SECTION 9: RETURN-TO-WORK PROGRAM Minger’s Return-to-Work Program is designed to restore an employee’s physical and mental ability to perform normal duties within their original job description. Working within an employee’s medical restrictions lessens productivity losses and reduces total incurred cost from incidents related to occupational safety and health. Employees are encouraged to return to work as soon as possible under this program in order to earn their full wages. This policy establishes guidelines for assisting employees who have sustained occupational injuries or illnesses restricting their ability to perform regular job duties or tasks. All of Minger’s employees are eligible for the Return-to-Work Program regardless of wage or salary. Employees may be informed by communicating the company policy via a safety meeting or toolbox talk, reviewing the policy as part of the new employee orientation, etc. Employees entering the Return- to-Work Program are expected to eventually return to full duty. Every reasonable effort shall be made to restore the physical and mental capacity of an employee injured on the job as soon as it is determined to be medically feasible to do so. A critical component to achieving maximum medical improvement requires effective rehabilitation and medical treatment. An overall treatment plan shall address the whole person and the opportunity to return to work within the restrictions of the particular injury or illness. This policy is not intended to instruct procedures applicable to employees who are eligible for reasonable accommodation under the American with Disabilities Act (ADA) or to leave benefits under the Family and Medical Leave Act (FMLA). Inquiry about eligibility under the ADA or FMLA should be directed to Minger’s Controller. NON-OCCUPATIONAL INJURY OR ILLNESS Injuries and illnesses occurring off the job shall not be accommodated in Minger’s Return-to-Work Program. Medical leave, paid time off and leave of absence policies apply to non-occupational injuries and illnesses. If the injury or illness constitutes a disability, policies regarding reasonable accommodation may apply. Contact Minger’s Controller/Authorized Minger Personnel for more information on reasonable accommodation for disabilities related to non-occupational injuries and illnesses. All non-occupational injuries shall be reported to the Supervisor and the Safety Department. Employees will be asked to return with a doctor’s note stating that it is safe for the employee to perform all normal daily work tasks without restrictions. Minger Construction Co., Inc. prohibits 51
employees from working with non-occupational injuries if the work performed while at work will worsen the existing non-occupational injury. BENEFITS OF RETURN-TO-WORK PROGRAM Returning employees to work who have been injured in the performance of their jobs is an important component of Minger’s safety and loss control program. Benefits of a Return-to-Work program include: • Employees are able to make their full wage vs the percentage from indemnity payments covered by insurance. • Faster, more effective healing. • Safer work environment. • Direct and indirect savings in lost wages, medical costs and productivity. • Improved morale by providing support to employees with alternate assignments during recuperation. • Employee retention. • Minimizes the impact on the company’s EMR. Statistics have shown that without a Return-to-Work program, employees have little incentive to return to work and are less likely to return to work the longer they are out of work. This safety policy and procedure includes provisions for supervisory training, a discussion of the return-to- work process, presents details on Minger’s preferred medical provider network and presents information on transitional work assignments, permanent job modifications and new position assignment requirements. RESPONSIBILITIES SAFETY DEPARTMENT • Complete full investigation for any injury with all personnel involved in the incident leading to the injury. • Administer Minger’s Return-to-Work Program. • Coordinate with preferred providers, authorized Minger personnel, and Supervisors in the placement of employees into transitional work assignments, permanently modified jobs or new positions. • Coordinate program communication by ensuring that timely distribution of program materials is performed. • Ensure effective implementation of this safety policy and procedure. • Provide resources and support to Supervisors in the Return-to-Work Program. • Assist in employee placement decisions. 52
• Meet with injured employees to explain alternate duty position(s). • Encourage proper and ethical practices. SUPERVISORS • Complete accident and other applicable forms in the event of an injury. • Pre-determine alternate duty options for the positions under their control. • Provide alternate duty options to the Safety Department, and Controller. EMPLOYEES • Promptly reporting injuries to their Supervisor. • Visiting preferred provider clinics and hospitals as directed by their Supervisor or the Safety Department if at all possible. • They must also cooperate with the Safety Department in order to return to work as soon as allowed by the medical professional. • Provide regular updates, at least weekly, to the Safety Department with medical reports on current health conditions, treatments, etc. CONTROLLER/AUTHORIZED MINGER PERSONNEL • Assist the Controller or Authorized Minger Personnel in placement decisions that require new position assignments. • Provide information regarding wage and salary grade equity issues. • Approve temporary assignments greater than ninety days. DEFINITIONS ALTERNATE DUTY: duties assigned on either a short term or permanent basis, and medically approved by the authorized treating healthcare provider, work comp carrier, to an injured employee. Alternate duties are assigned when none of the employees’ regular work duties can be performed due to the work restrictions. PERMANENT JOB MODIFICATION: jobs that are permanently modified for employees that have permanent restrictions upon return to work following an injury. Permanent job modifications and new position assignments are used for employees who receive a permanent disability as a result of an injury. Permanent job modifications may be the same as transitional work assignments except the transitional work assignments are temporary in nature. If an employee cannot be placed in a permanently modified job, then that employee may be assigned to another position that meets the restrictions imposed upon the employee by the treating physician. 53
PREFERRED PROVIDER: a healthcare provider that has entered into an agreement with the unions to provide prompt healthcare services to an employee injured during the performance of their jobs. The preferred provider network, Union Construction Worker’s Compensation Program, is a list of physicians who have agreed to treat injured union employees when such injuries arise out of the performance of their job duties. This preferred provider list should include orthopedic, neuro- surgeon, neurologist, urgent care or emergency room physicians. This list shall be maintained by the Union Construction Workers’ Compensation Program. If the employee chooses to treat outside of the UCWCP (Without permission) they are subject to the cost of treatment being denied. TRANSITIONAL WORK ASSIGNMENT: work assignments (duties) that are short term and those employees with temporary restrictions are given upon return to work following an injury. Transitional duties typically include a number of the employee’s regular work duties however, these duties may consist of modified work or alternative work as well. Employees may be provided with transitional work assignments during their recuperation in order to maintain desirable productivity levels. These assignments should be short term in nature (no greater than 90 days) until the employee is able to return to his/her original job assignment. WORKERS’ COMPENSATION LEAVE: period of time that employees are recuperating from job-related injuries and during which the employee receives a percentage of their regular pay. 54
SECTION 10 COMPLIANCE INSPECTIONS BY REGULATORY AGENCIES 55
SECTION 10: COMPLIANCE INSPECTIONS BY REGULATORY AGENCIES It is Minger policy to admit any lawfully delegated inspector of health Compliance Officer, who upon presentation of proper credentials, from a local, state or federal regulatory agency, requests entry to conduct a site inspection. The Safety Department is to be contacted immediately to be informed and to accompany the inspector/compliance officer for the inspection of the jobsite. Contact • Safety Department: Mike Nelson Cell Phone Number: 507-217-7019 Contact • Safety Department: Whitney Larson Cell Phone Number: 952-228-5452 This policy is not intended to abridge the Constitutional Rights of our subcontractors or the General Contractor who have the right to request for a warrant prior to allowing for an inspection to commence onsite. Each subcontractor and or the General Contractor must determine their desire for a warrant prior to an inspection commencing and they must notify the inspector/compliance officer immediately upon his or her arrival to the jobsite. Minger will not, under any circ*mstances, discriminate against and or terminate any employee that has exercised any right under the Occupational Safety and Health act of 1970 or any other regulatory standard, including the right to make safety and health complaints or to request a compliance inspection. REGULATORY AGENCIES The most common regulatory agencies that may conduct an inspection on Minger jobsites and or facilities at any time, include but are not limited to: • Occupational Safety & Health Administration (OSHA) • Minnesota Pollution Control Agency (MPCA) • Environmental Protection Agency (EPA) • City or County Officials 56
