per year and Gribbins Insulation Company has elected not to implement engineering and work practice controls to achieve the PEL; or

v. Emergencies 2. Where respirator use is required by this section, Gribbins Insulation Company

respiratory protection program shall be followed. h. Protective Work Clothing and Equipment

1. Where a hazard is present or is likely to be present from skin or eye contact with chromium (VI), Gribbins Insulation Company shall provide appropriate personal protective clothing and equipment at no cost to employees and shall ensure that employees use such clothing and equipment


2. Employees shall remove all protective clothing and equipment contaminated with chromium (VI) at the end of the work shift or at the completion of their task involving chromium (VI) exposure, whichever comes first.

3. No employee shall remove chromium (VI) contaminated protective clothing or equipment from the workplace, except for those employees whose job is to launder, clean, maintain or dispose of such clothing or equipment.

4. When contaminated protective clothing or equipment is removed for laundering, cleaning, maintenance, or disposal, the employer shall ensure that it is stored and transported in sealed, impermeable bags or other closed, impermeable containers.

5. Bags or containers of contaminated protective clothing or equipment that are removed from change rooms for laundering, cleaning, maintenance or disposal shall be labeled in accordance with the requirement of the Hazard Communication Standard.

6. Gribbins Insulation Company shall clean, launder, repair and replace all protective clothing and equipment required by this section as needed to maintain its effectiveness.

7. The removal of chromium (VI) from protective clothing and equipment by blowing, shaking or any other means that disperses chromium (VI) into the air or onto an employee’s body is prohibited.

8. Gribbins Insulation Company shall inform any person who launders or cleans protective clothing or equipment contaminated with chromium (VI) of the potentially harmful effects of exposure to chromium (VI) and that the clothing and equipment should be laundered or cleaned in a manner that minimizes skin or eye contact with chromium (VI) and effectively prevents the release of airborne chromium (VI) in excess of the PEL.

i. Hygiene Areas and Practices 1. Where protective clothing and equipment is required, Gribbins Insulation

Company shall provide change rooms. Where skin contact with chromium (VI) occurs, Gribbins Insulation Company shall provide washing facilities. Eating and drinking areas shall be provided in accordance with 1926.51.

2. Change rooms shall be equipped with separate storage facilities for protective clothing and equipment and for street clothes and these facilities shall prevent cross contamination.

3. Readily accessible washing facilities capable of removing chromium (VI) from the skin shall be provided and the affected employees shall use these facilities when necessary.

4. Employee who have skin contact with chromium (VI) shall was their hand and faces at the end of the work shift and prior to eating, drinking, smoking, chewing tobacco or gum, applying cosmetics or using the toilet.

5. When employees are allowed to consume food or beverages at a worksite where chromium (VI) is present, eating and drinking areas and surfaces shall be maintained as free as practicable of chromium (VI).


6. No employee shall enter eating and drinking areas with protective clothing or equipment unless surface chromium (VI) has been removed from the clothing and equipment by methods that do not disperse chromium (VI) into the air or onto an employee’s body.

7. Employees are prohibited from eating, drinking, smoking, chewing tobacco or gum or applying cosmetics in areas where skin or eye contact with chromium (VI) occurs; or carry the products associated with these activities, or store such products in these areas.

j. Medical Surveillance 1. Gribbins Insulation Company shall make medical surveillance available at no

cost to the employee, and at a reasonable time and place, for all employee: i. Who are or may be occupationally exposed to chromium (VI) at or above

the action level for 30 or more days a year; ii. Experiencing signs or symptoms of the adverse health effects associated

with chromium (VI) exposure; or iii. Exposed in an emergency.

2. All medical examinations and procedures required by this section shall be performed by or under the supervision of a PLHCP.

3. Medical examination shall be provided: i. Within 30 days after initial assignment, unless the employee has received

a chromium (VI) related medical examination that meets the requirements of this paragraph within the last twelve months;

ii. Annually; iii. Within 30 days after a PLHCP’s written medical opinion recommends an

additional examination; iv. Whenever an employee shows signs or symptoms of the adverse health

effects associated with chromium (VI) exposure; v. Within 30 days after exposure during an emergency which results in an

uncontrolled release of chromium (VI); or vi. At the termination of employment, unless the last examination that

satisfied the requirements of paragraph (i) of this section was less than six months prior to the date of termination.

4. The medical examination shall consist of: i. A medical and work history, with emphasis on: past, present and

anticipated future exposure to chromium (VI); any history of respiratory system dysfunction; any history of asthma, dermatitis, skin ulceration or nasal septum perforation; and smoking status and history;

ii. A physical examination of the skin and respiratory tract; and iii. Any additional tests deemed appropriate by the examining PLHCP.

5. Gribbins Insulation Company shall ensure that the examining PLHCP has a copy of this standard and shall provide the following information:

i. A description of the affected employee’s former, current and anticipated duties as they relate to the employee’s occupational exposure to chromium (VI);


ii. The employee’s former, current and anticipated levels of occupational exposure to chromium (VI);

iii. A description of any personal protective equipment used or to be used by the employee, including when and for how long the employee has used that equipment; and

iv. Information from records of employment related medical examination previously provided to the affected employee, currently within the control of Gribbins Insulation Company.

6. Gribbins Insulation Company shall obtain a written medical opinion from the PLHCP, within 30 days for each medical examination performed on each employee, which contains:

i. The PLHCP’s opinion as to whether the employee has any detected medical condition(s) that would place the employee at increased risk of material impairment to health from further exposure to chromium (VI);

ii. Any recommended limitations upon the employee’s exposure to chromium (VI) or upon the use of personal protective equipment such as respirators;

iii. A statement that the PLHCP has explained to the employee the results of the medical examination, including any medical conditions related to chromium (VI) exposure that require further evaluation or treatment, and any special provisions for use of protective clothing or equipment.

7. The PLHCP shall not reveal to the employer specific findings or diagnoses unrelated to occupational exposure to chromium (VI).

8. Gribbins Insulation Company shall provide a copy of the PLHCP’s written medical opinion to the examined employee within two weeks after receiving it.

k. Communication of Chromium (VI) Hazards to Employees 1. Gribbins Insulation Company shall ensure that each employee can demonstrate

knowledge of at least the following: i. The contents of this section; and ii. The purpose and a description of the medical surveillance program

required by paragraph (i) of this section. 2. Gribbins Insulation Company shall make a copy of this section readily available

without cost to all affected employees. l. Recordkeeping

1. Air Monitoring Data i. Gribbins Insulation Company maintain an accurate record of all air

monitoring conducted to comply with the requirements of this section. ii. This record shall include at least the following information:

a. The date of measurement for each sample taken; b. The operation involving exposure to chromium (VI) that is being

monitored; c. Sampling and analytical methods used and evidence of their

accuracy; d. Number, duration and the results of samples taken;


e. Type of personal protective equipment, such as respirators worn; and

f. Name, social security number and job classification of all employees represented by the monitoring, indicated which employees were actually monitored.

iii. The employer shall ensure that exposure records are maintained and made available in accordance with 29 CFR 1910.1020.

2. Historical Monitoring Data i. Where the employer has relied on historical monitoring data to determine

exposure to chromium (VI), the employer shall establish and maintain an accurate record of the historical monitoring data relied upon.

ii. The record shall include information that reflects the following conditions: a. The data were collected using methods that meet the accuracy

requirements of paragraph (d)(5) of this section; b. The processes and work practices that were in use when the

historical monitoring data were obtained are essentially the same as those to be used during the job for which exposure is being determined;

c. The characteristics of the chromium (VI) containing material being handled when the historical monitoring data were obtained are the same as those on the job for which exposure is being determined;

d. Environmental conditions prevailing when the historical monitoring data were obtained are the same as those on the job for which exposure is being determined; and

e. Other data relevant to the operations, materials, processing or employee exposure covered by this exception

iii. Objective Data a. Gribbins Insulation Company shall maintain an accurate record of

all objective data relied upon to comply with the requirements of this section.

b. This record shall include at least the following information: I. The chromium containing material in question;

II. The source of the objective data; III. The testing protocol and results of testing or analysis of the

material for the release of chromium (VI); IV. A description of the process, operation or activity and how

the data support the determination; and V. Other data relevant to the process, operation, activity,

material or employee exposures. c. Gribbins Insulation Company shall ensure that objective data are

maintained and made available in accordance with 29 CFR 1910.1020.

iv. Medical Surveillance


a. Gribbins Insulation shall establish and maintain an accurate record for each employee covered by medical surveillance under paragraph (i) of this section.

b. The record shall include the following information about the employee:

I. Name and social security number; II. A copy of the PLHCP’s written opinions;

III. Copy of the information provided to the PLHCP as required by paragraph (i)(4) of this section.

c. Gribbins Insulation Company shall ensure that medical records are maintained and made available in accordance with 29 CFR 1910.1020.

