Procedure 10 – Environmental, Health and Safety Program
REV. 7
Revision History
Revision
Date
Comments
1
03-26-03
Added electronic links
2
12-11-09
General Revision
3
03-16-12
General Revision; renumbered procedure
4
10-01-14
Revised Disciplinary action section
5
09-14-16
Revised Sections 8.0 (Training), 10.0 (Recordkeeping & Reporting) and 11.0 (Accident/Injury Handling)
6
01-17-20
Annual Review
7
04-17-20
Form Revisions
8
07-30-21
Revised Disciplinary action section
1.0 PURPOSE
The purpose of this Environmental, Health & Safety (EHS) Program is to establish written guidelines for assuring safety in Nitro Construction Services workplaces. The intent is to provide a uniform approach to industrial occupational safety and health, to promote broader understanding among those persons who can affect safety.
Information contained in this manual was developed by a cooperative effort from the Operations, Engineering, Risk Management, and Environmental Health & Safety groups of the Nitro Construction Services. The procedures contained in this manual have been developed to assist in providing and maintaining a safe workplace. These procedures were developed per OSHA, ANSI, and EPA guidelines.
The work of Nitro Construction Services is quite diversified and involves work in a variety of locations and disciplines. Because of that diversity, it may become necessary to adhere to guidelines of a specific facility or client in addition to the Nitro Construction Services Environmental, Health & Safety Procedures.
This Environmental, Health & Safety Program is intended to comply with federal guidelines for construction and general industry safety. It applies specifically to Nitro Construction Services (hereafter referred to as “The Company” or “Nitro”), its subsidiary companies, and subcontractors.
2.0 EHS POLICY STATEMENT
Safety will be given primary importance in planning and operating all Nitro Construction Services activities to protect employees, clients, and visitors from occupational injuries and illness, property damage, or environmental loss.
Employees of Nitro Construction Services are our most valuable asset. Their safety is of vital concern. Recognizing the need and responsibility for the safety of its employees, Nitro Construction Services considers accident prevention an important and integral part of every operational undertaking.
Each member of Management is responsible for the safety, well-being, and safe work conduct of all persons who report to or are assigned to him. Cooperation and compliance with this policy are expected of all employees and is accepted as a condition of employment.
To carry out this policy the Company will:
1. Maintain safe and healthy working conditions while continually striving for process improvements.
2. Furnish, fit-for-purpose mechanical safeguards and personal protective equipment, where and when they are needed.
3. Maintain an active and aggressive EHS Program, for all employees, with complete participation, endorsement, and support by management.
4. Provide access to appropriate medical and first-aid facilities for work-related injuries and illness.
5. Maintain a continuous educational program for process safety improvements.
6. Insist that all employees observe established EHS regulations, best practices, and appropriate personal protective measures.
7. Review incidents to determine the cause and to develop measures to prevent reoccurrence.
8. Monitor compliance to EHS policy procedures and provide disciplinary action up to and including dismissal for noncompliance.
3.0 Structure and function of the Environmental, Health & Safety (EHS) Department.
The Safety and Health functions of our company continue to grow as a critical part of our day to day business and are even more critical to the future success of our company. The success or failure of our safety program will be a deciding factor in the ability of our company to be competitive in today’s market. This directive is issued to ensure that we continue to experience a high degree of safety and health program success by clarifying the roles and responsibilities of our safety and health professionals within our organizational structure. The site manager/superintendent is accountable for achieving project safety performance and program implementation.
Corporate Environmental, Health & Safety
The Corporate EHS Department writes, implements, and maintains corporate environmental, health, and safety policies. The EHS Department performs site audits to evaluate the utilization of best practices, compliance to corporate and client policies, and compliance to applicable OSHA and EPA regulatory law. The corporate EHS Department is responsible for accumulating and providing safety-related management data for corporate management, providing assistance in accident investigations, advising on safety engineering techniques and issues, acting as a liaison on customer safety issues, and acting as a resource for safety professionals assigned to specific projects.