EMPLOYER RIGHTS Under OSHA Law, Minger has the legal right to: • Request the reason for the inspection. • Refuse to allow an inspection without a warrant. • Obtain legal counsel for the inspection. • Refuse to answer questions (LYING IS ILLEGAL). • Accompany the inspector while on site. • Request that trades secrets be kept confidential. • Refuse to allow employees to be interviewed on the job if it will interfere with their duties. • May request the inspector’s name, title and telephone number as well as that person’s Supervisor’s name. EMPLOYEE RIGHTS Under OSHA’s law, Minger employees have legal rights before, during and after any inspection by a regulatory agency. These rights include: • Prior appointment must be made before the employee may be approached for an off-site interview. • An employee cannot be contacted at home between 9:00 PM and 8:00 AM without prior permission. • Interviews are voluntary unless OSHA has a written order. • The employee may obtain legal counsel for the interview. • The employee may notify the employer of OSHA’s activity if he or she wishes. • The employee may obtain a written record of the interview. • An authorized representative of the employees, if any, also has the right to go along. HARASSMENT Local, state and federal compliance officers, inspectors, or similar personnel are not to be harassed, intimidated, or abused. Problems that arise during the inspection, which cannot be resolved, are to be referred to the Safety & Regulatory Compliance Department. Federal and state agencies may impose severe penalties against persons and/or companies who fail to abide with this section. Penalties may include monetary fines and jail terms. 57
INSPECTION PROCESS & PROCEDURES 1. CREDENTIAL VERIFICATION Ask to see the Compliance Officer’s credentials. Obtain a business card from the compliance officer or record at a minimum the agency they represent, first and last name, office address, phone number and email. If there are multiple compliance officers, gather the information from each compliance officer. If someone is not from a regulatory agency and or does not have credentials, they are to be denied access to the job site for an inspection. Actions to be taken at this point in time include the following: • Call the Safety Department immediately and ask the compliance officer to wait for the Safety Department to arrive onsite to accompany the officer during the inspection. • Stay calm. • Grab a pen, paper and camera. • Be polite and respectful. 2. OPENING CONFERENCE The next step will be the opening conference, at which time the Compliance Officer is to explain the purpose of the visit. At this time, it must be determined if the Supervisor, subcontractors or General Contractor would like to request a warrant. At any time before, during and after the inspection, Minger has the right to seek legal counsel. Actions to be taken at this point in time include the following: • NEVER admit guilt. • NEVER volunteer information. • NEVER demonstrate any procedures. • HALT all work on the jobsite and have the employees take a break immediately. 3. INSPECTION TOUR The function of the regulatory agency Compliance Officer is to identify conditions and/or acts that he/she considers unsafe and in violation of the regulatory agency standards promulgated by the regulatory agency he/she represents. In the case of an OSHA Compliance Officer this would mean the OSHA Safety and Health Standards, 29 CFR 1926 and 1910. In the pursuit of his/her duties he/she may go wherever the individual wishes on the job site. The regulatory agency compliance officer may take any number of samples or 58
measurements believed to be of importance, photograph objects or personnel, and conduct interviews with employees. He/she can request copies of any literature, documents, or those parts of the contract that relate to safety or industrial hygiene. Compliance Officers CANNOT require you to demonstrate anything or perform any procedures for their observation or evaluation. Compliance Officers DO NOT have the authority to control employees onsite. They are a guest on the Jobsite and should be treated with respect but not feared. Compliance Officers DO NOT have the authority to take any written material from the jobsite that is the property of Minger Construction Co., Inc. Actions to be taken at this point in time include the following: • Stay with the Compliance Officer for the entire inspection. • ALWAYS take photographs of whatever the Compliance Officer photographs and record all measurements that the Compliance Officer measures during the inspection. • Record all of the following information on your notepad: a. What the Compliance Officer asked to see on their visit. b. Whom the Compliance Officer talked to on their visit. c. Questions asked and comments made. d. Types of photographs, videos or samples were taken on the visit. e. Types of measurements taken and record what those measurements were recorded as during the inspection with the Compliance Officer. • Record all jobsite conditions and employee practices – both good and bad. • NEVER argue with the Compliance Officer. • ALWAYS tell the truth, but do not volunteer information beyond the questions asked. • Remove any employees from ALLEGED unsafe areas. • NEVER admit guilt. 59
4. CLOSING CONFERENCE The Compliance Officer is required to have a closing conference to review the findings during the inspection. During the closing conference, the Compliance Officer will advise you that this is time for free discussion of problems. Do not approach this as a friendly conversation or try to convince the Compliance Officer the issuing citations. Let the Compliance Officer state what he/she observed. Do not agree or admit guilt to any of the allegations stated by the Compliance Officer during the closing conference. Simply state that you understand what is being explained but that you do not wish to answer any questions or comment about the alleged safety violations. It is required to participate in the closing conference. If there is no participation from the contractor it may be noted by the Compliance Officer that there was a lack of cooperation or a lack of “good faith”. Actions to be taken at this point in time include the following: • Take additional photographs. • OPEN TRENCHES – At a minimum, take an additional 6 photographs of each open trench from different angles. • Take additional photographs of the specific areas, items, equipment, containers, surroundings, jobsite set-up, etc. that the Compliance Officer observed or photographed. NOTE: YOUR PHOTOGRAPHS MAY MAKE THE DIFFERENCE BETWEEN WHETHER OR NOT A CITATION IS ISSUED. • Draw diagrams of the jobsite. • Organize your notes. • Your notes contain valuable information on the direct observations that were made at the time of the inspection. Take the time to organize the information you have collected. NOTE: YOUR NOTES AND OBSERVATIONS MAY MAKE THE DIFFERENCE BETWEEN WHETHER OR NOT A CITATION IS ISSUED. • Complete the Compliance Inspection Report completely and accurately. 60
NOTIFICATION OF CITATIONS & PENALTIES The Compliance Officer is required to advise you of the hazards and potential penalties before leaving the jobsite and will send the citation & penalty notice to the company office. The following are the types of violations that may be cited by Minnesota OSHA and the penalties that may be proposed with the violation(s): Table 1: Maximum and Minimum Amounts for Civil Penalties Table 1: Maximum and Minimum Amounts for Civil Penalties Type of Violation Penalty Minimum Penalty Maximum Serious [$975] per violation $13,653 per violation Other-Than-Serious $0 per violation $13,653 per violation Willful or Repeated [$9,753*] per violation $136,532 per violation Posting Requirements $0 per violation $13,653 per violation Failure to Abate N/A $13,653 per day unabated beyond the abatement date [generally limited to 30 days maximum] The site management shall post a copy of the citation at or near the place where each alleged violation occurred. The citation must be posted for three working days or until the violation has been corrected (abated), whichever is longer. Failure to comply with posting requirements, even if the citation is contested, is punishable by a fine. 61
SECTION 11 HOUSEKEEPING & GENERAL WASTE MANAGEMENT 62
SECTION 11: HOUSEKEEPING & GENERAL WASTE MANAGEMENT GENERAL 1. Project waste, trash, and/or scrap materials will be taken into consideration before work begins. a. The Superintendent will enforce participation in housekeeping activities by all site contractors. b. Employees will be made aware of the proper method to dispose of wastes. c. Employee training is required for the proper disposal of waste materials. d. A program for debris removal throughout the site will be established by the Superintendent and agreed to by all subcontractors. e. Scrap materials and rubbish are fire and accident hazards. If an excess of these materials exists in areas, notify the Supervisor to arrange for removal. 2. Use the trash receptacles, which are located throughout the jobsite. If one is needed in the immediate work area, notify the Supervisor. Outdoor receptacles must be covered to eliminate the dispersion of waste & prevent runoff. 3. All equipment cabs, stairways, corridors, ladders, catwalks, ramps, and passageways must be kept clear of loose materials and trash. 4. Return all surplus materials to the stockpile at the end of the job. 5. Do not leave tools and materials where they will create a hazard for others. 6. Place oily rags in approved containers. 7. Wipe up spilled liquids immediately. If you are unable to handle the problem, notify the Supervisor so he/she can arrange for the necessary cleanup. Petroleum spills of five gallons or more shall be reported to the Minnesota Pollution Control Agency (MPCA). 8. Keep all job offices and trailers clean. Floor shall be cleaned and trash removed regularly. 9. An adequate supply of fresh, potable water, from a city water line, if possible, should be provided at a readily accessible location for drinking purposes. If this is not possible, bottled water or portable water containers shall be provided. 10. Portable water containers, used to dispense drinking water, must be capable of being tightly closed and equipped with both a tap and a paper cup dispenser. Where paper cups are supplied, a receptacle for disposing of the used cups should be provided. The use of pails and dippers or a common drinking cup for dispensing drinking water is prohibited. 11. From November to March, when temporary toilets are not placed inside of heated buildings, provisions shall be made for heating temporary toilets to a minimum of heat that can be emitted from the installation of a 1,3000-watt heater or other type equivalent heater. 12. All protruding nails, bands, wires, must be bent down, pulled, or removed; from lumber, packing cases, and bales. 63