7.32 Ammonia

1. Ammonia is a colorless gas under normal conditions. It can be liquid under pressure. It has a pungent, suffocating odor.

2. High concentrations of ammonia gas, liquid gas, and solutions of ammonia can cause harm if inhaled or if they come into contact with eyes or skin.

3. Possible ways employees may be exposed to ammonia include: working on/near industrial refrigeration machinery rooms, equipment, and/or piping; working in petroleum refineries; and working with/near agricultural fertilizer.

4. Exposure of the eyes to ammonia may cause burning, tearing, temporary blindness, and severe eye damage. Exposure of the skin to ammonia may cause sever burns and blistering. Exposure of the respiratory tract (mouth, nose, and throat) to ammonia may cause runny nose, coughing, chest pain, severe breathing difficulties, severe burns, and death.

5. PPE will be provided and required if there is a possibility of skin contact with liquid ammonia or vessels containing liquid ammonia. Employees must use impervious clothing, gloves, face shields, and other appropriate protective clothing necessary to prevent any possibility of skin contact with liquid anhydrous ammonia or aqueous solutions of ammonia containing more than 10% by weight of ammonia. Similar precautions should be taken to prevent the skin from becoming frozen from contact with vessels containing liquid anhydrous ammonia.

6. Owners’ contingency plans and provisions will be provided to employees. Employees will also be informed where ammonia is used in the host facility and aware of additional plant safety rules.

7.33 Refractory Ceramic Fibers

a. General

Refractory Ceramic Fibers (RCFs), made from molten silica, alumina or kaolin clays are

used as a thermal insulation material, particularly in high temperature applications. Such

applications include industrial furnaces and boilers, high temperature stress relieving,


heat resistant application, high temperature pipe and vessel insulation, furnace linings

and heating element supports, high temperature gaskets and seals, encapsulated high

temperature insulation for the aerospace, automotive and appliance industries, fire

protection systems and fire stops.

b. Health Effects

There are no known reports of adverse health effects in humans when working with RCF

materials. There have been laboratory studies in animals that suggest inhalation appear

to cause fibrosis, lung cancer and mesothelioma. Epidemiology studies in the US and

Europe have led the International Agency for Research on Cancer (IARC) to classify

RCF as “possible carcinogenic” to humans.

Exposure to RCF may cause temporary irritation to the eyes, skin and respiratory tract.

Respiratory irritation is characterized by scratchiness or burning of the nose and throat.

Unprotected exposure to high concentrations of airborne fibers may cause coughing or

wheezing. Dermatitis, asthma, chronic lung disease and other pre-existing medical

conditions may be aggravated by exposure. Individuals with a history of allergies may

experience greater amounts of skin and respiratory irritation.

c. Exposure Limits

Although no PEL has been set by OSHA, the American Conference of Governmental

Industrial Hygienist and the Refractory Ceramic Fiber Coalition have posted their own

exposure limits.

American Conference of Governmental Industrial Hygienist – 0.1 fiber per cubic

centimeter (0.1 f/cc).

Refractory Ceramic Fiber Coalition, endorsed by OSHA – 0.5 fibers per cubic centimeter

(0.5 f/cc)

d. Safe Work Practices

a. Always wear the appropriate PPE.

b. Installing

i. Always keep airborne dust to a minimum.

ii. Use engineering controls, such as local exhaust or dust collecting

systems, to minimize airborne dust.

iii. Limit the use of power tools unless in conjunction with local exhaust. Use

hand tools whenever possible.

iv. Clean up with HEPA filtered vacuum or wet sweeping.

v. Do not use compressed air for clean up.


c. Removing

i. Dampen the insulation with a light water spray to control dust.

ii. Frequently clean the work area with a HEPA filtered vacuum or wet

sweeping.

iii. Drop cloths should be used where grating, openings or other

circumstances would allow for RCF materials to fall to a lower level.

iv. The area shall be barricaded with danger tape and a sign saying why it is

there with the following warning:

WARNING

Airborne Refractory Ceramic Fibers

Skin, Eye & Respiratory Irritant

Suspect Cancer Hazard*

Authorized Personnel Only

Protective Equipment Required

*2001 ACGIH Threshold Limit Value A-2

v. Materials shall be placed in labeled trash bags or containers to prevent

the release of airborne dusts and fibers. Bags or containers are required

to be disposed of in a RCF dumpster or other disposal methods approved

by the Owner.

d. Other Practices

i. Do not take unwashed work clothing home. If clothing must be taken

home, vacuum with a HEPA filtered vacuum before leaving the work area.

ii. Wash work clothes separately from other clothing. Rinse washer after

use.

iii. Do not smoke, eat or drink in the work area. Wash hands before eating,

drinking or smoking.

e. Personal Protective Equipment

a. A half face respirator equipped with a NIOSH approved P-100 cartridge.

b. A hooded Tyvek suit with footies

c. Cotton gloves.

d. Tape Tyvek suits at the wrist and ankles.


7.34 Environmental

Inherently Green At Gribbins Insulation, we are proud to be a part of the Green Movement. Because of its energy-saving qualities, insulation is an inherently green product. As an industrial and commercial insulation contractor, every single one of our projects is environmentally-friendly. The insulation that we install directly improves the efficiency of HVAC systems and process piping and equipment in commercial buildings and industrial plants. Our customers are some of the largest energy consumers out there, including power plants, hospitals, factories, and schools.

Insulation is one of the oldest types of green building materials and has long been used to save money and improve efficiency. The aspect of sustainability was often an afterthought. Even now, in the middle of a major “green movement,” many Federal and State energy programs take mechanical insulation for granted instead of encouraging more. Recent research from the Department of Energy and the National Insulation Association demonstrates that improvements in the use of mechanical insulation and more stringent insulation requirements would result in major energy savings in the industrial and commercial sectors alone: $4.8 billion in energy savings, a reduction of 43 million metric tons of CO2 emissions and 89,000 new jobs. The CO2 reduction would be the equivalent of shutting down nine coal plants every year.

July 2009 Press Release from the National Insulation Association. http://www.insulation.org/articles/article.cfm?id=PR090701

In addition to installing green materials, we are committed to waste prevention and recycling in our offices and warehouses.

EPA’s WasteWise Program The Environmental Protection Agency’s WasteWise program is a voluntary membership program that demands a commitment from “partners” like us to change our behaviors and track our waste reduction efforts. We joined the program in May 2010. WasteWise encourages all types of waste reduction efforts, including recycling and waste prevention, along with selling and manufacturing recycled products. By tracking our efforts, we will have a solid grasp on how our efforts help the environment and our bottom line. According to the WasteWise online membership list, Gribbins Insulation was the first construction-related partner to join from Illinois, Indiana, or Kentucky.

Recycling Our extensive recycling program at our main office in Evansville encompasses all aspects of our activities in the office and the warehouse. Large blue recycling bins are located throughout the facilities to collect mixed paper, and there are several bins for each of the following items: cardboard, aluminum, phone books, plastic bottles, and newspaper. In addition to the large bins, each employee has their own individual bin to collect mixed paper throughout the day, which can then be emptied into a larger bin. In the warehouse, we recycle about 30 large boxes a week. All of these recyclables are collected weekly and placed into our designated recycling dumpster, which we arranged with our waste collection provider. The recycling dumpster is full every week. In addition to what we place in the recycling dumpster, we take scrap metal to be recycled on a monthly basis. This usually totals about 350 pounds per month. We also recycle toner cartridges.


