Minger Construction_SAFETY MANUAL and APPENDIX_2022

6. Identify Safety Monitor. b. Control Line Specifications 1. Use ropes, tape or equivalent material. 2. Each line must be flagged with visible material at six (6) foot intervals. 3. Each line must be rigged and supported so at no point does line sag closer than 39 inches from top of work surface or higher than 45 inches from top of work surface. 4. Each line must have a minimum breaking strength of 200 pounds. c. CAZ Specifications for type of work to be performed Overhand Bricklaying 1. CAZ must be defined by placing the Control Line not less than 10 feet nor more than 15 feet from the working edge 2. Control Lines must enclose all employees performing overhand bricklaying. 3. Control Lines must be as parallel as possible to the working edge. 4. Any employee who must reach below the working edge more than 10 inches must use personal fall arrest equipment. 5. Do not remove existing guardrail systems until it is necessary to progress the work. 6. Only remove as much existing guardrail as block can be installed in one (1) work shift. d. Leading Edge Work 1. CAZ must be defined by placing the Control Line not less than six (6) feet or more than 25 feet from the unprotected or leading edge. 2. The control line must extend along the entire length of the unprotected or leading edge. 3. The control line must be as parallel as possible to the unprotected or leading edge. 4. The control line must be connected to each side to a guardrail system or wall. e. Precast Concrete Erection 1. CAZ must be defined by placing the Control Line not less than six (6) feet or more than 60 feet or half the length that the member being erected, whichever less, from the leading edge is. 2. The control line must extend along the entire length of the unprotected or leading edge. 3. The control line must be as parallel as possible to the unprotected or leading edge 4. The control line must be connected to each side to a guardrail system or wall. 201

SUMMARY OSHA’s REVISED STANDARDS ON FALL PROECTION - SUBPART M DUTY TO HAVE FALL PROTECTION 1. Employers must determine whether walking/working surfaces are structurally capable of supporting workers safely. 2. Workers on walking/working surfaces with unprotected sides or edges six feet or higher above a lower level must be protected from falling by the use of guardrails, nets or fall arrest systems. 3. Workers constructing or working near leading edges at six feet or higher above a lower level must be protected from falls by guardrails, nets or fall arrest systems. 4. Workers in hoist areas must be protected from falling more than six feet by guardrails or personal fall arrest systems. 5. Workers must be protected from falling more than six feet through holes (including skylights) by hole covers, guardrails or personal fall arrest systems. 6. Workers on the face of formwork or reinforcing steel must be protected from falling six feet or more by personal fall arrest systems, nets or positioning devices. 7. Workers on the edge of excavations deeper than six feet must be protected from falling by guardrails, fences or barricades when excavations are not easily visible. 8. Workers less than six feet above dangerous equipment must be protected from falling into or onto the equipment by guardrails or equipment guards. 9. Workers six feet or higher above dangerous equipment must be protected from fall hazards by guardrails, personal fall arrest systems or nets. 10. Workers near wall openings six feet or higher above lower levels and less than 39 inches above the walking/working surface must be protected from falling by guardrails, nets or personal fall arrest systems. 11. Workers on walking/working surfaces six feet or higher above lower levels which are not otherwise addressed must be protected from falling by guardrails, nets or personal fall arrest systems. 12. Where workers are exposed to falling objects, the employer must have each worker wear a hard hat and must: a. Erect toe boards, screens or guardrails to prevent objects from falling, b. Erect a canopy structure and keep objects away from the edge of the higher level, or c. Barricade the area to which objects could fall and keep objects away from the edge of the higher level. 202

FALL PROTECTION SYSTEMS CRIETERIA AND PRACTICES 1. The top edge of guardrails must be between 39 inches and 45 inches high. 2. Midrails, screen, mesh or intermediate vertical members must be installed between the top edge of the guardrail and the walking/working surface when there is no wall or parapet wall at least 21 inches high. 3. Guardrails must be capable of withstanding a force of at least 200 pounds applied within two inches of the top edge in any outward or downward direction. 4. With 200 pounds of downward force the top edge of the guardrail must not deflect to less than 39 inches. 5. Midrails, screens, mesh and intermediate vertical members must be capable of withstanding a force of at least 150 pounds applied in any downward or outward direction at any point along the midrail or other member. 6. Guardrail must be surfaced in a way that will prevent punctures, lacerations and snags. 7. The ends of top rails and mid rails must not overhang terminal posts unless an overhang would not create a projection hazard. 8. Steel and plastic banding must not be used on top and mid rails. 9. Top and mid rails must be at least one-quarter inch nominal diameter or thickness. 10. When guardrail is used in hoisting areas, a chain, gate or removable guardrail section must be placed across access opening when hoisting operations are not taking place. 11. When guardrails are used at holes they must be erected on all unprotected sides or edges. 12. When guardrails are used to protect holes, which are used for passage of materials not more than two sides, can be protected by removable guardrail. 13. Safety nets must be installed as close as possible, but not more than 30 feet below the walking/working surface. 14. Safety nets must extend outward from the outermost projection of the work surface (see regulations for distances). 15. Drop tests must be performed on safety nets by dropping a 400 pound 30-32 inch diameter bag of sand into the net from the highest walking/working surface (but not less than 42 inches). 16. When it is unreasonable to perform a drop test on a net, the employer or a designated competent person must certify that the net and net installation is in compliance with this standard. 17. Nets must be inspected at least once a week and defective nets and parts must be removed from service. 18. Effective January 1, 1998, body belts are not acceptable as part of a fall arrest system. Lanyards and vertical lifelines must have a minimum breaking strength of 5,000 pounds. 19. Personal fall arrest systems when stopping a fall must limit the maximum arresting force on the worker to 1,800 pounds when used with a body harness. 20. Personal fall arrest systems must be rigged so that the worker can neither fall more than six feet nor contact any lower level. 203

21. Positioning devices must be rigged to prevent free falls more than two feet. 22. Warning lines must be erected around all sides of a roof work area. 23. Controlled access zones must be defined by a control line or other means that restricts access. 24. When using safety monitoring systems, a competent person must be used to monitor the safety of the workers. 25. Fall protection equipment must meet ANSI & ASTM Requirements. 26. The employer must provide training for each worker that may be exposed to fall hazards. 27. The employer must keep a written certification record to verify compliance with training requirements. 28. The employer must provide retraining when workers do not have the understanding and skills required by initial training. 29. Accident investigations shall be conducted to evaluate the fall protection plan for potential updates to practices, procedures, or training in order to prevent reoccurrence. Rescue 30. Employer shall provide for prompt rescue of employees in the event of a fall or assure they are able to rescue themselves. TRAINING PROGRAM 1. 1926.503(a)(1) The employer shall provide a training program for each employee who might be exposed to fall hazards. The program shall enable each employee to recognize the hazards of falling and shall train each employee in the procedures to be followed in order to minimize these hazards. 2. 1926.503(a)(2) The employer shall assure that each employee has been trained, as necessary, by a competent person qualified in the following areas: 3. 1926.503(a)(2)(i) The nature of fall hazards in the work area; 4. 1926.503(a)(2)(ii) The correct procedures for erecting, maintaining, disassembling, and inspecting the fall protection systems to be used; 5. 1926.503(a)(2)(iii) The use and operation of guardrail systems, personal fall arrest systems, safety net systems, warning line systems, safety monitoring systems, controlled access zones, and other protection to be used; 6. 1926.503(a)(2)(iv) The role of each employee in the safety monitoring system when this system is used; 7. 1926.503(a)(2)(v) The limitations on the use of mechanical equipment during the performance of roofing work on low-sloped roofs; 8. 1926.503(a)(2)(vi) The correct procedures for the handling and storage of equipment and materials and the erection of overhead protection; and 9. 1926.503(a)(2)(vii) The role of employees in fall protection plans; 10. 1926.503(a)(2)(viii) The standards contained in this subpart. CERTIFICATION OF TRAINING 1. 1926.503(b)(1) The employer shall verify compliance with paragraph (a) of this section by preparing a written certification record. The written certification record shall contain the name or other identity of the employee trained, the date(s) of the training, and the signature of the person who conducted the training or the signature of the employer. If the employer 204