OSHA Housekeeping 29 CFR 1926.25, 1926.151, 1926.250, 1926.252, 1926.852, 1926.853 1. General Requirements: a. Aisles, b. Walkways, c. And stairways must be kept clean and free of debris at all times. 2. Trash receptacles must be: a. Made available throughout work areas so employees have a convenient place to discard trash. b. Emptied regularly to permanently dispose of this material. 3. Failure to remove debris causes: a. Obstruction of other activities, b. Fire hazards, c. Potential for injury, d. Repetition in handling the material, e. And rising project costs. 4. Reusable materials must be cleaned, sorted, and stacked in appropriate storage areas. 5. Protruding nails must be completely removed from material. 6. The accumulation of “junk piles” of debris is not allowed in any yard or work area. 7. When possible, the promotion of recycling programs is advisable. 8. Materials must not be dropped or thrown from upper levels to lower levels, or to the ground from roof areas, unless the following conditions are met: a. Dropping Materials – Building Exteriors: • When dropping materials more than 20 feet to any area outside of a building, an enclosed chute must be used. b. Dropping Materials – Building Interiors: • When debris is dropped through holes in a floor, an enclosed chute must be provided. • Signs warning of the hazard of falling materials must be posted at each drop area. The removal of debris from the drop area must be timed so other debris is not dropped at the same time. 9. Trash must not be allowed to accumulate. 10. All combustible debris must be placed in containers and removed promptly. An extra fire extinguisher must be provided in these areas. a. Soiled rags. b. Crating, boxes, and packing materials. c. Lunch area scraps. 64
11. Solvent waste, oily rags and flammable liquids must be kept in fire resistant covered containers and removed daily. 12. Lunch areas must be kept clean and provide suitable receptacles for employees to dispose of their garbage. Cleanup Notice: in accordance with our subcontract agreement, the subcontractor must clean up and remove all rubbish and debris caused by its operations and in connection with the execution of its work to the satisfaction of Minger Construction Co., Inc. If cleanup does not satisfy Minger Construction Co., Inc. requirements, Minger Construction Co., Inc. will arrange to have this work performed after notifying the subcontractor in writing. The cost of work performed will be charged back to the subcontractor. 65
SECTION 12 HAND & POWER TOOLS 66
SECTION 12: HAND & POWER TOOLS GENERAL 1. Minger Construction Co., Inc. shall furnish the required equipment and tools for work. Company owned tools and equipment are not to be used for personal use. Employee-owned tools shall not be used for company purposes. 2. Inspect tools daily to ensure that they are in proper working order. a. Damaged or defective tools must be tagged out of service and removed from service immediately. b. Tools shall be kept clean, sharp, oiled, dressed, adjusted, etc. c. Chisels, star drills, etc. shall be dressed to prevent mushroomed heads from producing flying metal fragments. 3. Workers shall not wear loose-fitting clothing, chains, or other loose jewelry around equipment that poses an entanglement hazard. Long hair shall be tied back to keep it safely out of danger. 4. Eye protection is mandatory 100% of the time. Employees shall be provided with face shields where safety glasses are NOT sufficient when using hand and power tools, and exposed to: a. The hazard of falling, flying, abrasive, and splashing material. b. Harmful dusts, fumes, mists, vapors, or gases. 5. Power tools shall be hoisted or lowered by a hand line and never by the cord or hose. Cords and hoses must be kept out of walkways and off stairs and ladders. 6. Hand & Power tools must be placed so as not to be subjected to damage from equipment or materials. 7. Electrically powered tools and equipment shall be grounded or double insulated. 8. Hand tools shall be used for their intended purposes only. The design capacity of hand tools shall not be exceeded by unauthorized attachments. 9. All hand tools must be properly stored and tools having sharp edges must be sheathed. 10. When working overhead, tools must be secured to prevent them from dropping on the persons below. 11. All tools must be properly maintained. 12. All files must be fitted with handles. 67
MACHINE GUARDING 1. All machines, equipment and tools with Belts, gears, shafts, pulleys, sprockets, spindles, drums, flywheels, chains, or other reciprocating, rotating or moving parts of equipment shall be guarded if such parts are exposed to contact by employees or otherwise create a hazard. Guarding shall meet the requirements as set forth in American National Standards Institute, B15.1-1953 (R1958). 2. All ON-OFF controls shall be clearly labeled, marked in red and readily accessible to the operator to deactivate the equipment in case of an emergency. 3. Guards may only be removed in order to perform a task in which the guard is inhibiting the work from being performed. The guard must be removed and set next to the work area. Once the specific task has been completed, the guard MUST be installed back onto the machine or tool. All PPE shall be worn at all times. ELECTRICAL TOOLS 1. Minger Construction Co., Inc. will provide all non-hand tools (power, powder, etc.). 2. All portable electric tools must have grounded cords, or be of an approved double insulated type. 3. Double insulated tools must be easily identified as such by the manufacturer. 4. All electrically powered tools must be inspected each day before use for: a. Breakdown of cord insulation. b. Proper grounding. 4. Temporary electrical cords must be covered or elevated to protect the cord from being damaged, and to avoid tripping hazards. 5. Never use electrically powered tools in or around flammable liquids or vapors unless the tool is explosion proof. 6. Tools shall not be carried by or pulled out of outlets by the cord. CHAIN SAWS 1. Chain saws shall have an automatic chain brake or kickback device. 2. A face shield, gloves and protective leg chaps are mandatory when operating a chainsaw. 3. Never use a chainsaw to cut above shoulder height. 4. Hearing protection is required during operation. 68
CUT OFF SAWS 1. All guards must remain in place at all times. Eye protection and face shields are always required when using chop saws (safety glasses alone are not sufficient). 2. Chop saws shall be operated with two hands on the machine at all times. BENCH GRINDER 1. Floor and bench-mounted abrasive wheels, used for external grinding, must be provided with protective hoods capable of stopping broken wheel chips. 2. Adjustable work rests must be kept within 1/8 inch from the wheel surface. 3. Abrasives must be ‘ring’ tested before mounting. A dull thud sound indicates cracking or other defects. 4. For small piece work, pliers or equivalent must be used to hold the piece against the wheel. 5. Eye protection is required (i.e., face shields or goggles). COMPRESSED AIR 1. When air hoses are connected together, or attached to tools or compressors, couplers must be secured to prevent accidental separation. (For example: Place wire through the coupler alignment holes, use chains/ cables to secure the connection and the use of whip checks.) 2. When compressed air is used for cleaning purposes, a blow pipe with an on/off valve, that automatically closes, must be attached to the live end of the hose and not exceed 30 PSI. Eye protection must always be worn when using a blow pipe. The pipe shall not be pointed at other personnel or used for personal cleaning. 3. All hand-held pressure hoses and nozzles that could cause injury when the hose or nozzle is not being held, including air, water, hot water and steam, and all high temperature hoses or nozzles including hot water and steam, shall have a constant pressure control. 4. Compressed air cylinders must be visibly inspected before use. 5. All air receivers must be equipped with a pressure indicating gauge. 6. All safety valves must be tested prior to use. 7. The drain valves on air receivers are to be opened and the receiver completely drained frequently to prevent accumulation of excessive amounts of liquid in the receiver. FUEL-POWERED 1. Fuel-powered tools must be shut down while being refueled. 2. Refueling must be conducted away from any possible sources of ignition. 3. Using fuel-powered tools indoors should be the last option available. If this option is used, the air quality must be monitored continuously. For example, if the building is closed up for weather protection, all of the gasoline powered lifts shall be switched over to scrubbed diesel or electric. 69
ABRASIVE WHEEL EQUIPMENT 1. Before mounting, the grinder and wheel must be closely inspected according to manufacturer specifications for damage. 2. The wheel should be sound-tested or ring-tested (tapped gently) to ensure that it is free from cracks or defects with a non-metallic instrument. a. If the wheels sound cracked or dead, they must not be used because they could fly apart in operation. b. A stable and undamaged wheel, when tapped, will give a clear metallic tone or \"ring.\" c. To prevent an abrasive wheel from cracking, it must fit freely on the spindle. The spindle nut must be tightened enough to hold the wheel in place without distorting the flange. d. Allow the tool to come up to operating speed prior to grinding or cutting. The employee should never stand in the plane of rotation of the wheel as it accelerates to full operating speed. e. The maximum rating of the grinder shall not exceed the maximum operating wheel speed. 3. Portable grinding tools need to be equipped with safety guards to protect workers not only from the moving wheel surface, but also from flying fragments in case of wheel breakage. a. Grinders that use a coolant shall be equipped with splash guards to prevent coolant from coming into contact with the operator. 4. Grinding wheel work rests shall not be more than one-eighth inch from the grinding wheel. 5. Non-handheld grinders such as floor stand or bench-mounted types shall be fastened and secured to a working surface to prevent shifting or tipping during operation. 6. All ON-OFF controls shall be clearly labeled, marked in red and readily accessible to the operator to deactivate the equipment in case of an emergency. 7. All abrasive wheel equipment must be equipped with a dead man swtich. POWDER-ACTUATED TOOLS 1. Powder-actuated tools must be treated with extreme caution and only operated by specially trained employees. 2. Inspect the tool before using it to determine that it is clean, that all moving parts operate freely, and that the barrel is free from obstructions and has the proper shield, guard, and attachments recommended by the manufacturer. 3. Do not load the tool unless it is to be used immediately. 4. Do not leave a loaded tool unattended, especially where it would be available to unauthorized persons. 5. Do not use spark producing tools or equipment in an explosive or flammable atmosphere. 6. The user must select a powder level -- high or low velocity -- that is appropriate for the powder-actuated tool and necessary to do the work without excessive force. 70