Waste Prevention Even better than recycling are the efforts to prevent waste at the source. Some of our efforts include: 1. Reuse wooden pallets – about 40 per week 2. Eliminated disposable cups for water and coffee – ceramic mugs available in the

break room 3. Removed fax number from all communications, including business cards, the

website, and email signatures. Customers and vendors are encouraged to use email.

4. Directive from executive management to limit printing and use email for all written communication.

5. Transitioned from a mailed company newsletter to electronic updates via website blog, company Facebook page, and email updates.

Office Supplies When it is not cost prohibitive, we purchase recycled-content napkins, plates, paper towels, hanging folders, manila folders, and any other products that are available.

Knauf Eco-Batt Insulation We are a proud supplier of Knauf Eco-Batt Insulation, which contains a minimum of 30% post-consumer recycled glass content. www.ecobatt.us

Ecofont

Gribbins Insulation is now a proud user of “Ecofont” for all internal communications. Featured in National Geographic Magazine, Ecofont is a font with holes that enables savings of about 25% on toner usage. The font is similar to Ariel, and at size 11 and below, the holes are barely noticeable. The font can be downloaded for free at the Ecofont website: www.ecofont.com.

The purpose of Gribbins Insulation Environmental Program is to ensure that construction

activities are conducted in accordance with all applicable environmental requirements to

protect the environment. Employees will be made aware of the proper method to

dispose of wastes.

Non Hazardous Waste

Non Hazardous waste shall be disposed of at frequent regular intervals in designated

disposal areas. Work areas shall maintain good housekeeping throughout all jobs.

Hazardous Waste

Hazardous waste must be disposed of in accordance with federal, state and local

regulations. Examples of hazardous waste include oils, fuel, paints and solvents,

aerosol cans, etc. Other examples include lead and asbestos, in this instance the owner


will be responsible for directing waste disposal. All hazardous waste must be handled

by trained employees with appropriate PPE and precautions.

Storage

There are special precautions that must be in place for storage of fuel, oils or other

hazardous waste. These precautions include:

A containment area or container that will contain 110 percent of largest container

in the storage area.

Must be located away from drains.

Elevate off of the ground.

Label the appropriately.

All containers must remain closed and be in good condition.

Labeling

Containers holding hazardous waste must be labeled with the contents of the container,

type of hazard and EPA hazardous waste number.

Spills

In the unexpected event that a spill or release occurs, employees should try to contain

the spill, if they know what the substance is, it is non hazardous and can be contained.

A spill kit shall be used to clean up the material and all drains shall be blocked to prevent

materials from getting into sewers or water ways. The employee shall notify the Owner

and Safety Department immediately of any spill or release.

General Waste Management

Universal Waste – The Universal Waste Rule is a modification of the hazardous waste rules enacted under the Resource Conservation and Recovery Act (RCRA). It is designed to reduce regulatory management requirements to promote recycling or disposal of certain categories of commonly generated hazardous wastes. The Universal Waste Rule does not potentially apply unless a waste is first characteristic or listed hazardous waste by definition under 40 CFR 261. Universal wastes include:

Nickel-Cadmium (Ni-Cd), Sealed Lead-Acid or Mercury-Oxide Batteries – these types of batteries are found in electronic equipment, cell phones, portable computers, emergency backup lighting and car batteries.


Agriculture Pesticides – These include agricultural pesticides that have been recalled or banned from use, are obsolete, have become damaged or are no longer needed.

Waste Mercury Containing Equipment – These include mercury containing thermostats, thermometers, barometers, mercury switches and certain types of meters, regulators and gauges, in which elemental mercury is contained in ampoules or otherwise enclosed and can be managed intact.

Waste Lamps – Include mercury or lead containing bulbs, fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium and metal halide lamps and mercury containing equipment.

All Universal Waste shall be disposed of in appropriate containers with proper labeling.

Hazardous Waste – Is a solid waste, or combination of solid waste that, because of its quantity, concentration, or physical, chemical or infectious characteristics may cause or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness or pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed. Hazardous wastes can be liquids, solids, semisolids, or contained gases. If a waste meets the definition of solid waste and has not been excluded by rule form the definition of hazardous waste, it is considered a hazardous waste if it is included on one of the four list of hazardous waste found in the regulation or it exhibits one of the four defined hazardous waste characteristics of ignitability, corrosivity, reactivity or toxicity.

All hazardous waste shall be properly disposed of in appropriate containers in designated areas with proper labeling.

Waste Oil – Waste oil is defined as any oil that has been refined from crude oil, or is a synthetic oil, and has been used and as a result of such use is contaminated by physical or chemical impurities. Used oils may include lubricants, hydraulic fluids, and heat transfer fluids, including commonly generated oils such as motor oil, hydraulic oils, metalworking oils, wire drawing solutions, refrigeration oil, or electrical insulating oil. If waste oils are not destined for recycling it becomes a hazardous or solid waste.

General Waste/Trash – Any non hazardous waste, including tape, unused insulation, metal or food scraps.

Waste Water – Is a liquid waste discharged which often contains some contaminants that result from the mixing of wastewater from different sources. Waste water can be classified as sanitary, commercial, industrial, agricultural or surface runoff.

There shall be no unauthorized discharges to sewers including sanitary sewer prohibition from Local Sewer use ordinances.

Aerosol cans shall be recycled if possible. If it is not possible to recycle them they can be disposed as nonhazardous waste if it can be ensured that the can is empty or that the product it contained was not hazardous and that the can itself is not hazardous.


Contaminated wipes shall be disposed of as to the type of contaminate on the wipe. If the contaminate is unknown the wipes shall be treated as hazard waste.

Spill Control and Clean-Up

In the unexpected event that a spill or release occurs, employees should immediately try to contain the spill, if they know what the substance is, it is non hazardous and can be contained. If the employee cannot contain the spill, do not know what the substance is or it is hazardous they shall notify the Owner immediately through the emergency telephone number. If the employee can control the spill they shall still immediately notify their supervisor who will then notify the Owner and Gribbins Insulation Safety Department.

A spill kit shall be used to clean up the material and all drains shall be blocked to prevent materials from getting into sewers or water ways.

Clean up materials shall be contained and disposed of in properly labeled containers.

All waste must be in an appropriate and compatible container. Cap and close containers at all times.

All containers must be in good condition and not leaking.

Containers must be stored in a manner that will not cause them to spill or leak. Store containers upright and place securely. Do not place containers in areas such as hallways, doorways or next to moving equipment.

All containers must be stored in a manner that readily allows for inspection.

All chemical must be properly labeled.

Chemicals should be segregated according to compatibility.

Good housekeeping practices shall be used in areas that are subject to hazardous chemical handling.

Hazardous Chemical Handling

When practical, drums and containers shall be inspected and their integrity shall be assured prior to being moved. Drums or containers that cannot be inspected before being moved because of storage conditions shall be moved to an accessible location and inspected prior to further handling.

Oil containers shall be included in any Spill Prevention, Control and Countermeasure (SPCC) Plan.

All hazardous chemicals shall have secondary containments to hold at least 100% of the contents of the original container. The discharge of any hazardous chemical into sewers is prohibited.


Any employee that will be working with or around hazardous chemicals, shall be trained on the methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area, the physical and health hazards of the chemicals in the work area, the measures they can take to protect themselves from those hazards and details of the hazard communication program including labeling and MSDS. All training shall be documented and keep on file at the Main Office.

All waste must be in an appropriate and compatible container. Cap and close containers at all times.

All containers must be in good condition and not leaking.

Containers must be stored in a manner that will not cause them to spill or leak. Store containers upright and place securely. Do not place containers in areas such as hallways, doorways or next to moving equipment.

All containers must be stored in a manner that readily allows for inspection.

All chemical must be properly labeled.

Chemicals should be segregated according to compatibility.

Good housekeeping practices shall be used in areas that are subject to hazardous chemical handling.