relies on training conducted by another employer or completed prior to the effective date of this section, the certification record shall indicate the date the employer determined the prior training was adequate rather than the date of actual training. 2. 1926.503(b)(2) The latest training certification shall be maintained. RETRAINING 1. When the employer has reason to believe that any affected employee who has already been trained does not have the understanding and skill required by paragraph (a) of this section, the employer shall retrain each such employee. Circumstances where retraining is required include, but are not limited to, situations where: a. Minger Construction Co., Inc. will provide training for employees exposed to falls as part of their regular work duties. This would include workers involved in demolition work where the majority of fall exposures faced by this company will exist. 205

SECTION 29 LOCKOUT/TAGOUT 206

SECTION 29: LOCKOUT/TAGOUT GENERAL This section has information for isolating all forms of energy, from any source, with lockouts and tagouts (durable tags) to prevent unexpected energizing or start-up of equipment or release of stored energy that can cause injuries. Energy forms include, but are not limited to: Electrical, Mechanical, Hydraulic, Pneumatic, Chemical, Thermal and Gravity. IDENTIFICATION OF HAZARDS 1. Electrical Hazards - Severe shock, burns or electrocution can result from accidental or unexpected energizing of an electrical circuit, which is contacted. 2. Mechanical Hazards - Crushing, bruising, pinching, grinding and shearing injuries can result from unexpected activation of a piece of equipment. This activation may result from electrical input, combustion engine input, hydraulic or pneumatic input, or from mechanical advantage, such as a counterweight or spring and gravitational. 3. Chemical Hazards - Burns, drowning or other serious side effects can result from an unexpected release of chemicals. These may include acids, bases, solvents and even water. 4. Hydraulic Hazards - Loss of eyesight, hearing and skin laceration or penetration can result from a sudden release of fluids under high pressure, such as hydraulic fluids. 5. Pneumatic Hazards - Loss of eyesight, hearing and skin laceration or penetration can result from a sudden release of compressed gases or vapors under high pressure. 6. Thermal/Cryogenic Hazards - Burns may result from elevated or reduced temperature associated with gases or liquids. These may include steam, condensate, liquid nitrogen or others. TRAINING Each employee who will be involved in the lockout-tagout procedure must be trained by the designated lockout-tagout coordinator prior to performing work on any mechanical, electrical system, etc. This may include: 1. millwrights, 2. ironworkers, 3. laborers, 4. carpenters, 5. pipefitters, 6. cement finishers, 7. masons, 8. electricians, 9. plumbers, 10. operating engineers, 11. boilermakers, etc. 207

Any additional employees whose work operations may be in an area where energy control procedures are necessary must receive training. All training must include; 1. recognition of hazardous energy sources, 2. types and magnitude of energy, 3. methods and means required for energy isolation and control, 4. and use of locks and tags along with the procedure that will be implemented. 5. Trainees are informed that tags are not to be removed without authorization and tags are not to be ignored or defeated in any way. 6. All training is documented, signed, and certified. 7. Retraining is required when there is a change in job assignment, in machines, a change in the energy control procedures, or a new hazard is introduced. PROCEDURE/APPLICATIONS FOR CONTROL An authorized employee will be designated to control this program. This authorized employee will be responsible for enforcing the program and ensuring all specific procedures, rules, techniques, and inspections are performed properly. 1. SEQUENCE Authorized persons will work together to identify energy sources and apply the appropriate protection. They will: a. Notify all affected persons that an equipment lock-out/tag-out procedure is going to be implemented (specify which equipment is included). b. If the machine or equipment is operating, production will shut down. The equipment shall be shut down using the procedures established for that particular machine. Orderly shutdown will be utilized to avoid any additional hazards. c. The authorized employee shall have knowledge of the type and magnitude of the energy, as well as the hazards of the energy being controlled. The methods and means of controlling the energy shall be known. d. Isolate the equipment from its energy source(s). Stored energy (such as that in springs, elevated machine members, rotating flywheels, hydraulic systems, capacitors, and air, gas, steam or water pressure, etc.) must be dissipated or restrained by methods such as repositioning, blocking, bleeding down, etc. If there is a possibility of re-accumulation of stored energy, verification of isolation will be continued until the servicing or maintenance is completed. e. Lockout and Tag applicable energy sources. All locks must also be tagged to identify the individual applying the lock & the date. Devices will be affixed by authorized employees. Where a tag cannot be affixed directly to the energy isolating device, the tag shall be placed as close as safely possible to the device in a position that will be immediately obvious to anyone attempting to operate the equipment. f. Isolation Verification: After ensuring that no personnel are exposed, try to start/operate the equipment using normal operating controls to make certain the equipment will not operate. CAUTION: Return operating control(s) to “neutral” or “off” position after the test. g. The equipment is now locked out and tagged. 208

2. RESTORING MACHINES/EQUIPMENT TO NORMAL OPERATION a. After work is complete and equipment is ready for normal operation, authorized personnel shall check the area around the machines/equipment to ensure that nobody is exposed. b. After all tools have been removed from the machine/equipment, guards have been reinstalled, and personnel are cleared from the area, remove all lockout devices and tags. c. Notify all affected persons that the machine will be started. Remove the energy isolating devices to restore energy to the machine or equipment. d. Start the machine/equipment. 3. REMOVAL OF LOCKDOWN DEVICES BYOTHER PERSONS a. Verify that the individual who applied the lockout device is not at the Plant/Site. b. Make all reasonable efforts to contact the individual to inform him/her that the lockout device will be removed and to determine if there is a reason not to remove it. c. Notify the individual’s supervisor that the lockout device needs to be removed. d. Ensure that the individual knows that the lockout device has been removed upon their return to the Plant/Site and before they return to the work area to resume work. 4. GROUPS Multiple groups of workers, different crafts, or different departments are not permitted to work under the same program, unless the procedures can afford the group of employees a level of protection equal to that provided by a personal lockout-tagout system. The authorized employee will ascertain the exposure status of individual group members. Each employee shall attach a personal lockout-tagout device to the group’s device while working and then removes it when finished. During shift change or personnel changes the excused authorized employee will facilitate a hand-off meeting with the starting authorized employee to ensure continuity in the lockout-tagout system. A sign on / sign off sheet will be kept for documentation. 5. INSPECTION Periodic inspection will be conducted at least annually to ensure the lockout-tagout procedures and requirements are being adhered to. This inspection may be performed by the project superintendent, project safety manager, or another competent person other than those who actually are using the lockout-tagout in progress. The Safety Director will review this inspection and document the certification including date, equipment, employees, and inspector information. 209