7. The muzzle end of the tool must have a protective shield or guard centered perpendicular to and concentric with the barrel to confine any fragments or particles that are projected when the tool is fired. A tool containing a high-velocity load must be designed not to fire unless it has this kind of safety device. 8. To prevent the tool from firing accidentally, two separate motions are required for firing. a. The first motion is to bring the tool into the firing position. b. The second motion is to pull the trigger. c. The tool must not be able to operate until it is pressed against the work surface with a force of at least 5 pounds (2.2 kg) greater than the total weight of the tool. 9. If a powder-actuated tool misfires complete the following steps: a. Hold the tool in the operating position for at least 30 seconds before trying to fire it again. b. If it still will not fire, hold the tool in the operating position for another 30 seconds and then carefully remove the load in accordance with the manufacturer's instructions. This procedure will make the faulty cartridge less likely to explode. The bad cartridge should then be put in water immediately after removal. c. If the tool develops a defect during use, it should be tagged and must be taken out of service immediately until it is properly repaired. 10. When using powder-actuated tools to apply fasteners, several additional procedures must be followed: a. Do not fire fasteners into material that would allow the fasteners to pass through to the other side. b. Do not drive fasteners into very hard or brittle material that might chip or splatter or make the fasteners ricochet. c. Always use an alignment guide when shooting fasteners into existing holes. d. When using a high-velocity tool, do not drive fasteners more than 3 inches (7.62 centimeters) from an unsupported edge or corner of material such as brick or concrete. e. When using a high velocity tool, do not place fasteners in steel any closer than 1/2- inch (1.27 centimeters) from an unsupported corner edge unless a special guard, fixture, or jig is used. f. Powder-actuated tools used by employees shall meet all other applicable requirements of American National Standards Institute, A10.3-1970, Safety Requirements for Explosive-Actuated Fastening Tools. 71
SECTION 13 FIRE PREVENTION & PROTECTION PLAN 72
SECTION 13: FIRE PREVENTION & PROTECTION PLAN GENERAL 1. Fire protection must be provided at each project. This will normally consist of 20 lb. ABC extinguisher, although in certain circ*mstances carbon dioxide or Halon may be needed. The use of soda-acid or carbon tetrachloride is prohibited. 2. All extinguishers must be conspicuously located. Each extinguisher will be subject to a monthly visual check by a designated employee and inspected annually by an authorized inspector. Extinguishers will also be inspected when they have been discharged or damaged. Each extinguisher will have a durable tag, or equivalent, securely attached to show the maintenance test and recharge date. 3. A minimum of one ABC extinguisher must be located within 35 ft. of all hot work operations and/or heat-producing equipment. In addition, all combustibles must be removed from the immediate area or adequately covered to limit the potential of a fire. When hot work operations do not permit normal fire prevention precautions, a fire watch is required and work must be completed a minimum of thirty minutes prior to the end of the work shift. (refer to Hot Work Policy) 4. Fire extinguishers will be located in each job trailer and office trailer. A 20 lb. ABC fire extinguisher is required for each 3000 sq. ft. building, with travel distance from any area not to exceed 100 ft. In addition, at least one extinguisher must be provided per floor, located adjacent to the stairway. 5. A minimum of one 5 lb. ABC extinguishers must be located in the cab or near the operator station of all cranes, trucks, and heavy equipment over 10,000 lbs. 6. Emergency telephone numbers and alarm systems shall be established according to Minger Construction Co., Inc.’s Emergency Action Plan. 7. Access to firefighting equipment must be maintained at all times. Firefighting equipment will be conspicuously located. 8. Housekeeping must be maintained on the jobsite so access to firefighting and/or building exits is not limited. 9. Combustible materials stored outside cannot be piled higher than 20 ft. 10. Outdoor yard storage areas must have fire extinguishers conspicuously located so that the maximum travel distance to the nearest unit does not exceed 100 ft. 11. Smoking is prohibited in areas of operation which may constitute a fire hazard, and will be identified by signage reading “NO SMOKING OR OPEN FLAME”. 12. When using flammable/combustible liquid in excess of 5 gal., a fire extinguisher must be provided within 50ft. 73
TRAINING 1. Employees will initially receive training on fire protection through safety orientation and safety meetings. Additional training is to be completed upon initial assignment and on an annual basis. 2. Training will include the following: a. Proper use of fire extinguishers and/or other fire protection equipment. b. Inspection of fire extinguishing equipment as well as location of equipment. c. Emergency procedures – contacting authorities, supervisor, client, etc.… d. Identifying the right fire extinguisher for the type of fire. PROCEDURES 1. Familiarize yourself with the location of all firefighting equipment in your work area. In addition to 911, have the numbers of the local fire department on the jobsite emergency sheet. 2. Keep areas around firefighting equipment clear at all times. Do not hang items on or store materials near fire extinguishers. 3. Only approved solvents shall be used for cleaning and degreasing. The use of gasoline and similar flammable products for this purpose is prohibited. 4. Keep the work area clean. An orderly jobsite reduces fire and accident potential. 5. When you must weld or burn near combustible materials, move them, cover with fire resistant material, or wet them down. A fire watch is recommended for one hour following the use of welding or cutting equipment. 6. Flammable and combustible liquids must be handled only in approved, properly labeled safety cans. 7. Place oily rags in approved metal containers. 8. Do not attempt any work involving a source of ignition near a pit, sewer drain, manhole, trench, or confined space where flammable gases may be present. Wait until tests have been made with an approved combustible gas indicator and the area has been declared safe for hot work. 9. Except during cleaning and grubbing operations, the use of open fires is strictly forbidden. Exceptions must be authorized by the responsible Supervisor and local Fire Department. 10. Do not weld or cut on a tank or in an enclosure that has contained gasoline or other flammable gas or liquid without specific instructions from your Supervisor. 11. A fire extinguisher shall be kept in the area wherever work is being performed that produces sparks, flames, or heat. 12. Fire extinguishers shall be inspected prior to the start of each job and immediately after use. 13. Report all fires immediately to your Supervisor. 14. Inspect fire extinguishers monthly. 74
PASS 1. Use the following fire extinguisher operation method: P – Pull the pin on the extinguisher. A – Aim at the base of the fire. S – Squeeze the handle. S – Sweep at the base of the fire. 2. REMEMBER: a. Stand about 10 ft. from the fire. b. Fire extinguishers last approximately 10 seconds. c. Be aware of smoke and fumes in the ambient (surrounding) air. 75
SECTION 14 CONFINED SPACE ENTRY PROGRAM 76
SECTION 14: CONFINED SPACE ENTRY PROGRAM 29 CFR 1926 Subpart AA This program is designed to provide a system for uniform and safe entry of personnel into confined spaces. For the purpose of this procedure, a confined space has all of the following characteristics: a. Sized and configured so that a person can enter to perform work b. Limited restrictive means for entry or exit (limited egress) c. Not designed for continuous occupancy Confined spaces may contain an atmosphere hazardous to human life because of oxygen deficiency or the presence of flammable or toxic gases, liquids, solids, vapors, dusts, mists, or fumes. Confined spaces also may contain the potential for engulfment by particulate matter or by a liquid. Examples of such spaces include, but are not limited to: • tanks used for mixing, reacting, or • some ovens; storage; • vaults; • hoppers; • pits; • diked areas; • trenches; • crawl spaces; • sewers; • and ductwork. • silos; manholes; CONFINED SPACE ENTRY PROGRAM According to MN OSHA the definition of a confined space is a special configuration that could result in any of the following conditions: a. Atmospheric condition, a condition in which a dangerous air contamination, oxygen deficiency, or oxygen enrichment may exist or develop, b. Entry or exit access, a condition where the emergency removal of a suddenly disabled person is difficult due to the location or size of the access, or the opening, c. Engulfment condition, a condition where the risk of engulfment exists or could develop. 77