The Hiring of Safety Professionals
All safety professionals are to be hired through the EHS Department. For specific projects, a joint effort by the EHS Department and Operations and/or Production Management shall be utilized to provide the appropriate staffing for site safety professionals. Professionalism and competence in the field of EHS will be the primary consideration in staffing selections.
Site Safety Professionals
The site safety professional will support a team approach in achieving safety performance and program implementation. The site safety professional will be responsible and accountable on a day to day basis administratively to the site manager but will maintain autonomy with respect to non-compliance issues. This autonomy will allow direct reporting to the Corporate Safety Director if events preclude the resolution of the issues at the project level. Good management practices dictate that safety issues that may arise during the course of the project should be addressed at the site level within the policies established by the Project Specific Safety and Health Plan (combines company policy with client-specific policies) and secondly by the policies set forth in the Corporate EHS Manual. If further guidance is needed, the Corporate Safety Director should be consulted. The basic responsibilities of the site safety professional are listed below along with guidelines for minimum requirements. Please note that on smaller projects these tasks remain the responsibility of the site manager as outlined in the Corporate EHS Manual.
As we grow, the process of assimilation can sometimes be awkward and not without some conflict. Each of you is expected to guard our success in this area by working within the framework of our policies and being proactive in the prevention of injuries and losses through professional planning and management of your projects.
Site Safety Professional Responsibilities
• Perform accident investigation and interface with doctors to minimize lost time and/or recordable incidents
• Selection of a Primary Treating Physician
• Jobsite compliance with Company Policies and regulatory requirements including training.
• Administration and implementation of the site safety program.
• Perform and document weekly safety inspections and corrective measures.
• Conduct weekly safety meetings.
• Perform or provide for exposure monitoring for various air contaminants.
• Interface with state and federal agencies.
• Interface with clients on EHS issues.
• Provide first aid services when qualified.
• Maintain all safety-related documentation.
• Perform regulatory training requirements when qualified.
• Interface with laboratories for analysis of contaminants.
• Inspect project for compliance to RCRA where applicable.
Site Safety Professional Qualifications
• High School Diploma at a minimum.
• Demonstrate 5 years of experience in Occupational Health & Safety activities with at least 50% of the time spent in safety.
• An Associate Degree from an accredited institution in Health & Safety or other technical and scientific disciplines.
• A Baccalaureate Degree in industrial hygiene, occupational health, or occupational safety.
• A combination of education and experience equivalent to 5 years.
Site Safety Professionals must meet the first two qualifications at a minimum. Individuals that have obtained higher education through an accredited institute may combine education and experience to meet these qualifications.
4.0 OSHA REQUIREMENTS
This Safety program is intended to meet the applicable requirements of CFR 29 Part 1926 and CFR 29 Part 1910. Other applicable OSHA requirements shall be referenced in the site Project Specific Safety and Health Plan (PSSHP).
1926.20 General Safety and Health provisions (OSHA General Duty Clause):
Contractor requirements:
(1) Section 107 of the Act requires that it shall be a condition of each contract which is entered into under legislation subject to Reorganization Plan Number 14 of 1950 (64 Stat. 1267), as defined in 1926.12, and is for construction, alteration, and/or repair, including painting and decorating, that no contractor or subcontractor for any part of the contract work shall require any laborer or mechanic employed in the performance of the contract to work in surroundings or under working conditions which are unsanitary, hazardous, or dangerous to his health or safety.
Accident prevention responsibilities.
(1) It shall be the responsibility of the employer to initiate and maintain such programs as may be necessary to comply with these requirements.
(2) Such programs shall provide for frequent and regular inspections of the job sites, materials, and equipment to be made by competent persons designated by the employer.
(3) The use of any machinery, tool, material, or equipment that is not in compliance with any applicable requirement is prohibited. Such a machine, tool, material, or equipment shall either be identified as unsafe by tagging or locking the controls to render them inoperable or shall be physically removed from its place of operation.
(4) The employer shall permit only those employees qualified by training or experience to operate equipment and machinery. Documentation of the training for authorized equipment operators shall be on file at the project.
5.0 RESPONSIBILITIES
It is the inherent responsibility of each employee to safeguard himself and his/her immediate environment in accordance with this EHS Program.