MATERIALS If an energy source can be locked out, this method will be utilized. A lockout device will use a lock and key or combination to hold an energy isolating device in the safe position. If using a lockout device is not possible then the tagout system will be used. 1. HARDWARE USED FOR LOTO a. Locks, b. tags, c. chains, d. wedges, e. key blocks, f. adapter pins, g. self-locking fasteners, h. or other hardware shall be provided for isolating, securing or blocking of energy sources from equipment. 2. LABELING The energy isolating devices required by this standard shall be permanently labeled, identifying the isolated equipment for “affected” and “authorized” employees. Each devise will display the identity of the employee applying the device. 3. TAGOUTS (durable tags) shall be used in conjunction with lockout devices. a. Tags are warning devices affixed to lockout devices. b. Tags shall be dated, and shall be legible and understood by all affected employees. c. A tagout shall identify the person who applied the lockout devices and briefly describe the reason for the lockout. d. A tag attached to a lockout device shall not be removed without authorization from the person responsible for it. e. Tags and their means of attachment shall be made of materials that can withstand environmental conditions. f. Tags shall be securely attached to lockout devices so that they cannot be inadvertently or accidentally detached. 210

SECTION 30 ELECTRICAL SAFETY PROGRAM 211

SECTION 30: ELECTRICAL SAFETY PROGRAM 29 CFR 1926 Subpart K & NFPA 70E GENERAL No Minger Construction Co., Inc. employee will be permitted to work on energized electrical parts or take part in any activity that would require them to be a qualified person regarding electrical work. If this nature of work is in the scope of work for a contract the work will be performed by a qualified subcontractor and this qualified contractor will abide by this safety manual. TRAINING Employees must be trained in and familiar with any electrically related safety practices that pertain to their respective job assignments and related job duties. This training will be part of the employee’s on-the-job training when job assignments are made. WORK PRACTICES 1. Safety related work practices must be employed to prevent electric shock or other injuries resulting from either direct or indirect electrical contacts, when work is performed near or on equipment or circuits which are or may be energized. The specific safety related work practices must be consistent with the nature and extent of the associated electrical hazards. 2. Live parts to which an employee may be exposed must be de-energized before the employee works on or near them, unless: a. A qualified electrician can demonstrate that de-energizing introduces additional or increased hazards or is infeasible due to equipment design or operational limitations. Live parts that operate at less than 50 volts to ground need not be de- energized if there will be no increased exposure to electrical burns or to explosion due to electric arcs. b. If the exposed live parts are not de-energized, other safety-related work practices must be used to protect employees who may be exposed to the electrical hazards involved. Such work practices must protect employees against contact with energized circuit parts directly with a part of their body or indirectly through some other conductive object. c. The work practices that are used must be suitable for the conditions under which the work is to be performed and for the voltage level of the exposed electric conductors or circuit parts. WORKING ON OR NEAR EXPOSED DE-ENERGIZED PARTS 1. Conductors and parts of electric equipment that have been de-energized but have not been locked out or tagged must be treated as energized parts. 212

2. While any employee is exposed to contact with parts of fixed electric equipment or circuits which have been de-energized, the circuits energizing the parts must be locked out or tagged or both in accordance with the Minger Construction Co., Inc. Lockout-Tagout Procedure. 3. Safe procedures for de-energizing circuits and equipment must be determined before circuits or equipment are de-energized. a. The circuits and equipment to be worked on must be disconnected from all electric energy sources. Control circuit devices, such as push buttons, selector switches, and interlocks may not be used as the sole means for de-energizing circuits or equipment. Interlocks for electric equipment may not be used as a substitute for lockout and tagging procedures. b. Stored electric energy which might endanger personnel must be released. Capacitors must be discharged and high capacitance elements must be short- circuited and grounded, if the stored electric energy might endanger personnel. c. Stored non-electrical energy in devices that could re-energize electric circuit parts must be blocked or relieved to the extent that the circuit could not be accidentally energized by the device. d. A lock and a tag must be placed on each disconnecting means used to de-energize circuits and equipment on which work is to be performed. The lock must be attached so as to prevent persons from operating the disconnecting means unless they resort to undue force or the use of tools. e. Each tag must meet the requirements of the Minger Construction Co., Inc. Lockout- Tagout Procedure. f. A tag used without a lock must be supplemented by at least on additional safety measure that provides a level of safety equivalent to that obtained by the use of a lock. Additional safety measured include the removal of an isolating circuit element, blocking of a controlling switch, or opening of a controlling switch, or opening of an extra disconnecting device. 4. A qualified person must operate the equipment operating controls or otherwise verify that the equipment cannot be restarted. a. A qualified person must use test equipment to test the circuit elements and electrical parts of equipment to which employees will be exposed and must verify that the circuit elements and equipment parts are de-energized. b. The test must also determine if an energized condition exists as a result of inadvertently induced voltage or unrelated voltage backfeed even though specific parts of the circuit have been de-energized and presumed to be safe. c. If the circuit to be tested is over 600 volts, nominal, the test equipment must be checked for proper operation immediately before and immediately after this test. 5. A qualified person must conduct tests and visual inspections as necessary, to verify that all tools, electrical jumpers, shorts, grounds, and other such devices have been removed so that the circuits and equipment can be safely energized. a. Employees exposed to the hazards associated with re-energizing the circuit or equipment must be warned to stay clear of circuits and equipment. b. Each lock and tag must be removed by the employee who applied it. Removal of the lock or tag must be made in accordance with the Minger Construction Co., Inc. 213

Lockout-Tagout Procedure. If removal must be made in the employees’ absence, The Lockout-Tagout Procedure must be followed. c. There must be a visual determination that all employees are clear of the circuits and equipment. WORKING ON OR NEAR EXPOSED ENERGIZED PARTS 1. Only qualified persons may work on electric circuit parts or equipment that has not been de-energized. These qualified persons must be capable of working safely on energized circuits and must be familiar with the proper use of special precautionary techniques, personal protective equipment, insulating and shielding materials, and insulated tools. 2. If work is to be performed near overhead un-insulated lines, or insulated lines of 600 volts or greater, the lines must be de-energized and grounded, or other protective measures provided before work is started. If protective measures are provided (such as guarding, isolating, or insulating), these precautions must prevent employees from contacting such lines directly with any part of their body or indirectly through conductive materials, tools, or equipment. 3. When a qualified person is working in the vicinity of overhead lines, whether in an elevated position or on the ground, the person may not approach or touch any conductive object without an approved insulating handle. The qualified person may not come closer to the exposed energized parts than shown in the following table: Voltage Range (Phase to Phase) Minimum Approach Distance 300V. and less Avoid contact 300V. up to 750V. 1 ft. 0 in. 750V. up to 2kV. 1 ft. 6 in. 2kV. up to 15kV. 2 ft. 0 in. 15kV. up to 37kV. 3 ft. 0 in. 37kV. up to 87.5kV. 3 ft. 6 in. 87.5kV. up to 121kV. 4 ft. 0 in. Over 121kV. not over 140kV. 4 ft. 6 in. a. These qualified persons must be insulated from the energized part (gloves, with sleeves, if necessary, rated for the voltage involved are considered to be insulation for the person from the energized part on which work is performed.) b. The qualified person must be insulated from the energized part and from all other conductive objects at a potential different from that of the energized part. 3. Any unqualified vehicle, persons or mechanical equipment capable of having parts of its structure elevated near energized overhead lines must be operated so that a clearance of ten (10) feet is maintained. If the voltage is higher than 50kV, the clearance must be increased four (4) inches for every 10kV over that voltage. 4. Employees may not enter spaces containing exposed energized parts unless illumination is provided that enables the employees to perform the work safely. a. Where lack of illumination or an obstruction precludes observation of the work to be performed, employees may not perform tasks near energized parts. b. Employees may not reach blindly into areas which may contain energized parts. 5. When an employee works in a confined or enclosed space that contains exposed energized parts, the Qualified Contractor will provide, and the employee must use, 214