d. Some examples of confined spaces include: • Silos, • pipelines, on their • tanks, • ovens, some • vats, • crawl spaces, • vessels, • vaults, • bins, tubs, • pits, • boilers, • manholes, • compartments, • and depending • ducts, • sewers, configuration excavations. 5. There are four main hazards associated with working in a confined space. Under no circ*mstance will any employee enter a confined space with these or any other serious life- threatening hazards. a. Oxygen Rich/Deficient: Normal air is 21% oxygen by volume. The acceptable range of oxygen for a working environment is between 19.5% and 23.5%. Working in an environment where the % oxygen is outside of this range is extremely hazardous and can even be fatal. b. Combustible or Flammable Gases: Many gases are heavier than air and can potentially collect in the bottom of confined spaces. When exposed to a source of ignition, these gases can catch fire or even explode. Therefore, flammable gas concentrations should be less than 4% of the Lower Explosive Limit (LEL). c. Toxic Substances: There are numerous toxic substances that can be encountered within a confined space. Substances like Carbon Monoxide (CO) and Hydrogen Sulfide (HS), in certain amounts can be extremely hazardous to life and health. If the atmosphere in the confined space contains a substance over the OSHA Permissible Exposure Limit (PEL) then certain precautions must be taken prior to entering the confined space. d. Engulfment: The surrounding and effective capture of a person by finely divided particulate matter or liquid. GENERAL 1. Minger Construction Co., Inc. requires the Confined Space Entry Permit be followed and work performed according to Minger Construction Co., Inc. Confined Space Entry Policies and Procedures. 2. A Minger Construction Co., Inc. employee will supervise the confined space entry procedures. The person representing Minger Construction Co., Inc. as the entry supervisor shall be trained for the job, shall not have other duties while acting as the entry supervisor,
and shall remain at the point of entry for the duration of the entry unless an adequate replacement relieves him/her. 3. Each entry supervisor has overall responsibility for safe operations during the confined space entry. PERMIT VS. NON-PERMIT CONFINED SPACES 1. Non-permit Confined Space is a confined space that does not contain, or have the potential to contain, atmospheric hazards capable of causing death or serious physical harm. 2. Permit-Required Confined Space has one or more of the following: a. Contains or has the potential to contain dangerous air contamination (flammable, explosive, toxic, corrosive, or asphyxiates); b. Contains material that has the potential for engulfing the entrant; c. Has internal configuration such that an entrant could be trapped or asphyxiated by inwardly converting walls, or by a floor that slopes downward or tapers to a smaller cross section; d. Contains an oxygen rich or deficient atmosphere; e. Contains any other recognized serious safety or health hazards. f. Use Permit Required Confined Space Rescue Services Evaluation Form to determine rescue requirements. RESPONSIBILITIES 5. ENTRY SUPERVISOR a. The entry supervisor shall know and understand the unique hazards and exposure conditions associated with each confined space, and are aware of the effects of the exposure conditions. b. The entry supervisor shall ensure that the Confined Space Entry Permit is completed and signed before anyone enters a confined space. c. Terminate entry and cancel permit(s) when the operations are completed or if a new condition exists. d. The entry supervisor authorizes entry under normal and low exposure conditions, but shall obtain authorization from the owner of the facility or project site management when exposure conditions are more hazardous. The entry supervisor can also deny entry, terminate entry, remove unauthorized personnel, and cancel the permit at any point during the procedure. e. Before anyone enters a confined space, the entry supervisor shall ensure that lockout/tagout procedures have been followed. f. The entry supervisor shall ensure that pre-entry conditions are acceptable and that conditions do not deteriorate during the entry. g. The entry supervisor shall verify the means of rescue prior to the pending entry. 79
h. Based on the work being performed, the entry supervisor shall determine the maximum residence time for personnel in the confined space. i. The entry supervisor shall verify that each person who participates in any confined space entry has been trained. j. When a transfer of responsibility occurs during an entry, the new entry supervisor shall verify the entry conditions and initial the entry permit. During a shift change, the new entry supervisor shall complete a new permit. k. The entry supervisor shall have access to material safety data sheets (MSDS) or equivalent information for use by all confined space entry personnel, and shall furnish the information to medical facilities that treat any exposed or injured member of the entry team. l. The entry supervisor shall ensure that a point-of-entry attendant is properly stationed at each permit-required confined space for the duration of the entry. m. The entry supervisor will coordinate with other employers in the event multiple employers will be working in the confined space. This will ensure that employees of one employer do not endanger the employees of any other employer. 6. ATTENDANT AT THE POINT OF ENTRY a. The attendant at the point of entry shall participate in the process of verifying entry conditions, and shall sign the permit. b. A point-of-entry attendant shall serve for the duration of the permit. The attendant will not monitor more than one entry at a time. c. The attendant shall remain at his/her post and not leave for any reason, except self- preservation, unless replaced by an equally qualified individual while entry continues. d. Attendants shall know and understand the unique hazards and exposure conditions associated with each confined space, and are aware of the effects of the exposure conditions. e. The attendant shall maintain continuous communication with all entrants by voice, radio, telephone, visual observation, or any other equally effective means. f. The attendant shall monitor conditions inside and outside of the confined space and determine whether or not it is safe for the entrants to remain in the confined space. g. The attendant shall have the authority to order entrants to exit the space, and perform a non-entry rescue at the first indication of: i. Increased exposure condition. ii. Unexpected hazard/exposure condition. iii. Equipment malfunction. iv. Any unusual conduct by the entrants which could indicate a toxic reaction. v. Situations occurring outside the confined space that could pose a hazard to the entrants. 80
h. The attendant shall know the procedure and have the means to summon immediate emergency assistance. i. The attendant shall keep all personnel not listed on the permit out of the area designated for confined space entry. j. Before anyone enters a confined space, the attendant shall ensure that the lockout/tagout procedures have been followed. 7. ENTRANT a. Entrants shall read and sign the entry permit, state their understanding of the unique hazards and exposure conditions in the confined space to the entry supervisor, and be aware of the effects of the exposure conditions. b. The entrant shall maintain continuous communication with the attendant at the point of entry by voice, radio, telephone, visual observation, or any other equally effective means. c. Entrants shall know how to properly use all entry equipment necessary to conduct the confined space entry operation. d. The entrant shall exit the confined space immediately when the: i. Point-of-Entry Attendant orders evacuation, or ii. Entry supervisor orders evacuation, or iii. Entrant perceives warning signs or symptoms due to exposure. 8. PROCEDURES a. Normal Exposure Conditions: (Oxygen 19.5%-23%; and flammable or toxic substances are not detected). i. Determination of entry - Every effort must be made to avoid the need to enter a confined space. ii. Equipment shutdown (lockout/tagout) - Supervisor determination based on the entrant’s potential exposure to hazards. If an area is protected by a CO2 system, the system must be locked out for both automatic and manual operation. Equipment that generates vapors in the room that may pose a potential hazard to the entrant will be shut down. iii. Entry permit - A Confined Space Entry Permit will be completed by the employee authorizing the confined space entry. Completion of the checklist will confirm that the confined space is safe for entry. iv. Communication - Constant communication is required between entrant and attendant at the point of entry. v. Air ventilating - Provide at least four air changes in the confined space prior to entry. Ventilation will continue in the confined space until work is complete and the employee exists 81
vi. Atmospheric monitoring - In order: (1) Oxygen level, (2) combustible gases and vapors (pay special attention to \"pocket\" areas), (3) toxic gases and vapors. Continuous monitoring will be maintained throughout the entry. vii. Oxygen level 19.5% - 23% viii. Flammable vapors < 4% LEL ix. Toxic liquids or gas direct reading toxic gas/vapor analyzer (Draeger pump or TLV sniffer) x. The monitoring data will be shared with all affected employees and additional monitoring may be requested at any time. xi. Temperature check - If the dry-bulb temperature is greater than 90 degrees, an Industrial Hygienist should be contacted. xii. Lockout/Tagout - Mechanical, process equip., electrical, pneumatic, gravity, etc. xiii. Guards and barriers - Guards and/or barriers will be provided to protect entrant and attendant from local traffic. Also, to protect non-entrant employee(s) from hazards in the confined space. xiv. Lighting - Adequate lighting will be provided for the type of work being performed. Emergency lighting should be available in case of a power failure. xv. Spark and heat producing operations - Welding, cutting, grinding, etc. are not permitted in a confined space in the normal exposure category. These operations change the confined space into Low Hazard Exposure. xvi. Hoisting equipment - Entrant is required to wear a safety harness attached to a manual means of retrieval. The hoisting equipment will be approved for hoisting people and will include a ratchet or brake to ensure against dropping persons during entry or rescue. If the descent is greater than 12 feet, the entrant must also be attached to a fall arrestor. xvii. Respiratory protection - Air supplied respirators are not required for confined spaces with a normal exposure hazard. xviii. Entry equipment - Will be inspected prior to use. The attendant will be equipped with a device for immediately summon an Emergency Rescue Squad. b. Low Hazard Exposure Conditions: (Oxygen 19.5% - 20.4%; or flammable vapor concentration greater than zero but equal to or less than 4% LEL; or toxic substances concentration below the TLV). All of the procedures listed for Normal Exposure conditions apply, exceptions: i. Respiratory protection - The minimum required respiratory protection is a pressure demand or continuous flow respirator (escape air pack is not required) or a pressure demand SCBA. 82