Storm Water Quality

A Storm Water Pollution Prevention Plan shall be developed, implemented and maintained for any project where discharge of sediment off-site or to a water of the state is possible or other pollutants that may be associated with construction activity. This plan will be developed by the Safety Manager and the site foreman will be responsible for compliance with this plan. This plan shall include erosion and sediment control practices and inspection and maintenance of control practices.

Employees shall be trained in the general sediment and erosion control and storm water pollution prevention practices.

The foreman of the job shall receive qualified individual training and experience before participating in the Storm Water Pollution Prevention Plan.

All inspection and training records shall be documented and records kept at Main Office.

7.35 Proper Lifting Techniques

a. Always use mechanical lifting devices if possible.

b. All equipment or materials that weigh over 50 pounds shall not be lifted by a single

employee.


c. Lift with your legs, not your back.

d. Have a secure grip before lifting.

e. Do not exceed your lifting capabilities.

f. Do not lift heavy objects above or away from your body.

g. Size up the load before you lift.

h. Do not twist your body when lifting.

i. Stop lifting immediately if you feel pain.

7.36 Pre Work Stretching

a. Employees are encouraged to perform pre work stretches each day. Stretching will get

your body ready to work and reduce the risk of sprain and strain injuries.

b. The following are a list of recommended stretches to perform. Each should be done for

20 to 30 seconds and comfortable enough to hold for 10 seconds.

1. Back

i. Bend slowly side to side.

ii. Place your hands on your lower back, bend your neck back and arch your

back.

iii. Place your legs together, slowly bend down and try to touch your toes.

iv. Slowly twist your upper body side to side.

2. Legs/Knees

i. Stand on one leg and reach behind your back and pull you foot up.

ii. Spread your legs, bend down and try to touch the ground.

3. Shoulders

i. Extend your arms and make large, slow circular motion with your arms.

Forward then backwards.

ii. Grab the opposite elbow and pull the elbow across your body.

4. Neck

i. Make a slow circular motion by rotating your head clockwise and then

counter clockwise.

ii. Place your hand on one side of your head and use your neck muscle to

push against your hand. Then switch and push from the other direction.


7.37 Cell Phones

Cell Phone Usage includes all activities on a hand-held mobile device, including talking,

texting, emailing, games, social media, etc.

a. Cell Phone Usage on the Jobsite

1. Supervisors:

i. Cell phones may be accessed outside of break areas only for business

purposes.

2. Other site personnel:

i. Cell phones are to remain in lunch boxes or break areas during working

hours. Cell phones may only be accessed during breaks.

ii. In the event of an emergency, instruct friends and family to contact a

main office or site office. You will be notified immediately.

b. Cell Phone Use While Driving

1. Refer to section 10.5.7 “Use of Electronic Devices”

c. Site Requirements

1. Employees must abide by all additional site requirements regarding cell phones

on their jobsite.

d. Disciplinary Action

1. Individuals found violating this policy will be subject to disciplinary action up to

and including termination.

7.38 Heat Related Illness

Heat related illnesses are progressive conditions caused by overexposure to heat. If they are recognized in the early stages they can usually be reversed. If they are not caught early they may progress to life threatening conditions. Supervisors and employees shall be trained in the measures to prevent heat stress.

a. Measures to Prevent Heat Stress

Engineering controls include general ventilation, personal cooling devices or protective clothing.

Work practice controls include drinking plenty. It is recommend that you drink one glass of water (8 ounces) every 15 to 20 minutes, depending on the heat and humidity. Employees shall have access to a sufficient amount of water throughout the day.

Alternating work and rest periods with more rest periods in cool areas can help workers avoid heat stress. If possible heavy work should be scheduled during the cooler part of the day. Employees will be provided with access to shade.


Acclimatization to the heat through short exposures followed by longer periods of work in the hot environment can reduce heat stress.

Read medication labels to know how to cause the body to react to the sun and heat. Avoid alcohol and drugs, they can increase the effects of heat. Employees shall be educated so they are aware of the need to replace fluids and salt

lost through sweat and can recognize dehydration, exhaustion, fainting, heat cramps, salt deficiency, heat exhaustion, and heat stroke. Supervisors shall be trained in the prevention of heat related illnesses, signs and symptoms and how to react if heat illnesses occur prior to working in the heat.

Physical factors that contribute to heat related illness should be taken into consideration before performing a task. The most common physical factors that can contribute to heat related illness are type of work, level of physical activity and duration, and clothing color, weight, and breathability.

b. Types of Heat Related Illnesses 1. Heat Cramps – Are severe muscle spasms that often begin suddenly in the hands,

calves or feet they are painful and disabling. The muscles become hard, tense and difficult to relax. They are caused by salt depletion as sweat losses are replaced by water alone. Heat cramps result from over exertion and heavy sweating.

2. Heat Exhaustion – Causes excessive fluid loss from heavy sweating, leading to increased fatigue, weakness, anxiety, drenching sweats, low blood pressure, faintness and sometimes collapse. Heat exhaustion results from prolonged exposure to extreme heat for many hours. The overheating is due to the electrolytic fluid loss that reduces blood volume, which lowers blood pressure and the pulse.

3. Heat Stroke – Is a life threatening condition is caused by over exertion and over exposure to extreme heat environments. Heat stroke is imminent when the core body temperature approaches 106 F any higher may result in coma or even death. The symptoms are dizziness, weakness, emotional instability, nausea/vomiting, confusion, delirium, blurred vision, convulsions, collapse and unconsciousness. The skin is flushed, hot to the touch, and at first may be covered with sweat that soon dries. Be aware of these warning signs.

c. First Aid Measures

1. Heat Stroke

Move the victim to a cool, shaded place. Remove heavy clothing; light clothing can be left in place.

Immediately cool the victim by any available means. This can be accomplished by placing ice packs at areas with abundant blood supply (neck, armpits, and groin). Wet towels or sheets are also effective. The cloths should be kept wet with cool water.

Continue to cool the victim until their temperature drops to 102 degrees Fahrenheit to prevent hyperthermia.

Keep the victim’s head and shoulders slightly elevated. Seek medical attention immediately. All heat stroke victims need

hospitalization. Care for seizures if they occur.


Do not use aspirin or acetaminophen.

2. Heat exhaustion:

Move the victim to a cool, shaded place. Keep the victim lying down with legs straight and elevated 8 to 12 inches. Cool the victim by applying cold packs or wet towels or cloths. Fan the

victim. Give the victim cold water if he or she is fully conscious. If no improvement is noted within 30 minutes, seek medical attention.

If any employee goes home due to or is showing signs or symptoms of a heat related illness the Safety Department must be notified immediately.


Section Eight

Emergency Plans

Emergency action plans shall be developed for all jobsites. These plans shall include what to do, where to go and emergency contact numbers in case of fire, serious, injury, severe weather/tornado, earthquakes or other catastrophes. These plans shall be posted and review with all employees when they arrive onsite. (See Appendix 8.1)

8.1 Fire

The following six emergency fire procedures all require planning, and should be established in advance. The basic concepts are applicable to an office, warehouse, fabrication shop or job site.

1. Make sure everyone knows what to do the instant a fire is discovered.

The first step is to SOUND THE ALARM. Different situations will have different procedures. The person who discovers the fire is supposed to: pull an alarm box, call the fire department, notify the in-house or job site fire brigade, report to his supervisor or call the switchboard operator.

Whatever it is, make sure everyone knows exactly how the alarm is to be given.

2. Make sure everyone knows what to do after sounding the alarm. After giving the alarm, not before, the individual has to make the decision whether to fight the fire. The wisdom of doing so depends on the circumstances. If it does not seem feasible to try to extinguish the blaze, the individual should know what equipment is available to him/her and how to use it. It is important that everyone know where fire extinguishers are located or whether or not there is a hand hose line nearby. If the individual discovering the fire can put it out, or get it under control, one thing every employee should be made aware of: No one should try to fight a fire alone. They should have at least one other person with them in case the fire gets beyond them. If they are weakened by the heat, smoke or exertion, or if the extinguisher is exhausted before the flames are out, they will need help fast. The second individual can come to their rescue and perhaps attack the fire with another extinguisher.