a. protective shields, b. protective barriers, c. or insulating materials as necessary to avoid inadvertent contact with these parts. d. doors, hinged panels, and the like must be secured to prevent their swinging into an employee and causing the employee to contact exposed energized parts. 6. Conductive materials and equipment that are in contact with any part of an employee’s body must be handled in a manner that will prevent them from contacting exposed energized conductors or circuit parts. a. If an employee must handle long dimensional conductive objects in areas with exposed live parts, the Qualified Contractor must institute work practices (insulation, guarding, material handling techniques, etc.) which minimize, or eliminate, the hazard. b. Portable ladders must have nonconductive side rails due to the potential of contact with exposed energized parts. Metal ladders are not allowed in the work area. c. Conductive articles of jewelry and clothing may not be worn if they might contact exposed energized parts. 7. Where live parts present an electrical contact hazard, employees may not perform housekeeping duties at such close distances to the parts that there is a possibility of contact unless adequate safeguards are provided. 8. The following alerting techniques must be used to warn and protect employees from hazards which could cause injury due to electric shock, burns, or failure of electric equipment parts: a. Safety signs, safety symbols, or accident prevention tags must be used where necessary to warn employees about electrical hazards which may endanger them. b. Barricades must be used in conjunction with safety signs where necessary to prevent or limit employee access to work areas exposing employees to un-insulated energized conductors or circuit parts. Conductive barricades may not be used where they might cause an electrical contact hazard. c. If signs and barricades do not provide sufficient warning and protection from electrical hazards, an attendant must be stationed to warn and protect employees. PROTECTIVE EQUIPMENT 1. Employees working in areas where there are potential electrical hazards must be provided with, and use, electrical protective equipment that is appropriate for the specific parts of the body to be protected and for the work being performed. 2. Protective equipment must be maintained in a safe, reliable condition and must be periodically inspected or tested. 3. If the insulating capability of protective equipment may be subject to damage during use, the insulating material must be protected. 4. Employees must wear nonconductive head protection. 215

SECTION 31 RESPIRATORY PROTECTION PROGRAM 216

SECTION 31: RESPIRATORY PROTECTION PROGRAM 29 CFR 1910.134 Subpart I GENERAL Minger Construction Co., Inc.’s Safety Department is qualified by appropriate training or has experience that is commensurate with the complexity of the program to administer or oversee the respiratory protection program and conduct the required evaluations of program effectiveness. All respirators, training, and medicals are provided at no cost to the employee. PROCEDURES FOR SELECTING RESPIRATORS 1. Minger Construction Co., Inc. will evaluate respiratory hazard(s) in the workplace; identify relevant workplace and user factors, and base respirator selection on those factors that affect respirator performance and reliability. 2. All respirators will be NIOSH (National Institute of Occupational Safety and Health) certified. Selection is based on the physical and chemicals properties of air contaminants and the concentration level likely to be encountered. 3. The evaluation shall include a reasonable estimate of employee exposes to respiratory hazard(s) and identification of the contaminant’s chemical state and physical form. 4. Where Minger Construction Co., Inc. cannot identify or reasonably estimate the employee exposure, the Company shall consider the atmosphere to be IDLH (Immediately Dangerous to Life or Health). 5. If the company determines that any respirator use is permissible, the company will provide the respirator user with information contained in Appendix D (“Information for Employees Using Respirators When Not Required Under the Standard”) 6. Exception: Under the OSHA Standard the employer is not required to include in a written respiratory protection program for those employees whose only use of respirators involves the use of filtering face piece (dust mask). 7. All oxygen-deficient atmospheres will be considered IDLH. The company will provide a full face pressure demand SCBA certified by NIOSH for a minimum service life of thirty minutes, or a combination full face piece pressure demand supplied-air respirator (SAR) with auxiliary self-contained air supply. 8. Respirators that may be used and are approved include: Self Contained Breathing Apparatus (SCBA), Supplied-Air (SA), Escape Mouthpiece Type (E), Air Purifying Half- Mask or Full-face (AP)(PAPR), Dust/Mist/Fume Filter Mask (DMF), and Air Purifying (AP). 217

MEDICAL EVALUATION 1. Using a respirator may place a physiological burden on our employees that varies with the type of respirator worn, the job and workplace conditions in which the respirator is used, and the medical status of the employee. 2. The company will provide a medical evaluation to determine the employee’s ability to use a respirator, before the employee is fit tested or required to use a respirator in the workplace. The company may discontinue an employee’s medical evaluations when the employee is no longer required to use a respirator. 3. Medical Evaluation Procedures a. Minger Construction Co., Inc. will identify a physician or licensed health care professional (PLHCP) to perform medical evaluations using a medical questionnaire or an initial medical examination that obtains the same information as the questionnaire. b. The medical evaluation will obtain the information requested by the questionnaire in section 1 and 2, Part A of Appendix C of this program. 4. Administration of the Medical Questionnaire and Examinations a. The medical questionnaire and examinations will be administered confidentially during the employee’s normal working hours or at a time and place convenient to the employee. b. The medical questionnaire will be administered in a manner that ensures that the employee understands its content. The company will provide the employee with an opportunity to discuss the questionnaire and examination results with the PLHCP. FIT TESTING PROCDURES 1. Before an employee will be required to use any respirator with a negative or positive pressure tight-fitting face piece, the employee must be fit tested with the same make, model, style and size of respirator that will be used. 2. The company will ensure that an employee using a tight-fitting face piece respirator passes an appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT). SARs are required to be fit tested. 3. Face piece Seal Protection, the company will not permit respirators with tight-fitting face piece to be worn by employees who have: a. Facial hair that comes between the sealing surface of the face piece and the face or that interferes with the valve function; or any condition that interferes with the face- to face piece seal or valve function. b. If an employee wears corrective glasses or goggles or other personal protective equipment that does interfere with the seal of the face piece. 4. The company will ensure that personal protection equipment is worn in a manner that does not interfere with the seal of the face piece to face of the user. 5. The employee shall perform a user seal check each time they put on the respirator, using recommend procedures from the manufacturer. 6. Positive and Negative fit tests shall be performed every time a respirator is worn by an employee to ensure the proper fit, prior to entering a work environment. 218