ii. Spark and/or heat producing operations - Welding, torch cutting and grinding are permitted under this category. c. Severe Hazard Exposure Conditions: (Oxygen less than 19.5%; or flammable vapor concentration greater than 4% but less than or equal to 20% of the LEL; or toxic substances may be present in concentrations above the TLV). All of the procedures for Normal Exposure conditions apply, with the following exceptions: i. Respiratory protection - Pressure demand or continuous flow air-supplied respirator (with a five-minute escape pack), or SCBA. ii. Spark and/or heat producing operations - Welding, torch cutting, and grinding are not permitted under this category. iii. Revival ability will be immediately available. d. Immediately Dangerous to Life and Health (IDLH): (Flammable vapor concentration is greater than 20% and less than or equal to 50% of the LEL). All the procedures listed for Normal Exposure conditions apply, with the exception of the following: i. This type of entry will be used only as a last resort after all attempt to reduce the hazard have failed. ii. Welding, etc. is not permitted. 9. EDUCATION AND TRAINING a. All entry teams shall be trained in confined space entry, permit required and non- permit required, according to this standard. Training will be completed prior to initial assignment, prior to a change in assigned duties, if a new hazard has been created, or special deviations have occurred. All entry personnel shall be taught how to complete the checklist on the entry. 10. DOCUMENTATION a. The successful completion of training for all entry shall be documented and filed. Training certification will be made available to employees and their authorized representatives. The certification will include the employee’s name, trainer signature, and dates of training. 11. HAZARD EXPOSURE/CONDITION RECOGNITION ATMOSPHERIC a. All entry personnel shall be taught that even though human senses may be unable to detect an exposure condition, breathing the atmosphere could be fatal. Only proper testing can be relied on to determine that the atmosphere is breathable. 12. LOCK-OUT/TAG-OUT a. All entry and rescue personnel shall be trained in lock-out/tag-out procedures. 83
13. IMPROPER ENTRANCE a. Attendants shall receive training regarding the importance of not entering a confined space unless they are properly equipped and relieved of their duties by another qualified attendant. Attendants who make improper entries into confined spaces will very likely fall victim to the associated hazards. 14. ATMOSHPERIC TESTING a. Pre-entry testing of confined space atmospheres shall be explained to all entry and rescue personnel. CAUTION: In atmospheres containing liquids, gases, or vapors from flammable or combustible liquids above the upper flammability limit (UFL), a %LFL (lower flammability limit) meter may momentarily read full scale and then return to zero which is a false low reading. In that case, re-calibrate the instrument in a clean air environment. 15. OXYGEN-ENRICHED ENVIORNMENT a. All entry personnel shall be trained in the hazards associated with working in an oxygen-enriched environment. Enriched oxygen levels present serious safety hazards because an entrant’s clothing and hair may become extremely flammable due to excess oxygen, and absorbed oxygen desorbs slowly. 16. RESPIRATORY PROTECTIVE EQUIPMENT a. All entry personnel shall be trained and certified in the use of respiratory protective equipment in accordance with OSHA 1910.134. 17. PERSONAL PROTECTIVE EQUIPMENT a. All entry personnel shall be trained and certified in the proper use of all applicable personal protective equipment (PPE) for eyes, face, head, feet, hands, body and extremity protection. 18. PHYSICAL PROTECTIVE EQUIPMENT a. All entry personnel shall be trained and certified in the proper use of harnesses, hoists, fall arrestors, ropes/lanyards, and rigging. 19. PURGING AND VENTILATION a. All entry personnel shall be trained to ensure that the confined space has been adequately purged prior to entry, and that adequate ventilation is maintained. 84
20. COMMUNICATION EQUIPMENT a. All entry personnel shall be trained in the proper use of the communications equipment for people in a confined space, and communications equipment for summoning the rescue team. 21. EVACUATION OF A CONFINED SPACE a. All entry personnel shall be taught the importance of immediate evacuation to a non-hazardous atmosphere to prevent serious or permanent injury. In order to minimize or prevent injury to themselves, they shall leave the confined space/area for a safe atmosphere immediately on being ordered to do so, or when they recognize any sign of reaction to an exposure condition. Training should address hazards inside and outside the confined space. 22. RESCUE AND EMERGENCY SERVICES a. On jobsites where confined space rescue becomes a possibility, a rescue plan will be developed for each type of permit required confined space. b. Whenever possible, the plan will specify rescue methods that do not require entry by rescuers into the confined space. c. The attendant and/or entry supervisor is responsible for preventing unauthorized persons from attempting a rescue in a confined space. d. It will be determined at each jobsite location whether Minger Construction Co., Inc. will make arrangements with the client and/or an outside rescue team (i.e. Fire Department). e. Outside services will be given the opportunity to examine the entry site, practice rescue, and decline service if appropriate. If these services are accepted, it will be stated and agreed to in the language of the contract. PROGRAM REVIEW 1. The confined space entry program will be reviewed annually if any entry is made during the prior 12-month period. Necessary revision will be made to protect workers from the hazards of confined space entry. 2. In the event the operations are determined to not adequately protect workers from the entry hazards, the program will be reviewed and revised prior to any subsequent entries. 3. Possible triggers for program review include but are not limited to: a. Entrance by an unauthorized person b. A hazard not covered by the permit c. The occurrence of an incident or Near Miss d. Employee complaints 4. Canceled entry permits will be kept for 12 months and made available for review to aid in problem identification. 85
CONFINED SPACE ENTRY PROGRAM MINNESOTA RULES 5207.0301 OVERVIEW Confined spaces require special precautions when entering, exiting and working in an enclosed area. A confined space is defined a s a space large enough and so configured that an employee can bodily enter and perform assigned work. 1. Definition of a Confined Space A confined space has limited or restricted means for entry or exit and could result in one or more of the following characteristics. Contains or has a potential to contain a dangerous air contamination, an oxygen deficiency, or an oxygen enrichment environment. Contains a material that has the potential for engulfing or asphyxiating any entrant; or contains any other recognized serious safety or health hazard. Examples of a confined space are; sewers, vessels, storage bins, trenches, ducts, silos, hoppers, compartments, pits, pipelines, and vaults. 2. Hazards Some confined spaces can be extremely hazardous if they have one or more of the following conditions: a. It contains or has the potential to contain a hazardous atmosphere. b. Oxygen deficiency (less than 19.5%) c. Toxic atmosphere (poisonous gases, vapors, or fumes) d. Flammable or explosive atmospheres (flammable gases, vapors, dusts, concentrated enough to ignite/combust) e. It has an internal configuration that could trap or asphyxiate an entrant by inwardly converging wall or by a floor that slope downward and tapers to a smaller cross- section. f. Safe air limits for confined space entry: i. Oxygen: Between 19.5% and 23.5% ii. LEL: Less than 10% of known LEL (LEL = Lower Explosive Limit) iii. H2S: Less than 10 ppm iv. CO: Less than 35 ppm (general industry): 50 PPM (construction) 3. Confined Space Classification a. Class 1 Confined Space: a space where an atmosphere with dangerous air contamination, oxygen deficiency, or oxygen enrichment is unlikely to develop. Example; Low level hazard such as a worker performing routine entry into low hazard chambers such as boilers, vaults, vessels, tanks, bins, and vats, where no risk 86
of engulfment can exist, and where the atmosphere cannot develop a dangerous air contaminant or oxygen enrichment, and where all known sources of hazards are positively controlled. b. Class 2 Confined Space: a space where an atmosphere free of dangerous air contamination, oxygen deficiency, or oxygen enrichment has been verified. c. Class 3 Confined Space: a space where an atmosphere free of dangerous air contamination, oxygen deficiency, or oxygen enrichment cannot be verified. 4. Emergency Situations NEVER ENTER A CONFINED SPACE TO ATTEMPT RESCUE of an unconscious or unresponsive person. In case of an emergency, the attendant must immediately call 911 to request emergency assistance. Make sure to tell emergency services that a “potentially hazardous confined space environment is involved. 87
SECTION 15 HOT WORK, WELDING & CUTTING PROGRAM 88
SECTION 15: HOT WORK, WELIDNG & CUTTING PROGRAM 29 CFR 1926 Subpart J GENERAL Pre- planning must be conducted with the appropriate permitting and procedures in place to assure all possible exposures are addressed. Before welding, cutting, or hot work is permitted the area will be inspected by the responsible Supervisor and precautions followed with a written permit. RISK OF FIRE The most prevalent hazard in cutting, welding, grinding, brazing, soldering and thawing operations is that of sparks setting fire to combustible materials in the vicinity of the work activity. When such operations are conducted, all combustible materials within 35 feet must be removed / relocated or protected or shielded from hazards with flame-proof covers. 1. A permit may be required in specific areas. 2. Monitor area with L.F.L (Lower Flammable Limit) analyzer. 3. A suitable fire extinguisher must be located within 20 feet of the hot work operation. 4. During all welding operations, Precautions must also be taken for the falling slag. (i.e. watering down the area, fire watch, housekeeping, etc.) 5. Fire Watch / Hot Work Area Monitoring: a. A fire watch must be maintained at the hot work sites until 30 minutes after all hot work is finished including any coffee or lunch breaks or as deemed necessary by Minger Construction Co., Inc. b. Fire watch is supplied with an extinguisher. c. Fire watch is trained in use of this equipment and familiar with location of sounding alarm. d. Fire watch may be required for opposite side of walls, above, and below floors and ceilings. 6. Ventilation: a. Due to the harmful gases and fumes given off during welding operations, adequate ventilation is critical. If local ventilation is not sufficient, forced ventilation must be used. b. Hot work performed in confined spaces introduces various hazards precautions such as ventilation issues, securing cylinders, lifelines, electrode removal, gas cylinder shutoff, and warning signs must be addressed. Consult with the safety director prior to cutting or welding in any confined spaces. 89