It is the direct responsibility of each supervisor to ensure that his/her team works in a safe manner and receives the training necessary to accomplish this objective.
It is the responsibility of Corporate leadership to set goals for EHS performance and to ensure adequate training and resources are provided to assure compliance to the EHS Program and other accepted industry EHS practices and standards.
6.0 SAFETY REPRESENTATIVE/COMPETENT/QUALIFIED PERSON
A qualified individual shall be designated as the “Safety Representative” for each job site. The Safety Representative, depending on the size, scope, and complexity of the project shall be a site safety professional or the site manager subject to the provisions of 14.3 of this section. In the absence of this individual, a member of the safety department or supervision shall be designated to function as the Safety Representative until their return.
This program refers to a “competent” or “qualified” person as being responsible for certain aspects of safety. This refers to persons who have received appropriate training and experience and who have the necessary authority to ensure compliance with specific EHS procedures and industry standards.
7.0 PROPRIETARY INFORMATION
This manual is a controlled document, in that each printed and complete EHS manual assigned to a specific person/position and will be updated with revisions. The manual will be primarily available for reference online through the company Intranet. It is the proprietary property of Nitro Construction Services. Please see the Revision Status and Distribution List attached.
8.0 TRAINING
Training is key to minimizing EHS-related problems. New hire orientation training should be conducted by the superintendent or safety representative. This training will consist of a general safety orientation, issuance, and review of the employer safety handbook and training on job-specific hazards and requirements. Weekly training sessions will be conducted by the superintendent or safety representative. These training sessions are usually on a single subject and are of short duration and may be conducted at the toolbox or tailgate level. All Nitro Construction Services site employees are required to attend these sessions. Attendance records are maintained of those persons present for any/all training sessions including new hire orientation. All training records, including new hire orientation and weekly safety meeting records, shall be sent to the Corporate Safety Director for retention. The records are maintained for the life of the job and are available for review and audit by management and clients.
9.0 NOTIFICATIONS
The following safety information shall be posted in a conspicuous location on each job site, including regional and home offices.
OSHA 2203 Poster – “You Have a Right to a Safe and Healthful Workplace”
A Panel of Physicians and medical help resources.
Emergency Phone Numbers
Copy of Injury Reporting Procedures
Copy of Drug and Alcohol Policy
These items are for the benefit of employees and must always remain posted while employees are on site. They will be audited by OSHA Inspectors and are grounds for citations and fines.
10.0 RECORDKEEPING AND REPORTING
Safety records are maintained on each job site during the life of the job. Duplicate copies may be stored at the home office and client copies are distributed as required.
The following items of OSHA compliance and worker’s compensation files and records should be kept on all job sites. These records will be audited in conjunction with site safety inspections from the Nitro Construction Services Home Office and are subject to auditing by OSHA Inspectors at any time. If you should need assistance or have questions, contact the Corporate Safety Director.
10.1 OSHA 300 Logs
10.1.1 Injuries that meet the guidelines for recordability should be recorded within 7 days.
10.1.2 The previous year’s OSHA 300A Log (Summary of Work-Related Injuries and Illnesses) should be posted no later than February 1st and remain posted until May 1st.
10.1.3 See other instructions on OSHA 300 Log.
10.2 First Aid Log: All First Aid actions and injuries shall be recorded on the “First Aid Log”.
10.3 Supplemental Injury Records consisting of the following:
(Copies, faxes, or originals of all reports in this section shall be sent to the Corporate Safety Director within 24 hours of injury/incident)
10.3.1 State First Report of Injury
10.3.2 Authorization for medical attention and physician’s release
10.3.3 Incident Investigation Report
10.3.4 Job Safety Analysis for each job contributing to injury
10.3.5 Root Cause Analysis for all lost-time injuries
10.4 Weekly Jobsite Inspection (should use a weekly checklist or equivalent and documentation should include corrective action of any hazards identified)
10.5 File of Weekly Safety Meetings – Completely filled out and signed by all employees. Copies are to be sent to the Corporate Safety Director for retention.