7. User seal check procedures are: a. Positive Pressure Test – While wearing the respirator, employee should cover or close off the exhalation valve(s) typically in the front of the respirator, and exhale into the face piece. This should a slight positive pressure inside the face piece without any air leaking out or breaking the seal. b. Negative Pressure Test – While wearing the respirator, employee should cover or close the inhalation valve(s) typically in the side of the respirator where the filters attach, and inhale. This should build a slight negative pressure inside the face piece, by collapsing against the employee’s face. If the face piece stays collapsed and there’s no air leaking into the respirator, you can proceed. SAFE WORK PRACTICES FOR RESPIRATOR USE 1. Respirators are designed to make sure the air we breathe does not pose a health hazard to us. 2. Air Purifying, Powered Air Purifying, and Filtering Respirators are used when the air has enough oxygen but contains dangerous contaminants. These types of respirators screen/filter out the dangerous materials or move the air through a chemical that “washes” the air so we can breathe it safely, & comes in full-face and half-face. 3. While very mild dust hazards may require a disposable-type filtering face piece respirator, most air-purifying respirators used by Minger Construction Co., Inc. have replaceable filters, or cartridges. Regardless of the hazard on-site, Supervisors (Project Managers and Foremen) are responsible for identifying, obtaining and training, employees on the safe use, fit, cleaning, maintenance and storage, as well as monitoring respirator use to ensure that selected respirator is effective. 4. The filter, cartridges, and even the mask don’t last forever. They have to be cleaned daily and changed periodically based on use, effectiveness, and ability to breath freely. Each respirator has its own requirements, but as a general rule, if you can smell or taste a contaminant in the air, it’s time to get to get the filters changed. 5. It is not anticipated that Minger Construction Co., Inc. will need to use air supplied respirators. For that reason, this program will not cover the use of those respirators. 6. Regarding SA and SCBA, air must be Grade D or better. When utilized with a compressor, it must be located in a clean atmosphere with in-line purification. This must be tagged to indicate date of installation or change-out. A carbon monoxide monitor must be incorporated in the system. An alarm will sound when levels exceed 10 PPM. Fitting must not allow connection to non-respirable gases or containers. 7. Maintenance and Care, Cleaning and Disinfecting of Respirators a. The company will provide for cleaning and disinfecting, storage, inspection, and repair of respirators used by employees. Each respirator user will be provided with a clean, sanitary, respirator in good working order. The respirators shall be clean and disinfected using procedures recommended by the respirator manufacturer. b. The respirators shall be cleaned and disinfected at the following intervals: i. Respirators issued for the exclusive use of an employee shall be clean and disinfected as often as necessary to be maintained in a sanitary condition; ii. Respirators used in fit test training shall be cleaned and disinfected after each use. 219

8. Storage; The company will ensure that respirators are stored as follows: a. All respirators will be stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals, and b. shall be packed or stored to prevent deformation of the face piece and exhalation valve. 9. Inspection; The company will monitor the program to ensure employees are following procedure. a. The company will ensure that respirators are inspected as follows: i. All respirators used in routine situations will be inspected before each use and during cleaning. ii. Respirators used for emergency will be inspected monthly as well as before and after each use. iii. Respirators used for escape only will be inspected before being carried into the workplace. b. The company will ensure that respirator inspections include the following: i. A check of respirator function, tightness of connections, and the condition of the various parts including, but limited to, the face piece, head straps, valves, connecting tube, and cartridges canisters or filters; and a check of elastomeric parts for pliability and signs of deterioration 10. IDLH Atmospheres a. One employee or, when needed, additional employees will be located outside the IDLH atmospheres. b. Visual, voice, or a signal line communication will be maintained between the employees located in the IDLH atmosphere and outside the IDLH atmosphere. c. Affected employees involved in this operation are to be trained to perform emergency rescue along with basic first aid and CPR. The designated employees are to have the knowledge to utilize rescue equipment such as: body harness, lifeline, tripod, SCBAs, supplied air respirator with auxiliary air supply, etc. d. Prior to an employee entering an IDLH atmosphere, the designated person assigned to monitor this activity is to be notified and provide assistance required to perform the work in a safe manor. 11. Training in Respiratory Hazards The company will ensure that each employee that uses a respirator will have training initially and annually of at least the following: a. Why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator; b. What the limitations and capabilities of the respirator are; c. How to use the respirator effectively in emergency situations d. How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators. e. What the procedures are for maintenance and storage of the respirator. f. The training shall be conducted in a manner that is understandable to the employee. g. If there is reason to believe that an employee lacks the skill or understanding necessary for safe work involving respirators, the employee must be retrained so that the required proficiency is obtained. 220

ANNUAL PROGRAM EVALUATION PROCEDURES 1. The company will conduct evaluations of the workplace as necessary to ensure that provisions of the current written program are being effectively implemented and that it continues to be effective. Employees will be asked about fit, selection, use, and maintenance. 2. Minger Construction Co., Inc.’s Safety Department is qualified to administer the program. RECORDKEEPING 1. A written copy of this program and the OSHA standard is kept in the Safety Directors office and is available to all employees who wish to view it. 2. Also maintained are copies of training and fit test records. These records will be updated as new employees are trained, as existing employees received refresher training, and as new fit tests are conducted. 3. The Responsible Safety Department will also maintain copies of the medical records for all employees covered under the respirator program. 4. The completed medical questionnaire and the PLHCP’s documented findings are confidential and will remain at the Registered Healthcare Providers facility. The company will only retain the physician’s written recommendation regarding each employee’s ability to wear a respirator. 221

SECTION 32 SILICA DUST HAZARDS 222

SECTION 32: SILICA DUST HAZARDS 29 CFR 1926.1153 GENERAL Employees may be exposed at the worksite when: • cutting, sawing, drilling, and crushing of concrete, brick, ceramic tiles, rock, and stone products, • jack hammering, abrasive blasting, rock drilling, concrete mixing, patching and grouting, tuck-pointing, and grinding and polishing concrete materials, • operating wheel-tired equipment such as small or large loaders, skid steers, and telescopic bucket lifts, • operating cranes, rigging, • managing a worksite, dust control • or through other means, which are determined by an exposure assessment. DEFINITIONS ACTION LEVEL (“AL”): a concentration airborne respirable crystalline silica of 25 ug/m3, calculated as an 8-hour Time Weighted Average. COMPETENT PERSON: a designated individual who is capable of identifying existing and foreseeable respirable crystalline silica hazards in the workplace and who has authorization to take prompt corrective measures to eliminate or minimize them. The competent person must have the knowledge and ability necessary to fulfill the responsibilities set forth in the Written Exposure Control Plan. EMPLOYEE EXPOSURE: the exposure to airborne respirable crystalline silica that would occur if the employee were not using a respirator. HIGH-EFFICIENCY PARTICULATE AIR: a filter that is at least 99.97 percent efficient in removing mono-dispersed particles of 0.3 micrometers in diameter. OBJECTIVE DATA: information, such as air monitoring data from industry-wide surveys or calculations based on the composition of a substance, demonstrating employee exposure to respirable crystalline silica associated with a particular product or material or a specific process, task, or activity. The data must reflect workplace conditions closely resembling or with a higher exposure potential than the processes, types of material, control methods, work practices, and environmental conditions in the employer’s current operation. PERMISSIBLE EXPOSURE LIMIT (“PEL”): concentration airborne respirable crystalline silica of 50 ug/m3, calculated as an 8-hour Time Weighted Average. 223