c. Any welding, cutting, or burning of lead-based metals, zinc, cadmium, mercury, beryllium, exotic metals, or paints requires proper ventilation and/or adequate respiratory protection. GAS WELDING AND CUTTING OPERATIONS 1. All personnel will be trained in the safe operation and safe use of processes before using gas welding or cutting operations. 2. Hoses used must be: a. Red for the acetylene hose b. Green or black for the oxygen hose 3. When used, hoses and torches must be inspected daily for worn spots or defective connections. All defective equipment must be tagged and removed from service. 4. Proper procedures must be used when lighting or extinguishing the torch set-up. 5. Only approved friction or spark type lighter may be used. 6. Acetylene may never be used at more than 15 pounds per square inch gauge pressure, or 30 pounds per square inch absolute pressure. 7. Each cylinder must be equipped with a back-flow check valve. 8. To secure the equipment when not in use: a. The torch must be extinguished. b. Both acetylene and oxygen cylinder valves must be closed, and hoses cracked open one at a time momentarily to allow the line to discharge. c. No cylinders may be stored or used in the horizontal position. In the horizontal position, the safety valve does not allow the excess gas to escape, but does allow the liquid to escape; this can result in an explosion. ARC WELDING 1. Welding equipment must be maintained in good operating condition. 2. Cables must be kept dry and free of oil. 3. Only electrode holders that are fully insulated and in good condition may be used. 4. Before starting operations, the operator must make certain that all electrical connections are securely made. a. The ground connection must be attached firmly to the work, not merely laid loosely upon it. b. Ground connections must never be made through pipelines carrying gases or flammable liquids. 5. Inspect cables for worn spots or exposed bare conductors. If such conditions are found, cover with rubber and friction tape. 6. Protect cables that must be laid on the floor. When possible, suspend cables at least 8 feet or higher. 7. Keep cables away from power supply cables, or high-tension wires. 90
8. Cables must be placed so that falling sparks will not come in contact with them. 9. When other employees are in the vicinity of electrical welding operations, the operations must be screened so that the employees cannot see the arc. 10. Fire Protection: a. All cables, hoses, cylinders, and welding machines must be located away from sources of ignition, including falling slag and sparks. b. All combustible materials must be removed or protected from the hot work area before starting work c. A fire watch must be established if the sparks fall below the floor where the welder is working. d. Cover or shield all duct, walls and floor opening with flame-proof covers. e. Cover floor drains, trenches, manholes and sewers f. If the object being welded or cut cannot be moved and if all the fire hazards cannot be removed, then guards shall be used to confine the heat, sparks, and slag and to protect the immovable fire hazards. g. If fire hazards cannot be taken to a safe place or guards cannot be used to confine heat, sparks, slag and protect the immovable fire hazards, the welding and cutting shall not be performed. h. Monitor sewers, trenches, manholes, floor drains, elevator pits, sumps and low areas with a L.F.L analyzer. i. A fire watch must be maintained for 30 minutes after all hot work operations end, or as deemed necessary by Minger Construction Co., Inc. COMPRESSED GAS CYLINDERS Transferring compressed gases from a large to a small cylinder is not recommended, unless the proper set-up is used, and the personnel have received the proper training. 1. If a cylinder is leaking and cannot be easily fixed: a. Evacuate the building. Guard all entrances. b. Add ventilation to the area to try to clear out the escaping gas. (Open doors, etc.) c. Shut down all sources of ignition. d. Contact the gas supplier. e. Call 911. f. Follow the supplier’s instructions regarding the return of the cylinder. 2. The gas supplier must be contacted if a cylinder: a. Has been exposed to a fire. b. Is leaking. c. Might contain a makeup other than that marked on the cylinder. 3. Each cylinder must bear the proper DOT label required for the compressed gas contained. 4. Labels, decals, tags, and stencil marks used for identification of cylinder contents must not be defaced. 91
5. Empty cylinders must have their caps secured and be marked \"empty\". 6. Do not place cylinders where they might become part of an electrical circuit. 7. Never attempt to repair or to alter cylinders, valves, or safety relief devices. 8. Never use cylinders for any purpose except to contain the product as it was received. 9. MOVING CYLINDERS: a. Only a competent trained person will be assigned to work with LPG. b. The caps must be secured. c. Never drop cylinders, or permit them to bump violently against each other, or against other surfaces. d. Never handle a cylinder with a lifting magnet. e. Only lift cylinders in a proper lifting rig unless the cylinder is equipped with the proper lifting attachment. f. Avoid dragging or sliding cylinders. g. When transporting and unloading cylinders, always use a suitable hand truck, fork truck, or similar device, with cylinder firmly secured. 10. STORING CYLINDERS: a. Cylinders must be stored in accordance with all legal regulations, local requirements, and appropriate standards of the Compressed Gas Association and the National Fire Protection Association. b. Cylinder storage areas must be prominently posted with the gases to be stored. c. All cylinders must be secured upright by means of dependable strength. d. Charged and empty cylinders must be stored separately. e. Cylinders may not be stored: i. Where the temperature is above 125 degrees Fahrenheit. ii. Near sources of heat. iii. Do not store cylinders near highly flammable substances, such as gasoline, oil, or waste. iv. Cylinders may not be stored in areas of continuous dampness, or near salt or other corrosive chemicals or fumes. v. If ice or snow accumulates on a cylinder, thaw at room temperature. vi. Where gases of different types are stored at the same location, cylinders must be grouped by types of gas. Note: Oxygen must be separated from fuel gases by a minimum of 20 feet or a half hour rated wall at least five feet high. 11. WITHDRAWING CYLINDER CONTENTS: a. Compressed gases may only be handled by properly trained employees. b. Check all cylinders to ensure that they are marked with the identity of the gas. If they are not, do not accept the cylinders. c. All cylinders must be secured during use. d. Never force a connection that does not fit. 92
e. Open cylinder valve slowly. Note: On cylinders that are hard to open or frozen due to corrosion, contact the supplier for instructions. f. Never use compressed gas to dust off clothing. g. Where compressed gas cylinders are connected to a manifold, the manifold and all related equipment must be of proper design. 12. MAINTENANCE a. Any equipment defect or safety hazard will be reported by operators and discontinue use of equipment until safety has been assured. Only qualified maintenance personnel will perform repairs on this equipment. b. All workmen assigned to operate or maintain the equipment will be familiar with the applicable industry standards including OSHA standards and the American Welding Society Standards. 13. TRAINING a. All employees who are exposed to compressed gases or arc welding must be informed of: i. Its contents, ii. proper use, & iii. the hazards associated with them. b. All employees who use compressed gasses must be instructed as to all proper procedures in using compressed gases. c. All employees who arc weld must be trained in: i. The proper procedures in using arc welding equipment. ii. The hazards associated with it. 14. First Aid equipment shall be available at all times and one employee in the work area will be trained in basic first aid. WELDING AND CUTTING OPERATIONS 1. Welding, cutting and heating performed in confined spaces may require general mechanical or local exhaust ventilation to reduce the concentrations of smoke and fumes. Check with the safety director prior to cutting or welding in any confined spaces. 2. If local exhaust ventilation cannot be provided, employees must be provided with and required to use, air supplied breathing apparatus. This requires input of the safety director. 3. When heated, some metals have a potential for releasing toxic fumes. Metals such as zinc, lead, cadmium and chromium – bearing metals require additional respiratory protection. Consult the safety director prior to working with any of these metals. 4. Pure oxygen, such as bottled or line fed, must never be used for ventilation. 5. Before starting to cut or weld, you must inspect your work area to ensure that sparks or molten metal won’t fall on combustible materials. If you cannot provide the necessary safeguards, check with the safety department. 93