Whenever possible, each employee should have the opportunity to witness or personally practice the operation of a fire extinguisher or hose lien and learn their capabilities and limitations.

3. Evacuation Proper planning for emergencies includes the designation of an individual to be responsible for emergency evacuation operations. They could be the Branch or Office Manager, the Safety Manager, a Fire Brigade Chief, Foreman or some other designated person. The important thing is that you have an individual who knows that, should an emergency develop, they will have the responsibility for the personal safety of everyone on the premises. They must be able to account for every person, employee or visitor who may be in the emergency area. All employees must know their recommended evacuation route and an alternative in case the fire blocks their prime route. They must know the designated assembly area so that head counts can be taken to account for all personnel. The designated person responsible for the evacuation plan must have the authority to carry out all phases, and must have an alternate(s), who are thoroughly familiar with the plan. Where practical, the plan should provide for regular fire drills to test the emergency procedures. Also, at frequent intervals, simple questions should be directed to the employees by their supervisor to check on their understanding of the established procedures.

4. Salvage Operations Begin salvage operations as soon as the fire is out. Be prepared to use protective tarps, if needed, to cover materials and equipment. Arrange for temporary office or storage facilities if required. Know who to call for debris removal, odor removal and other salvage services you may need. During extended salvage operations, your personnel will need relief. Plan for it.


5. Communication

If an emergency has occurred, it is important that your employees, customers and suppliers be told, as soon as possible, what effects the emergency will have on your operation.

Don’t make them depend on the news media for this information. If you tell the story, not only will the facts be straight, but your public image will be enhanced. Assign an individual in your operation to be responsible for communication during and after the fire emergency. Their responsibilities should include contact with the media as well as communication to employees and customers. All communication with news media and other outside people shall be coordinated through Management. This should be done prior to any release.

Finally, the plan should be in writing to insure its continued existence when personnel changes occur. Annually or as conditions change it is vital that emergency plans be updated. Also the “Job Site Emergency Procedures” document must be completed for each job site and posted. Again, all employees must be made aware of these procedures and documentation of the training session (Tool Box Meetings) must be maintained.

8.2 Serious Injury

For serious injury emergency procedures, see Section 6 of this manual.

8.3 Severe Weather, Tornado, Lightning

1. In the event of severe weather or lightning, employees shall seek shelter in break trailers or other approved shelters until permission is given to go back to work from Owner, Construction Manager or foreman.

2. In the event of a tornado, employees shall muster in designated areas on the jobsite. If there are no designated muster areas, employees shall muster in the most interior part of the building or restrooms. If none of these are available, employees should report to a ditch or culvert and lay down with their neck covered.

8.4 Earthquakes

1. In the event of an earthquake, employees should muster in an area as far away from the building as possible. If you are still in the building stand under a door way or seek shelter under a secure object.


8.5 Employee Verification

1. In the event of any type of emergency the foreman shall be responsible for accounting for every employee onsite. Every employee shall report to the designated muster area to be accounted for. The foreman should take a head count and report any missing employees to the Owner, Construction Manager, General Contractor or emergency personnel.

8.6 Bomb Threats

1. All bomb threats are serious until proven otherwise. Act quickly, but remain calm and obtain information with the bomb threat checklist.

2. If a bomb threat is received by phone: a. Remain calm. Keep the caller on the line for as long as possible. Do not

hang up, even is the caller does. b. Listen carefully. Be polite and show interest. c. Try to keep the caller talking to learn more information. d. If possible, write a note to another employee to call the authorities or, as

soon as the caller hangs up, immediately notify them yourself. e. If your phone has a display, copy the number and/or letters on the window

display. f. Complete the Bomb Threat Checklist immediately. Write down as much

detail as you can remember. Try to get exact words. (See Appendix 8.2) g. Immediately upon termination of the call, do not hang up, but from a

different phone, contact the Police immediately with information and await instructions.

3. If a bomb threat is received by a hand written note: a. Call the Police b. Handle the note as minimally as possible.

4. If a bomb threat is received by e-mail: a. Call the Police b. Do not delete the message

5. Signs of a suspicious package include no return address, excessive postage, stains, strange odor, strange sounds, unexpected delivery, poorly handwritten, misspelled words, incorrect titles, foreign postage or restrictive notes.

6. Do not use two way radios or cellular phone. Radio signals have the potential to detonate a bomb.

7. Evacuate the building until police arrive and evaluate the threat. 8. Do not touch or move a suspicious package.


8.7 Crisis Management

1. In the event of a crisis on one of our jobsites the supervisor onsite should secure the scene.

2. Once the scene is secured the Crisis Management team shall be assemble to determine how to proceed. This team is comprised of the President, Vice President, Construction Manager and Safety Manager.

3. The Director of Marketing and Business Development should be the only person talking to media about an incident.


Section Nine

Training and Motivation

9.1 General

People do unsafe things because often they lack the knowledge or skill to do their job properly and safely and are unaware that what they are doing is wrong. They may never have learned to do the job the right way or they may perform safely under normal conditions, but not fully realize the dangers of certain unsafe acts under unusual job conditions.

Good instruction on a regular basis is extremely important to safety. We cannot take it for granted that everyone knows how to do his/her job in a safe manner or to expect them to learn the hard way. Under the Federal Law, the employer is responsible to instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposures to illness or injury.

9.2 Tool Box Safety Meetings

Tool Box Safety Meetings are the most direct and effective means we have to provide safety instruction and to communicate safety awareness to our field employees.

For all jobs, the meeting should be held weekly, scheduled on a specific day, time and place. The meetings should be well planned and need not last more than 30 minutes. Keep written records of all meetings and who was in attendance. Gribbins Insulation Company’s Weekly Safety Meeting form should be used to document this. (See Appendix 9.1) These safety meeting sheets should be turned in to the Safety Manager on a monthly basis.

Under the direction of the foreman, or other qualified persons, any accidents of the past week should be discussed by the workers in a free exchange. Ideas suggested to prevent further accidents can be acted upon immediately when they have merit.

Any timely topics that relate to safety can be discussed. The following are some of those topics: near misses that could have been serious accidents, newly identified job hazards, instruction on the use of personal protective equipment, reviewing their capabilities, limitations and maintenance requirements, reviewing the job emergency plan for fire, serious injury and natural disaster, reviewing OSHA Standards for each piece of equipment used on the job, reviewing OSHA


Standards for ladders and scaffolding, reviewing medical emergency plan for transporting a seriously injured worker to a hospital, reviewing company policies, reviewing job safety and work rules, Material Safety Data Sheets or concerns that have happened during the past week.

9.3 Brochures/Posters/Publications

There are many brochures and publication available on safety matters, relating to job site hazards, proper use of tools and equipment, etc. Appropriate materials of this type can be used as pass out material to workers in a continuing effort to increase their safety awareness.

Posters are also available on a wide range of subjects. Good technique in the use of posters is not to leave them up for long periods of time. After you feel the message has been seen by the workers, remove it. Workers become immune to posters that have never changed.

The above materials are available from many sources. If you would like to request any materials for your jobsite please contact the Safety Department.

9.4 Manager/Superintendant/Foreman Education

a. Manager/Superintendents and Appointed Safety Personnel As a foundation for Gribbins Insulation Company’s Safety Training Program, each Manager/Superintendent/Safety Person must read and be thoroughly familiar with the Safety Manual and complete at least 40 hours of continuing education each year.

b. Foremen All foremen will attend Gribbins Insulation Company’s Foreman Training Course. This training at a minimum will cover how to conduct a job hazard analysis, audits, weekly safety meetings, accidents investigations, emergency action plans. It should also cover when and how task specific training must be conducted, why and how enforcement of safety rules and regulation shall be conducted and the contents of the Safety Manual. Foremen Safety Meeting shall be held on a yearly basis to provide training. A portion of each meeting can be utilized for this purpose. The instruction should be well planned, well presented and relative to their job. Many of the Sections in the Safety Manual can be used as appropriate training subjects. It is important for Management to attend all Foremen Safety meetings to communicate the importance Gribbins Insulation Company places on safety.