PHYSICIAN OR OTHER LICENSED HEALTH CARE PROFESSIONAL (“PLHCP”): an individual whose legally permitted scope of practice (i.e., license, registration, or certification) allows him or her to independently provide or be delegated the responsibility to provide some or all of the particular health care services required by this paragraph (h) of this section. REGULATED AREA: an area, demarcated by the employer, where an employee’s exposure to airborne concentrations of respirable crystalline silica exceeds, or can reasonably be expected to exceed, the Permissible Exposure Limit. RESPIRABLE CRYSTALLINE SILICA (“silica”): quartz, cristobalite, and/or tridymite contained in airborne particles that are determined to be respirable by a sampling device designed to meet the characteristics for respirable-particle-size-selective samplers specified in the International Organization for Standardization (ISO) 7708:1995 Air Quality – Particle Size Fraction Definitions for Health-Related Sampling. RESPIRATORY PROTECTION: when the use of respirators is required by this rule a respiratory protection program shall be instituted in accordance with 29 CFR 1910.134. Respirators protect the user by the removal of contaminants from the air. Respirators of this type include particulate respirators, which filter out airborne particles, and air-purifying respirators with cartridges/canisters which filter out chemicals and gases. Other respirators protect by supplying clean respirable air from another source. Respirators of this type include self-contained breathing apparatus, which include their own air supply. ROLES AND RESPONSIBILITIES 1. Controlling Entity - Under this plan the controlling entity is responsible for the following: a. Ensure common areas at the worksite (e.g., roadways, barren surfaces, walkways, etc.) are treated or maintained to minimize exposure to silica dust. b. Ensure workers are provided with an adequate and continuous supply of water to operate water integrated systems. c. Ensure proper coordination between subcontractors in order to minimize exposure to dust at the worksite. d. Use objective data or specific analysis of the silica content of the worksite when Table 1 does not provide guidance. e. Assessment of the written program's effectiveness at least annually. 2. Employer / subcontractor is responsible for the following: a. Ensure that this Exposure Control Plan is fully and properly implemented. b. Based upon objective and/or specific data the silica content of the worksite soil, the level of respirable silica on the information provided. c. Requirements for water and amounts needed are available. d. Ensure that the materials (e.g., tools, equipment, personnel protective equipment (“PPE”)) and other resources (e.g., employee training) required to fully and properly implement are readily available. e. Provide required materials and documentation to comply with 29 CFR 1926.1153. A copy of this Exposure Control Plan shall be present on this worksite and made readily available for examination and copying, upon request, to each employee or designated representative, the Assistant Secretary and the Director. 224

f. Ensure that supervisors and employees are trained in the proper use of engineering controls and implementation of work practices. g. Review and evaluate the effectiveness of the Exposure Control Plan at least annually and update it as necessary. h. Coordinate work with the general contractor and other subcontractors to minimize exposure to silica. 3. Supervisor Responsibilities - are responsible for the following: a. Provide adequate training and instruction to employees on the implementation of this Exposure Control Plan. b. Select and implement the appropriate control measures. c. Ensure that employees using respirators have been properly trained and fit-tested, and that the results are recorded. d. Ensure that control methods, including engineering controls and respirators, are maintained in accordance with manufacturer specifications. e. Ensure work is conducted in a manner that minimizes and adequately controls the risk to employees and others. This includes ensuring employees use the available engineering controls and implement work practices. f. Ensure employees have been trained in this exposure control plan. They must ensure that employees understand this Exposure Control Plan’s expectations and enforce it on the worksite. 4. Employee Responsibilities - employees are responsible for the following: a. Read, understand, and comply with the control methods set out in this Exposure Control Plan. b. Complete the training provided by the employer. c. Ensure their safety and the safety of others at the worksite. d. Use the Assigned Protection Factor (APF) equipment in an effective and safe manner in accordance with work site procedures developed by employer Follow established work procedures and use controls as directed by the supervisor e. Report to the supervisor any unsafe condition or equipment. f. Report to the supervisor any equipment or tool defect or change in conditions that could result in a potential overexposure to silica. CONDUCTING AN EXPOSRUE ASSESSMENT 1. An Exposure Assessment is required when an employer does not fully and properly implement Table 1 under section (c) or performs a task that is not listed on Table 1. 1926.1153(d)(1) – Permissible exposure limit (“PEL”). The employer shall ensure that no employee is exposed to an airborne concentration of respirable crystalline silica in excess of 50ug/m3, calculated as an 8-hour time weighted average (“TWA”). 1926.1153(d)(2)(i) – Exposure assessment. The employer shall assess the exposure of each employee who is or may reasonably be expected to be exposed to respirable crystalline silica at or above the action level (25ug/m3). 2. Factors of Exposure Risk: a. Identify the tasks that would place workers at risk of exposure. 225

b. Consider the following factors: Time, Proximity, Relative, Dustiness, Energy, Quantity in use and Percentage of Silica. 3. A medical surveillance program for all employees whose exposure are equal to or exceed the action level for 30 or more days per year. 4. Exposure assessments must be conducted for those employees who are expected to be exposed to respirable crystalline silica at or above the action level. 5. Applicable records must be kept. CONDUCT A JOB HAZARD ANALYSIS FOR SILICA 1. Tailor the Exposure Control Plan to the particular worksite. Recognize when silica dust may be generated and plan ahead to eliminate or reduce exposure of dust at the source. 2. Silica Hazard Analysis: a. Identify the Hazard. b. Describe tasks causing a Silica Hazard. c. Review any objective or specific air monitoring data. d. Gather additional information by conducting scheduled air monitoring. e. Document the answers to the following questions in a consistent manner: i. Where is it happening? ii. Who or what is it happening to? iii. What triggers the hazard? iv. Outcome that would occur? v. Any contributing factors? 3. Control the hazard with Engineering and Work Practice Controls. a. Engineering Controls: i. Housekeeping: Remove dust before it becomes airborne by traffic, vibration and random air currents. ii. Isolation: Hazardous operations should be isolated to reduce exposure to employees such as a physical barrier. iii. Wet Work: Airborne silica dust hazards can be minimized or greatly reduced by applying water. When possible, apply water to all respirable silica dust generating operations (i.e., sawing, drilling, etc.) iv. Ventilation: Local exhaust ventilation captures contaminants at their source before they escape into the jobsite. v. Dust Control: Use a vacuum with a high-efficiency particulate air filter (HEPA) b. Work Practice Controls; If engineering controls are infeasible or do not reduce silica levels below the PEL, work practice controls should be used. i. Restricted Areas: Post Warning signs in areas where there is silica exposure in order to keep other workers out of those work areas. ii. Personal Hygiene: Wash hands to minimize worker contact with silica dust. iii. Training: The training is about exposure to hazards in the workplace and is now required by state and federal hazard communications standards (right to know laws). Furthermore, OSHA under 29 CFR 1926.21 requires safety training for all exposed employees. Periodic refresher training is required. iv. Medical Surveillance: Medical examinations should only supplement exposure monitoring and controls. The examinations should take place 226