6. You must make certain that a suitable fire extinguisher is available in your work area prior to starting the torch. 7. When cutting or welding, you must wear approved eye protection, with suitable filter lenses. 8. Keep all welding leads and cutting hoses off floors, walkways, and stairways. You are responsible for seeing that your equipment complies with safe practices at all times. 9. Never weld on barrels, tanks, piping or other enclosed systems, which may contain or have contained combustible products. Contact the safety department prior to any work on an enclosed vessel or pipe system. 10. Workers in charge of oxygen or fuel-gas supply equipment will be instructed and declared competent. ARC WELDING 1. If your eyes are exposed to flying objects from chipping slag or grinding welds, you must wear approved eye protection. 2. When you arc-weld near other workers, they must be protected from the arc strikes by non- combustible screens or they must wear adequate eye protection. 3. The frames of all welding machines must be grounded. 4. Workers assigned to operate arc welding equipment will be properly trained and qualified to operate such equipment. GAS CUTTING AND BRAZING 1. Before using compressed gas cylinders, the cylinder valves shall be “cracked” to dislodge any dirt or debris prior to connecting gauges. 2. The cylinder valves shall be opened slowly to prevent damage to the gauges. Always stand to the side of the outlet, not in front of it. 3. For quick closing, the fuel gas cylinder shall not be opened more than 11/2 turns. If a special wrench is required, is shall be left in place on the valve stem for quick shutoff in the event of an emergency. 4. Torches shall be ignited by flint strikers or other approved devices. Matches or butane lighters are prohibited. Do not use torches to light smoking materials. 5. Torches or hoses shall be equipped with flashback arrestors. 6. The cylinder valve shall be closed and hoses bled-off before removing gauges. 7. Valves with leaks shall be removed from service immediately. 8. Unless the cylinders are firmly secured on a special carrier intended for this purpose, gauges shall be removed and valve protection caps put in place before transporting the cylinders. STORAGE AND HANDLING OF CYLINDERS 1. The protective caps must be kept in place on all cylinders not in actual use. 2. All cylinders must be upright and secured to prevent tipping. 94
3. Oxygen and acetylene (or other fuel gas) cylinders in storage must be separated by either twenty feet (20’) or by a five-foot (5’) barrier, which has a one-hour fire rating. 4. Cylinders must not be taken into confined spaces. 5. Cylinders shall not be hoisted or lifted by regulator valves or caps. A cylinder rack shall be used to hoist cylinders. They shall not be transported by magnetic devices or choker slings. 95
SECTION 16 HEAVY EQUIPMENT PROGRAM 96
SECTION 16: HEAVY EQUIPMENT PROGRAM Mobile earthmoving equipment includes the following: • Bulldozers • Loaders • Boom trucks • Self-propelled • Skid-steer loaders • Side dumps compactors • Motor graders • Dump trucks • Backhoes • Track loaders • End dumps • Off-road trucks OPERATING PROCEDURES Only qualified and properly trained personnel are designated to operate heavy construction equipment for which they have been trained. All Minger ground personnel are to be kept clear of mobile earth moving equipment or parts of that equipment without first making visual, voice, or signal communication with the operator. A safe distance of 25 feet must be maintained between ground personnel and the pieces of equipment when possible. If this is not possible due to the work zone limits, visual and or radio contact must be maintained between the operator and the ground personnel. PROCEDURES TO APPROACH A PIECE OF EQUIPMENT 1. Do not enter the danger zone (25-foot radius) of a piece of equipment without first making eye contact with the machine operator. Never approach a piece of equipment from behind or in the blind spots. 2. Use the Minger approved hand signals (see attached list) to signal your intention. Use a mobile radio if there is one on the site to communicate with the operator. 3. If an employee or worker must approach a piece of equipment the operator must place the blade or bucket on the ground. The operator will signal to the employee to come forward. The machine must be placed in neutral and the parking brake set. 4. The employee walking towards the piece of equipment must maintain eye contact with the operator and machine. 5. All project personnel must wear a high visibility class II garment at all times as stated in the PPE policy for Minger Construction Co., Inc. 6. The backup warning device on the machines must be operational at all times. 7. Equipment must be equipped with manufacturer’s specified lighting if used in periods of darkness and low light conditions. 97
GENERAL 1. Before any machinery is placed in use, it shall be inspected and tested on a daily basis by a competent person and certified to be in safe operating condition. 2. Whenever any machinery is found to be unsafe, or whenever a deficiency, which affects the safe operation of equipment, is observed, the equipment shall be immediately taken out of service and its use prohibited until unsafe conditions have been corrected. 3. Designated qualified personnel shall operate machinery and equipment. 4. Getting on or off the equipment while it is in motion is prohibited. 5. The use of head phones, cell phones, for entertainment purposes is prohibited. 6. Seats must be provided for each person required to ride on the equipment. NO RIDERS! 7. Mobile equipment shall have a service brake system and a parking brake system capable of stopping and holding the equipment while fully loaded on the grade of operation. 8. All machinery or equipment shall be shut down and positive means taken to prevent its operation while repairs or manual lubrications are being done. Equipment designed to be serviced while running are exempt from this requirement. 9. Heavy machinery, equipment, or parts thereof which are suspended or held apart by slings, hoist, jacks also shall be substantially blocked or cribbed before personnel are permitted to work underneath or between them. 10. Personnel shall not work or pass under or ride in the buckets or booms of loaders in operation. 11. All self-propelled construction equipment shall be equipped with a reverse signal alarm. The alarm must be audible and sufficiently distinct to be heard under prevailing conditions. Alarms shall be continuous during the backward movement. 12. A signal person shall be used where there is danger to persons from moving equipment, swinging loads, buckets, booms, etc. 13. Seatbelts are mandatory for use in all heavy equipment. 14. All bulldozers, tractors, or similar equipment used in clearing operations shall be provided with Falling Object Protective Structures (FOPS) to protect the operator from falling and flying objects. 15. Roll Over Protection Structures (ROPS) are required on all self-propelled construction equipment. OPERATING EQUIPMENT SAFELY Minger requires the following safe operating procedures for all pieces of equipment: 1. Operate the equipment from the operator's compartment—never from the outside. 2. Stay seated when operating the equipment controls. 3. Work with the seat belt fastened and the restraint bar in place. 4. Keep your arms, legs, and head inside the cab while operating the equipment. 5. When possible, plan to load, unload, and turn on level ground. 6. For maximum stability, travel and turn with the bucket in the lowest position possible. 98
7. Never exceed the manufacturer's recommended load capacity for the machine. 8. Operate on stable surfaces only. 9. Avoid traveling across slopes; travel straight up or down with the heavy end of the machine pointed uphill. 10. Always face the direction of travel. 11. Keep bystanders away from the work area. 12. NEVER modify or bypass safety devices. EQUIPMENT INSPECTIONS Pre-operational inspections shall include the following: 1. Pre-Operational Site Inspection: A site inspection to locate site features (i.e. overhead power lines, underground utilities are located and marked, etc.) and other site activities that may pose a hazard during operation. 2. Pre-Operational Daily Inspection: A walk around the exterior of the equipment inspecting for any deficiencies on the equipment (i.e. mirrors, brake lights, headlights, reverse alarm, leaks in hydraulics or motor, belts, tires, tracks, attachment points, attachments, glass etc.). 3. Pre-Startup Inspection (in the cab): Check the necessary paperwork, labeling of all switches and controls, and working order of all lights, braking systems, electronic equipment, and hydraulic systems. 4. If defects or problems are encountered during the pre-operational inspection, that piece of equipment will be tagged out of service, until such defects are repaired. Defects on any equipment, machinery, and tools that affect safety shall be correct in a timely manner to prevent the creation of a hazard to persons. Repairs or maintenance of machinery or equipment shall be performed only after the power is off, and the machinery or equipment blocked against hazardous motion. Machinery or equipment motion or activation is permitted to the extent that adjustments or testing cannot be performed without motion or activation, provided that persons are effectively protected from hazardous motion. 99
ENTERING AND EXITING EQUIPMENT SAFELY 1. Enter only when the bucket or other attachment is flat on the ground—or when the lift-arm supports are in place. Use supports supplied or recommended by the manufacturer. 2. When entering the equipment, face the seat and keep a three-point contact with handholds and steps. 3. Never use foot or hand controls for steps or handholds. 4. Keep all walking and working surfaces clean and clear of debris. 5. Before leaving the operator's seat, a. lower the bucket or other attachment flat to the ground, b. set the parking brake, and c. turn off the engine. 6. If you are unable to exit through the front of the machine, use the emergency exit through the roof or across the back. MAINTAINING EQUIPMENT IN SAFE OPERATING CONDITION 1. Follow the manufacturer's instructions for maintaining the loader. 2. Keep the foot controls and the operator's compartment free of mud, ice, snow, and debris. 3. Before servicing the loader, a. set the parking brake, b. lower the bucket or other attachment flat to the ground, c. turn off the engine, and d. remove the key from the switch. 4. If the machine cannot be serviced with the bucket on the ground, use the lift arm supports recommended or provided by the manufacturer. If the machine is not equipped with lift arm supports, contact the equipment dealer or manufacturer's representative for help in selecting proper supports. 5. Never work on the machine with the engine running unless directed to do so by the operator's manual. Follow the manufacturer's safety recommendations to complete the task. If the adjustments require that the engine be in operation, use two persons to perform the task. PERSONAL PROTECTIVE EQUIPMENT All Minger employees who are entering the work area where mobile equipment is being used will be provided and required to wear a Class II or Class III high-visibility safety vest. 100