9.5 Motivational Programs

Maintaining an interest in safety is necessary even if the work place has been engineered for safety, when procedures have been made as safe as possible and all employees have been thoroughly trained. Even with these optimum work conditions, accident prevention basically depends upon the desire of people to work safely. We must develop “safe” attitudes. One of the techniques used to maintain safety interest is a program utilizing safety objectives and awards. There are numerous types of programs with various safety objectives available for your use. A copy of the Gribbins Insulation Company Incentive Program shall be given to new hires after completion of the New Hire Orientation Program. A copy of the incentive program is located in Appendix 9.1.

9.6 Documentation

When safety training is given or received by the job site personnel, documentation of the training is required to be maintained. The documentation must include as a minimum:

Attendance list (signature and printed name) Date Trainer (signature) Subject Matter Cover

All training documentation is required to be maintained. This training should be documented using Gribbins Insulation Company’s Safety Training Report. (See Appendix 9.3)

9.7 New Hire Orientation

It is a vital part of our program that each new employee be orientated before performing work. New Hire Orientation teaches the employees what the rules and regulation are and what is expected of them before they begin work. This training will be conducted by the Safety Manager or Safety Coordinator.

During new hire orientation new employees will be made aware of OSHA’s and Gribbins Insulation Company’s rules, regulations and policies. Employees are given a copy of the Gribbins Insulation Company Safety Manual to look over and told where the manuals can be found on the jobsite for future reference. Each employee is given a copy of the training materials present for future reference. A


copy of Gribbins Insulation Company’s New Hire Orientation can be found in Appendix 9.4.

9.8 Task Specific Training

Employees shall be trained in the following areas if they are exposed to that type of hazard. The training will be documented and maintained by Gribbins Insulation Company. Employees shall be retrained when he/she exhibits signs or not understanding regulation or as necessary to meet changing Federal, State, Local and Project requirements.

The following is a list of minimum required topics for all employees: fall protection, personal protective equipment, ladder use, fire protection and prevention, aerial lifts, scaffold use, Hazard Communication, electrical safety, emergency action plans, confined space (when exposed) and lock out tag out (when exposed).

9.9 Job Hazard Analysis (JHA)

a. JHAs shall be done before each job involving more than 10 men begins to determine all hazards associated with that job. They should be done on a daily basis for the duration of the job.

b. All corrective or preventive action plans shall be sent to management for review.

c. Only trained employees shall conduct JHAs. d. Jobs or activities are investigated and analyzed when an accident, injury or

near miss occurs and reviewed. e. JHA should be completed on each type of equipment or activity to determine

the appropriate PPE. This JHA should be conducted by the Safety Manager or Coordinator and should include their name, signature and date.

f. JHAs shall be conducted using the Gribbins Insulation Company JHA Form. (See Appendix 9.5)

9.10 New Employee Mentoring Program

a. Program Elements a. The purpose of this program is to ensure that every new employee with

less than six months experience are trained, identified, adequately supervised and monitor to prevent injury to themselves or others, property damage, or environmental harm.

b. Once a new employee has successfully completed new hire orientation and site specific training they will be place in this program. The new employee will be assigned a mentor by their supervisor. During the 6


month evaluation period the mentor will train and evaluate the new employee’s safety awareness and comprehension. At the end of the 6 month period, the new employee will be removed from this program only after exhibiting safe behaviors and having a general awareness and working knowledge of Gribbins Insulation and the Owner’s health and safety rules and regulations.

c. An employee who does not qualify for release after the 6 month period may continue work only with documented approval from the Safety Department.

d. The Gribbins Insulation Supervisor may recommend a reduction of the 6 month requirements based on the employee’s performance and relevant industry experience. A reduction in the 6 month evaluation period must be approved by the Safety Department.

e. Documentation should be maintained for a period of 1 year after an employee has been removed from new employee mentoring program.

b. Mentor Minimum Requirements Be familiar with the new employee’s job, the oversight responsibilities

required, and the hazards associated with that job. Have completed Gribbins Insulation New Employee Mentoring Training. Be familiar with Gribbins Insulation and the sites policies, procedures. Exhibit the ability to recognize hazards and unsafe acts. Be able and willing to correct personnel in the workplace that do not

comply with Gribbins Insulation or the sites procedures, policies or requirements.

c. Supervisor Responsibilities Develop and communicate Safety Task Assignments (STAs) to the new

employee. Ensure the new employee mentor maintains proper knowledge and skills

in the particular job task assigned. Ensure the new employee mentor is adequately training the new

employee. Ensure the new employee is gaining the particular knowledge and skills in

the particular job tasks. Ensure the new employee is appropriately identified per this plan, Follow all safety rules and company policies of Gribbins Insulation and the

Owner. d. Mentor Responsibilities –

Have the desire, patient disposition and be willing to devote the necessary time to succeed as a mentor.


Possess knowledge and skills in the job tasks assigned to the new employee.

Be willing and able to effectively listen to the new employee to determine if the new employee is learning and retaining the knowledge being shared.

Be willing to observe the new employee perform a job without interfering as long as the new employee is not in a position to hurt themselves, others or damage equipment.

Provide a positive safety attitude, avoid criticism, and strive to build confidence and self-esteem in the new employee.

Be able to teach the new employee the proper way to create a quality STA and to follow that STA in performing tasks.

Refrain form taking short cuts and doing anything hazardous to health or safety

Demonstrate a positive work ethic at all times Follow all Gribbins Insulation and Owner policies and procedures.

e. Short Service Employee Responsibilities Be willing to watch and listen to the mentor. Establish a positive safety attitude towards assigned job tasks. Participate and learn the proper development of a STA and to follow the

STA in performing task. Be willing to gain the knowledge and skill in a particular job task to be able

to perform in a safe and environmentally sound manner. Stop and report unsafe conditions at any time. Participate in safety meetings. Follow all safety rules and policies of Gribbins Insulation and the Owner.

f. HSE Coordinator Responsibilities Conduct or provide access to the necessary safety training needed by the

new employee. Follow all Gribbins Insulation and Owner policies and procedures.

g. Notification

The jobsite foreman will notify the safety department of new employees on their site that require training.

h. Orientation

Each new employee shall successfully complete Gribbins Insulation New Hire Orientation prior to performing job tasks. Each new employee shall receive a Company Employee Handbook.


i. Training a. The new employee will be trained in: The hazards present in the work place The policies, procedures, and PPE utilized to control these hazards to

prevent illnesses, injuries, property damage and/or environmental incidents

The skills necessary to conduct their assigned jobs safely and efficiently while providing quality and economy.

b. The new employee will be retrained if they: Demonstrate they have not retained information from new hire

orientation. Violate a safety policy or procedure.

j. Identification

The new employee will be identified by the wearing a red Rookie sticker on their hard hat stating they are in the new employee mentoring program and the date that the employee was hired.

The supervisor shall remove the decals upon expiration of the new employee’s 6 month period only after verifying that the new employee exhibits a knowledge and skill level to perform the job tasks assigned.

Once the employee has successfully completed the mentoring process they will receive a yellow Seasoned sticker to replace the red Rookie Sticker.

After 5 years with no safety violations the employee will then receive a green Veteran sticker to replace the yellow Seasoned sticker.

k. Documentation

The supervisor shall complete the new employee notification form for new employees and forward to the Safety Department.

All records for the new employee’s orientation and training will be maintained at Gribbins Insulation’s main office.

Upon completion of training, supervisor signs off and forwards notification form to the Safety Department.

The Safety Department shall maintain orientation and training records for the new employee.


Section Ten

Vehicular Safety

10.1 Traffic Control

If at any time Gribbins Insulation Company employees are working in areas where they are on or near roadways, they shall contact the Safety Department to develop a traffic control plan before proceeding with work. This plan shall include what areas the employees will be working in, what procedures will be in place to protect the employees and what procedures will be used to notify motorist that work is being performed. All employees assigned to be part of traffic control or work in these areas must wear reflective hi visibility clothing in compliance with Department of Transportation Regulations.