before job placement or upon entering a trade and at least every three years thereafter. c. Personal Protective Equipment – PPE including the use of a respirator may be necessary to protect the worker from the environment when it is not feasible to render a completely safe work environment. i. Respiratory Protection: As a last resort, if the silica levels cannot be brought down to permissible limits, then a respirator will have to be introduced. ii. Protective Clothing: Change into disposable work clothes (i.e., Tyvek suits) at the jobsite, and always leave protective clothing at work! ELEMENTS OF AN EXPOSURE CONTROL PLAN 1. Exposure Control Methods for Construction Industry - 29 CFR 1926.1153(c), OSHA has performed an exposure assessment and a Job Hazard Analysis regarding specified tasks identified in the construction industry Table 1. 2. This Exposure Control Plan implements the requirements of 29 CFR 1926.1153(c). 3. Specified exposure control methods by: identifying and describing the tasks that involve employee exposure to silica, describing the engineering controls, work practice controls, and respiratory protection used to limit employee exposure to silica, describing the housekeeping measures to limit employee exposure to silica. 4. For each employee engaged in a task identified on Table 1, the employer shall fully and properly implement the engineering controls, work practices, and respiratory protection specified for the task on Table 1. 5. If the employer complies with Table 1, then an exposure assessment is not required to be performed and Job Hazard Analysis does not need conducted. 6. If an employer does not fully and properly implement Table 1, or a work task is not identified on Table 1, then the employer shall limit the exposure of the employee to silica in accordance with paragraph (d) of this section. 7. Alternative Exposure Control Methods Per 29 CFR 1926.1153(d) a. For tasks not listed in Table 1, or where the employer does not fully and properly implement the engineering controls, work practices, and respiratory protection described in Table 1, the employer shall follow 29 CFR 1926.1153(d). b. Section (d) requires the employer develop another table (Table 1A) to address the additional needs and tasks of the employer. This Exposure Control Plan implements the requirements of 29 CFR 1926.1153(d). c. Alternative exposure control methods require the employer to: conduct an exposure assessment and Job Hazard Analysis to identify and describe the tasks that involve employee exposure to silica, describe the engineering controls, work practice controls, and respiratory protections used to limit employee exposure to silica, and describe the housekeeping measures to limit employee exposure to silica. d. The employer shall perform an exposure assessment and a Job Hazard Analysis regarding tasks not identified in Table 1, or the tasks in Table 1 are not fully and properly implemented. 227

PROCDURES FOR RESTRICTING ACCESS TO WORK AREAS 1. Per section 1926.1153(g)(1)(iv), the employer shall establish procedures for restricting access to work areas, when necessary, to limit the number of employees exposed to silica and the levels to which they are exposed, including exposures generated by other employers or sole proprietors at a worksite. 2. The following procedures shall be reviewed and implemented for each work site. Due to the variability of when employees are exposed to silica and the changing construction environment, review and revisions of these procedures may be required during a project. 3. If this situation occurs, then additional communications to employees may be necessary. a. Identify work areas where employees are likely to be exposed to silica. If appropriate and helpful, use a general plat or map of the work site to identify work areas where employees are exposed to silica. b. The Competent Person shall regularly evaluate the work site and ensure that areas that cause employees to be exposed are properly restricted and employees informed. c. If appropriate, coordinate with other contractors on the worksite regarding work activities. To the extent possible, schedule high exposure tasks when others are not likely to be in the work area. d. Employees shall maintain a safe distance from dust clouds generated by work activities. e. Employees shall reposition themselves so they will not be exposed to silica plume. COMPETENT PERSON REQUIREMENTS 1. Regulatory Authority - OSHA’s silica standard for construction defines the duty of the employer, 29 CFR 1926.1153(g) (4) the employer shall designate a “competent person” to make frequent and regular inspections of job sites, materials, and equipment to implement the written exposure control plan. 2. OSHA’s silica standard for construction defines competent person as: 29 CFR 1926.1153(b) an individual who is capable of identifying existing and foreseeable respirable crystalline silica hazards in the workplace and who has authorization to take prompt corrective measures to eliminate or minimize them. The competent person must have the knowledge and ability necessary to fulfill the responsibilities set forth in paragraph (g) of this section. 3. Duties of Competent Person - The competent person requirement contained within 29 CFR 1926.1153 expands upon the general competent person requirement under 29 CFR 1926.32(f) by requiring the employer’s competent person to be able to identify respirable crystalline silica hazards, with responsibility for implementing its exposure control plan at its active worksite(s). 4. Training for Competent Person - OSHA maintains that “[b]y way of training and/or experience, a competent person is knowledgeable of applicable standards, is capable of identifying workplace hazards relating to the specific operation, and has the authority to correct them.” 228

ADMINISTRATIVE CONTROLS AND WORKER ROTATION 1. The use of administrative controls such as employee rotation is permitted to limit employee exposure. 2. If an employer has fully implemented Table 1, and working more than 4 hours will necessitate respiratory protection, then the employer could use administrative controls. 3. OSHA accepts administrative controls so that the 4-hour work task is not exceeded requiring respiratory protection. a. OSHA acknowledges that respiratory protection can be restrictive and can be a safety hazard by restricting visibility, impairing communication, contributes to heat stress, strain the respiratory system, and exacerbate other hazards such as slip, trip and fall. b. OSHA recognizes that administrative controls will allow employees to work if they are unable to pass the medical evaluation for respirator use, but otherwise capable of performing the task. 229

SECTION 33 HAZWOPER PROGRAM 230

SECTION 33: HAZWOPER PROGRAM GENERAL Minger Construction Co., Inc. does not directly have employees who are responsible for responding to chemical spills and hazardous waste operations, but this work is commonly found in the scope of various contracts. When HAZWOPER is in the scope of work Minger Construction Co., Inc. will hire a qualified Specialty Contractor to perform this work. Any subcontractor will be required to abide by this written plan and follow a written site-specific safety plan that will meet or exceed the provisions of this policy. 1. HAZWOPER is a complicated regulation, with many different elements required. At Minger Construction Co., Inc. we have done a thorough job of complying with the many aspects of HAZWOPER and we expect our subcontractors to perform at a high-level HAZWOPER compliance as well. 2. Because we may have contract employees who are responsible for responding to chemical spills, our organization has developed a detailed Emergency Response Plan. 3. Due to the exposures and potential exposures that workers can have at our job sites, we require a Medical Surveillance Program, under HAZWOPER 4. Part of our general compliance is to involve local response authorities, when appropriate. Chemical identities and quantities will be reported to the local fire departments and/or emergency management authorities prior to the start of HAZWOPER work. DECONTAMINATION PROCEDURES 1. The decontamination procedures used by the qualified contractor will be developed prior to the commencement of operations and will be detailed in the site-specific safety and health plan. The purpose of the SOP’s is to prevent, remove, or neutralize chemical contaminants that have accumulated on personnel and equipment. 2. Decontamination procedures will be established when there is the possibility of site personnel and equipment being contaminated by hazardous substances, hazardous waste, or where there is a possibility of emergency response activities. Our decontamination standard operating procedures are based on guidance from NIOSH, OSHA, CPWR, and the EPA. 3. All employees and equipment shall be decontaminated, cleaned, laundered, maintained, or replaced as needed to maintain its effectiveness and control the dispersion of contaminants from regulated areas. Impermeable clothing which becomes contaminated with hazardous substances shall be immediately removed by employees, and said employees shall proceed directly to the decontamination unit to remove any contaminants that may have penetrated and permeated the clothing. Equipment, solvents, and clothing which cannot be decontaminated effectively shall be disposed of in accordance with applicable regulations. 4. Decontamination will be performed in geographical areas that will minimize the exposure of uncontaminated employees or equipment to contaminated employees or equipment. 231