10.6 HAZCOM Log (Right-To-Know Log) including the following:
10.6.1 Copy of procedure
10.6.2 List of hazardous materials on site
10.6.3 MSDS’s
10.6.4 Acknowledgement of training documentation
10.7 Additional Supporting Documentation as Necessary
* Additional RECORD KEEPING may be required by clients or facilities
11.0 ACCIDENT/ INJURY HANDLING
Accidents shall be reported and documented as directed in Procedure No. 011.
All work-related fatalities are required to be reported to OSHA within 8 hours of occurrence. All work-related inpatient hospitalizations, all amputation, and all loss of an eye are required to be reported to OSHA within 24 hours.
Injured employees shall be given prompt medical treatment with participants from the designated panel.
For emergency treatment, employees shall be transported to the nearest emergency medical center. For severe injuries, the site or local EMS should be contacted for the transport of the injured.
12.0 SUBSTANCE ABUSE POLICY
Nitro Construction Services has a commitment to the safety of our employees and to the quality of work performed for our customers. The use, possession, or distribution of drugs or alcohol during working hours is completely inconsistent with the achievement of these objectives.
DRUG DISTRIBUTION: Any form of possession, distribution, and/or sale of illegal drugs is contrary to Company Policy and will result in immediate discharge. Any illegal substances will be turned over to the appropriate law enforcement agency and may result in criminal prosecution. This penalty will be imposed on whether these activities take place on or off the job site.
DRUG AND ALCOHOL ABUSE: The possession or use of illegal drugs on or off company premises or job site will result in immediate termination. In addition, if the possession or use of prescription drugs or alcohol off company premises or job site in any way affects an individual’s safe and efficient work performance or overall safety and efficiency, the penalty of termination may also apply.
Employees undergoing medical treatment where drugs are prescribed by a physician should report treatment to the Site Supervisor or Project Manager. Some prescription drugs have the potential to affect an individual’s ability to work safely. It is very important to notify Supervision whenever prescription drugs must be taken during or before working hours.
Employees who are under the influence of alcohol, or who possess or consume alcohol on the job, or on Client or Company property, will be subject to administrative action up to and including termination.
DRUG AND ALCOHOL TESTING: Applicants & employees shall have a drug test taken within the preceding 90 days of employment or seven days after hire; after injury, accident, for cause, and upon selection for random testing. All positive initial tests will be subject to confirmatory testing. Testing information shall remain confidential. Any individual refusing to submit to a test will be subject to dismissal. A positive test result, indicating that an individual was present at work while having drugs or alcohol in his or her system, will subject that individual to dismissal.
APPLICABILITY OF CUSTOMERS OR OWNERS POLICY: This policy is not all-inclusive as employees may also be subject to additional requirements regarding drug and alcohol use and/or possession by the policy of the Customer or Owner. It is the responsibility of the site manager to determine additional policy requirements of the Customer or Owner.
Employees shall sign a copy of the Substance Abuse Policy Acknowledgement and Consent form in Procedure No. 024.
13.0 HAZARD CONTROL PROGRAM
13.1 Asbestos Awareness
Refer to the Asbestos Abatement Procedure No. 046 in any situation where there is a potential to work around asbestos fibers. This procedure describes the facility owner’s and employee’s requirements and practices that shall be utilized to protect human life and the environment from asbestos fibers while performing removal and maintenance activities.
13.2 Lead Awareness
Controlling the lead hazard while removing paint coatings should be implemented whenever lead-based paint materials are being removed or disturbed so that lead particles cannot become airborne and breathed by humans. See EHS Procedure No. 047.
14.0 SITE-SPECIFIC EHS PLAN REQUIREMENTS
The purpose of the Project Specific Safety and Health Plan is to tailor the EHS Program to specific job sites. It should be included with the Work Plan for the job.
14.1 Start-Up Meeting: Prior to the start of any Nitro Construction Services job, a job start-up meeting is held in which the EHS Plan for the specific job is reviewed and approved.
14.2 Safety Policy Statement – The Safety Policy Statement should be posted for employees to read.
14.3 Assignment of Safety Responsibilities
14.3.1 The site manager maintains overall responsibility and accountability for safety at the site. The site manager is responsible for coordinating site safety requirements under this policy and procedures manual and for coordination with the Corporate Safety Director.