10.2 Lift Trucks (Forklifts)

1. General Requirements a. Whenever equipment is unattended, the parking brake must be set and

the load engaging means shall be fully lowered. b. The brakes of highway trucks shall be set and wheels chocks placed

under the rear wheels to prevent the trucks from rolling while they are boarded with powered industrial trucks.

c. Wheel stops shall be provided to prevent railroad cars from moving during loading and unloading operations.

d. When a forklift is left unattended, load engaging means shall be fully lowered, controls shall be neutralized, power shall be shut off and brakes set.

e. If at any time a forklift is found to be in need of repair, defective or in any way unsafe, the lift shall be taken out of service until it has been restored to a safe operating condition.

f. All cab glass must be safety glass and free of cracks that could distort the operator’s vision.

g. Unauthorized passengers shall not be permitted to ride on lift trucks. h. Documented inspections shall be performed daily. Other inspection shall

be performed on a regular scheduled basis (see Inspection Requirements of this section).

i. Modifications and/or additions which affect capacity or safe operation shall not be permitted.

j. All lift trucks shall be equipped with either an audible or visual warning device.


2. Do’s and Don’ts a. All traffic regulations must be observed. b. Driver should always face the direction of travel. c. Yield the right of way to pedestrians. d. Ascend or descend grades slowly. e. Do not indulge in stunt driving or horseplay. f. Do not exceed the manufacturer’s load rating. g. Do not operate unsafe vehicles. h. Use low gear going down ramps or steep grades. i. Always operate with forks as low as possible. j. Keep your feet and legs inside the vehicle when in operation. k. Do not drive over objects lying on the floor. l. Do not speed. m. Do not permit anyone to stand under a load that is being hoisted, lowered

or suspended. 3. Operator Qualifications and Training

a. Qualifications Only trained and authorized operators shall be permitted to operate a powered industrial forklift. Operators of forklifts shall be qualified as to visual, auditory, physical and mental ability to operate equipment safely.

b. Training i. The training program should be presented completely to all new

operators and not condensed for those claiming previous experience.

ii. An operator training program should consist of the following: careful selection of the operator, safety rules, basic fundamentals of truck and component design as related to safety, introduction to equipment, control locations and functions, an explanation of how they work when used properly and problems when used improperly, supervised practice sessions, oral, written and operational performance tests and evaluations during and at completion of course and refresher course for periodic operator evaluation. A complete list of training requirement is located in section 9.

iii. Shall be conducted at least every three years or when the operator shows signs that he/she need retrained.

4. Inspection and Maintenance a. Maintenance

Maintenance of all lift trucks shall be performed in conformance with the manufacturers’ recommendations. A scheduled preventive maintenance and lubrication program shall be followed.


b. Safety Inspections The forklift operator shall be designated as the person responsible to perform the scheduled safety inspection on his/her assigned forklift.

i. Daily – A daily visual safety inspection shall be completed on the “Lift Truck Inspection Checklist” prior to being placed into service giving special attention to tires, warning devices, lights, battery, brakes, lift and tilt systems, steering mechanism and fire extinguisher. This visual inspection shall be performed prior to operation of the forklift. (See Appendix 10.3)

ii. Monthly – A monthly written safety inspection shall be completed on “Lift Truck Inspection Checklist”. A formal (written) safety inspection must also be performed prior to any forklift being put back into service after an accident that resulted in physical damage. Again, the “Lift Truck Inspection Checklist” must be used for this inspection.

5. Elevating Personnel Whenever a forklift is used to elevate personnel for any reason, the following precautions shall be taken for the personnel being elevated.

a. Use a safe platform secured to the lifting carriage and/or forks. (If the platform is not constructed with appropriate hand rails then personal fall protection must be provided and its use required.)

b. There shall be an operator in the control position on the truck at all times. 6. Changing and Charging Storage Batteries for Electric Trucks

a. Battery charging areas shall be designated for this purpose. b. Battery charging areas shall be ventilated to ensure diffusion of the gases

from the battery to prevent the accumulation of explosive mixtures. c. When charging batteries, make certain vent caps are functioning, vent

caps shall be kept in place to avoid electrolyte spray and covers shall be open to dissipate heat.

d. Smoking and open flames are prohibited. Signs shall be displayed prohibiting smoking and open flames.

e. Fire protection must be provided. f. Personal protective equipment shall be provided for employees handling

acids and batteries. This includes face shield, aprons and rubber gloves. g. Facilities for quick drenching of the eyes and body shall be provided within

25 feet of the battery charging area.


10.3 Vehicle-Mounted Elevating Work Platforms (JLGs, Scissor Lifts, etc.)

1. General a. Lift controls shall be tested each day prior to use to determine that such

controls are in safe working conditions. b. Only trained persons shall operate an aerial lift. This training must be

documented. c. Employees shall always stand firmly on the floor of the basket or scissor

lift deck, and shall not sit or climb on the edge of the basket or scissor lift handrail or use plank, ladders or other devices to increase work position height.

d. Occupants and equipment shall not exceed the maximum platform capacity for the specific boom model. See operations manual for actual capacity rating.

e. A safety harness shall be worn and a lanyard attached to the anchor point of the boom or basket.

f. Lifts may not be moved when the boom or work platform is in the elevated position unless the equipment is specifically designed for this type of operation and the working surface is level and free of debris and/or materials.

g. Never alter or disable machine components that in any way will affect safety or stability.

h. Never raise the platform in strong or gusty winds. i. Platform entry mid-rail, gate or chain must be closed before operating. j. Do not push or pull toward any object outside the platform or attach

overhanging loads. The maximum allowable side force is 150 lbs. k. There should be no more than two employees in a lift at one time. Only

one employee may operate the machine at a time. l. Do not use the machine on a moving surface or vehicle. m. Be aware of collision hazards while operating. Be aware of limiting sight

distance and blind spots when driving. Be aware of machine tail swing when rotating the turntable. Be aware of crushing hazards when grasping the platform guardrails. Do not lower the platform unless the area below is clear of personnel and obstructions.

n. Never start the machine if you smell or detect liquid petroleum gas, gasoline, diesel fuel or other explosive substances. Refuel and charge the batteries only in an open well-ventilated area free from sparks, fumes and lighted tobacco. Do not fuel the machine when the engine is running.

o. These machines are not electrically insulated and will not provide protections from contact with or proximity to electrical current. Be aware


of the machine’s working height and maintain safe distance from electrical power lines according to the chart below: Phase to Phase Minimum Safe Approach in feet 0 to 300 V Avoid Contact 300 V to 50 K V 10’ 50 K V to 200 K V 15’ 200 K V to 350 K V 20’ 350 K V to 500 K V 25’ 500 K V to 750 K V 35’ 750 K V to 1000 K V 45’

p. Keep away from the machine if it comes in contact with energized power lines. Personnel on the ground or in the platform must not touch or operate the machine until energized power lines are shut off.

q. Allow for platform movement, electrical line sway or sag and be aware of strong or gusty winds.

r. Do not use the machine as a ground for welding.

2. Inspection Procedures a. The lift operator shall be designated as the person responsible to perform

the scheduled safety inspections. b. A formal (written) safety inspection must be performed on each lift at least

once per month. Gribbins Insulation Lift Inspection Checklist must be used for this purpose.

c. A formal (written) safety inspection must also be performed prior to any lift equipment being put back into service after an accident that resulted in physical damage to the equipment. Again, the Lift Inspection Checklist must be used for the inspection.

d. A visual inspection must be performed daily on all lifts prior to being placed into service. This inspection shall be documented on Gribbins Insulation Lift Inspection Checklist. (See Appendix 10.4 and 10.5)

e. Do not operate unsafe equipment. f. Any equipment that is found to be defective should be immediately tagged

and removed from service. It should not return to service until it has been repaired by a qualified repair person.

10.4 Fleet Management of Company Vehicles, Trucks, and Vans

1. General a. It is a requirement of Gribbins Insulation that all highway vehicles be

maintained and operated in the safest possible manner. Each supervisor will be responsible to ensure compliance with this requirement.


b. All drivers of company vehicles must be approved by Jim Will, Risk Manager.

c. Any person operating a company vehicle must comply with all State and Local laws and regulations which govern the operation of the vehicle.

d. Every vehicle must be registered, licensed and inspected as required by applicable state laws.

e. Occupant restraint (seatbelt) usage is required. Vehicle operators are responsible for utilization of occupant restraints for themselves and passengers.

f. All vehicle accidents must be reported to the Safety Department immediately. A documented accident must be completed using Gribbins Insulation Company’s Vehicle Accident Form. (See Safety Manual Appendix 10.1)

2. Driver Qualification a. Designated and approved employee of Gribbins Insulation b. Understand, signed, and returned “Company Vehicle Rules

Acknowledgement” c. All drivers must be at least eighteen (18) years of age. d. All drivers must possess a valid driver’s license. e. All drivers must have a good driving record based on their personal Motor

Vehicle Record (MVR). MVR’s will be checked on an annual basis by Management.

3. Driver Regulations a. All drivers are required to wear seat belts while operating a fleet vehicle.

Also, the driver is responsible to ensure that passengers wear their seat belts.

b. Drivers shall obey all traffic rules, drive courteously and practice defensive driving techniques.

c. Drivers shall maintain a valid driver’s license. d. Drivers will receive approval from Jim Will or Pete before allowing another

employee to use their vehicle. e. No children, relatives, or friends are allowed to drive the vehicle. f. Drivers shall notify management:

i. When there is a change in the driver’s license status including suspension, revocation or restriction.

ii. Any and all accidents that occur in a company vehicle. iii. Any and all ticketed violations.

g. No employee will possess a firearm or illegal drugs or chemicals in their Company vehicle at any time.


h. Drivers will not operate a company vehicle after having consumed alcohol and/or drugs including legal drugs which may impair their ability to operate the vehicle.

4. Vehicle Inspections: a. Delivery Vans and Trucks

i. A formal (written) safety inspection must be performed on each delivery van and truck daily, prior to use. This inspection should include items such as, but not limited to, lights, turn signals, tires, horns, windshield wipers, etc. The Gribbins Insulation Vehicle Inspection Checklist must be used for this purpose. (See Appendix 10.2)

ii. The inspection checklist should be securely maintained in the glove box of the vehicle and turned in to the safety department at the end of each week. The safety department will retain these logs for one month.

b. Passenger Vehicles: i. The primary operator of the passenger vehicle must complete and

turn in to the safety department a vehicle inspection form with each regular maintenance, or at least once per year.

c. A formal (written) safety inspection must also be performed prior to any vehicle being put back into service after an accident that resulted in physical damage. Again, the Vehicle Inspection Checklist must be used for this inspection.

d. Do not operate unsafe vehicles. If the vehicle is unsafe contact the Safety Department immediately.

5. Accident Reporting a. Stop immediately – if possible pull off the traveled portion of the roadway. b. Warn other motorists – set out emergency flares, warning devices, etc. c. Check for injuries and render assistance only if immediate danger to life

and health. d. Call the police e. Get the names and addresses of witnesses. f. Exchange driver and vehicle information with other involved parties. g. Do not argue or make statements as to who is at fault. h. Notify management immediately and complete a vehicle accident form.

(See Appendix 10.1) 6. Vehicle Maintenance

a. Vehicle maintenance is essential to ensure that company vehicles function properly and safely.


b. It is the responsibility of the designated driver to ensure that the vehicle is maintained on a timely basis, in accordance with the manufacturer’s specifications.

7. Use of Electronic Devices a. Drivers should complete actions on personal electronic devices while the

vehicle is parked and/or use the phone in a “hands free” mode via a headset or speaker.

b. Drivers are prohibited from using a personal electronic device while operating a vehicle for any action besides a hands-free phone call.

c. While driving, attention to the road and safety should always take precedence over conducting business on a personal electronic device.

d. Hand Held Devices i. Use of handheld electronic devices, whether personal or business-

owned, while behind the wheel of a moving company vehicle is strictly prohibited.

e. Hands-Free Devices i. Although use of electronic devices under any circumstances is

discouraged while driving, the use of hands-free technology may be warranted in some circumstances.

ii. When using a hands-free device, drivers need to be aware when use of the cell phone is creating a distraction from safe driving and adjust their usage accordingly, including pulling off the road to continue/finish the conversation if needed.

iii. While driving, attention to the road and safety should always take precedence over conducting business on a personal electronic device.


Section Eleven

Off-the-Job Safety

11.1 Purpose

An off-the-job safety program is essentially one that deals with the employees when they are not at work. The principle aim of an off-the-job safety program is to get the employee to follow the same safe practices in his outside activities as he used on the job. The off-the-job safety program should not be a separate program, but rather an extension of Gribbins Insulation’s on-the-job program.

One of the basic reasons for any company to become involved in an off-the-job safety program is cost. Operating cost and production schedules are affected as much when employees are injured away from work as when they are injured on the job. Although accidents occur off-the-job, a large part of the cost is borne by the employer. Some of these costs are direct and some are hidden.

The approach to an off-the-job safety program should not be negative: “Don’t do this” or “Don’t participate in that activity”, but should instead be positive. This can be done by pointing out that any activity can be performed safely if the employee only thinks through the activity first, finds out what hazards are involved, takes instruction if needed and uses the correct procedures and equipment. Off-the-job safety programming activities should be kept seasonal, if at all possible, to help create interest and obtain effectiveness. Employees are generally more receptive to subjects when they coincide with their normal routine. Also, many local gun clubs, powerboat clubs, the Red Cross, YMCA, health, police and fire departments have proven to be of valuable assistance in promoting off-the-job safety.

There are three major benefits that Gribbins Insulation can realize by expanding its safety program to include off-the-job safety:

Reduction in lost production time and operating cost. Efforts in off-the-job safety can increase interest in on-the-job safety. Better public relations.

Changing employees’ safety attitude is an essential goal of the Safety Program. Instituting an off-the-job safety program will assist in our obtaining this goal. No asset is more important to Gribbins Insulation than its employees. They must be given a safe place to work with and incentive to be safe on and off the job.

11.2 Most Common Types of Off-the-job Injuries and How to Prevent Them

a. Falls – use ladder properly, use fall protection when needed, clean up spills, maintain adequate lighting, use hand rails, use non-skid backing on small rugs, avoid using rugs


at the top of stairs, do not stand on chairs or tables and clear debris off stairs and out of entrances

b. Motor Vehicle Accidents – practice defensive driving, do not speed, and exercise extreme caution in snow and rain.

c. Poisoning – be familiar with the poisons around your home, know how to contact your local poison center, keep poisons and medications out of the reach of children.

d. Fire – install fire detectors and test monthly, purchase a fire extinguisher and know how to use it, inspect your attic, basement, garage and closets for fire hazards, inspect your electrical wiring, have a fire escape plan and practice using it and do not use aerosols near open flames or while smoking.

e. Drowning – make sure you and your family know how to swim, if you enjoy boating, enroll in a boater safety course, and install anti-slip strips in your tub and shower.

f. Electrical Shock – inspect appliances, lamps, cords, outlets, avoid wet environments when working with electricity, use proper size fuses, have GFCI put on receptacles outside, in bathrooms, kitchens and were ever else water is possible.

g. Back Injuries – practice safe lifting and carrying techniques h. Firearms – secure firearms in a locked rack or cabinet and ammunition stored separately

from the firearms.

11.3 Wellness

Gribbins Insulation Company fells that employee wellness is an important part of our safety program. The advantages of employee wellness include decreased absenteeism, increased productivity and a decrease in injuries.

Gribbins Insulation Company will include wellness articles in weekly safety meetings to inform employees of ways they can increase their wellness.

Examples of way that employees can improve their wellness include:

1. Exercise at least 30 minutes 3 times a week. 2. Get enough of sleep 3. Eat a healthy well rounded diet. 4. Drink plenty of water. 5. Don’t smoke.

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