14.3.2 Provisions for Site Safety Coordinator will be required as conditions merit. A minimum of 25 employees may require a full-time Safety Representative and 50 employees will require a full-time Safety Representative.
14.3.3 The site safety coordinator will report administratively to the site manager while reporting functionally to the Corporate Safety Director.
14.3.4 In the event, that a full-time site safety coordinator is not assigned the site manager will be responsible for the safety functions at the site.
14.4 Safety Orientation for Employees – New hire orientation shall address the following as a minimum
14.4.1 Site-Specific Requirements
14.4.2 PPE (Personal Protective Equipment)
14.4.3 HAZCOM
14.4.4 Accident & Injury Reporting
14.4.5 Lockout/Tagout
14.4.6 Confined Space Entry
14.4.7 Hazards Associated w/Specific Job Tasks
14.5 Specialty Training – Identify & Implement
14.6 Safety Program Compliance
14.6.1 Disciplinary Action – The site manager is responsible for maintaining the goals set forth by corporate management. To ensure compliance with Nitro Construction Services and client safety procedures and with all applicable state and federal regulations, the following three-step enforcement policy will be in effect at the job site and administered by the site manager:
Violation – Not following verbal or written safety procedures, guidelines, rules, horseplay, failure to wear selected PPE, abuse of selected PPE, etc.
14.6.1.1 Violation of Life Critical Procedures – includes, but is not limited to, Fall Protection, Lockout/Tagout, Hot Work, Confined Space Entry, etc.
14.6.1.1.1 First Violation
If an employee is observed in violation of safety and health procedures or regulations, the employee is suspended for 3 complete working days and will require retraining prior to restarting work.
14.6.1.1.2 Second Violation
A second violation of a regulation or procedure, even if different from the first violation, will result in the employee being removed from the site and not eligible for rehire.
14.6.1.1.3 Management Discretion
Management and / or Safety reserves the right to terminate the employment of any employee who commits a violation of a life critical procedure if his/her actions indicate a lack of commitment to the program
14.6.1.2 Violation of Safety Procedures other than Life Critical:
14.6.1.2.1 First Violation
If an employee is observed in violation of non-life critical safety and health procedures or regulations, a verbal warning will be issued. Issuance of a verbal warning will be documented and placed in the employee’s job file.
14.6.1.2.2 Second Violation
A second violation of a non-life critical regulation or procedure, even if different from the first violation, will result in the employee being given a written warning. The employee will be required to sign the warning and a copy placed in the employee’s job file.
14.6.1.2.3 Third Violation
Upon the third violation, the employee will be dismissed and removed from the job site for a period of not less than 30 days.
14.6.1.2.4 Management Discretion
Management and / or Safety reserves the right to terminate the employment of any employee who commits a violation of a life critical procedure if his/her actions indicate a lack of commitment to the program
14.6.1.3 Flagrant (Willful) Violation
Management and / or Safety reserves the right to terminate the employment of any employee who commits any violation of a flagrant nature or through his/her actions indicate a lack of commitment to the program.
14.6.2 Incentives – Incentives will be addressed on an individual site basis.
14.7 Weekly Safety Meetings – establish schedule and subjects
14.8 Site Safety Inspections
14.9 Accident Investigation
14.10 Orientation for Sub-Contractor
14.11 Posting of Safety Information
14.12 Required PPE
14.13 Emergency Response Plan
14.13.1 Panel of Physicians and medical help resources.
14.13.2 Emergency Phone Numbers
14.13.3 Evacuation Plan
14.14 Procedures
Identify additional procedures applicable to the job and distribute to appropriate persons.
15.0 SITE ENVIRONMENTAL PLAN
If hazardous waste will or may be produced because of the work being performed, then a site environmental plan must be implemented and approved with the Project Specific Safety and Health Plan. See EHS Procedure No. 055.
16.0 ADDITIONAL FORMS
16.1 Additional Forms are available for use with the respective Corporate Safety Director’s approval.