5. Unauthorized employees shall not enter controlled areas or remove protective clothing and equipment from decontamination unit change rooms. Protective clothing and equipment sent to commercial establishments shall be accompanied by documentation or the equivalent to ensure that the establishment is aware of the potential contaminants and the potential harmful effects of the hazardous substance. 6. These incorporated and adopted procedures will be monitored by either the Safety Department or the Project Manager to ensure their effectiveness. When deficiencies are noted, they shall be corrected immediately. The procedures will protect workers from hazardous substances that may contaminated and potentially permeate the protective clothing, respiratory equipment, and tools. 7. The decontamination plan, as part of our site-specific safety plan and attached to this written program, allows us to effectively: a. Determine the number, layout, and location of decontamination stations b. Determine decontamination equipment that is needed. c. Determine appropriate decontamination methods. d. Establish procedures to prevent contamination of clean areas. e. Establish methods to minimize worker contact with contaminates during removal of PPE f. Establish methods for disposal of clothing and equipment that cannot be decontaminated. g. Keep unauthorized individuals from entering decontamination areas. h. Inform commercial laundry facilities of potential contaminants and their health effects i. Provide for showers and change rooms in accordance with 29 CFR 1910.141. j. Properly dispose of all solvents and equipment used for decontamination. 8. The plan is revised whenever the type of PPE and equipment changes, the site conditions change, or the site hazards are reassessed based on new information. TRAINING PROGRAM 1. As part of the HAZWOPER program, this training program was developed and implemented to inform workers (including contractors and subcontractors) performing hazardous waste or emergency response operations of the level and degree of exposure they are likely to encounter. 2. Procedures have also been implemented for introducing effective new technologies that proved improved worker protection in hazardous waste operations and spill cleanup. 3. Training makes workers aware of the potential hazards they may encounter and provides the necessary knowledge and skills to perform their work with minimal risk to their safety and health. The employer must develop a training program for all employees exposed to safety and health hazards. 4. Both supervisors and workers must be trained to: a. Recognize hazards and to prevent them. b. Select, care for and use respirators properly as well as other types of PPE. c. Understand engineering controls and their use. d. Use proper decontamination procedures. 232

e. Understand the Emergency Response Plan, medical surveillance requirements, confined space entry procedures, spill containment program, and any appropriate safe work practices. 5. Workers also must know the names of personnel and their alternatives responsible for site safety and health. 6. The amount of instruction differs with the nature of the work operations. Employees must not perform any hazardous waste or emergency response operations unless they have been trained to the level required by their job function and responsibility, and have been certified by their instructor as having completed the necessary training. 7. All emergency responders must receive refresher training sufficient to maintain or demonstrate competency annually. 8. Employee training requirements are further defined by the nature of the work. 9. Minger Construction Co., Inc. relies on 3rd party qualified instructors to provide training for its employees. 10. If a subcontractor provides training to its employees in-house, it will be performed by a designated representative. This representative will have equivalent training or the academic background for the topics taught to provide competent instruction. Determination as to the amount of training to be provided will be determined using the following criteria: a. EMERGENCY RESPONSE 1. First Responder Awareness Level – 2 hours 2. First Responder Operations Level – 8 hours 3. Hazardous Materials Technician – 24 hours 4. Hazardous Materials Specialist – 24 hours 5. On-Scene Incident Commander – 24 hours b. HAZARDOUS WASTE OPERATIONS 1. General Site Workers – 40 Hours off site plus 3 days of field experience. 2. Occasional Workers with limited tasks, specialized skills, working in fully characterized areas not likely to exceed established exposure limits, and not required to wear respiratory protection – 24 Hours off site plus 1 day of supervised field experience. 3. Should Occasional workers exceed established exposure limits or need to wear respirators they shall complete additional training – 16 Hours off site plus 2 days of supervised field experience. 4. Managers and Supervisors shall be trained equivalent to a general site worker and have an additional 8 hours of specialized training on topics to include, but not limited to spill control and containment, PPE programs, site specific safety and health programs, and health hazard monitoring procedures and techniques. c. The program format will consist of formal classroom instruction and hands on activities. The program will be designed to meet or exceed the minimal requirements specified under the HAZWOPER and RCRA regulations detailed under 29 CFR 1910.120(e)(q) and 40 CFR 265.16. d. Employees are to be trained prior to assignment to job duties. Training is based on the duties and functions of assigned personnel. Annual refresher training takes 233

place for all individuals conducting hazardous waste operations and emergency response. e. Upon completion of training, certificates and wallet cards documenting training will be provided. Copies of certificates will be kept in participant’s personnel records at the Corporate Office, and are accessible to all employees, their representatives, the Secretary of Labor, or designee. f. Pre-entry briefing shall be held prior to initiating any site activity, and at such other times as necessary to ensure that employees are apprised of the site safety and health plan. The Project Manager or Project Safety Manager is responsible that this plan is being followed. ORGANIZATIONAL STRUCTURE 1. The project Manager is the general supervisor who has the responsibility and authority to direct all hazardous waste operations. 2. The Project Safety Manager is the site safety and health supervisor who has the responsibility and the authority to develop and implement the site safety and health plan and verify compliance. 3. Other personnel who are needed for hazardous waste site operations and emergency response shall be assigned employees who have received appropriate training. Their general functions and responsibilities will be detailed in the site-specific safety and health plan, and are generally dictated by the scope of services detailed by our contract with the host company. 4. The Project Manager has ultimate responsibility for this plan and carrying out assigned duties in accordance with the developed site-specific safety and health plan and required SOP’s. All employees have the authority to stop a job if hazards are identified which may jeopardize the safety of the operations at hand. Minger Construction Co., Inc. provides the training necessary to allow our employees to identify and predict various job site hazards and the authority to take prompt corrective action. 5. Our organizational structure is reviewed and updated as necessary to reflect the current status of site operations. SITE SPECIFIC SAFETY AND HEALTH PLAN 1. The site-specific safety and health plan is a program that aids in eliminating or effectively controlling anticipated safety and health hazards. The site safety and health plan identifies the hazards of each phase of the specific site operation and is kept on the work site. The site safety and health plan addresses the safety and health hazards of each phase of site operation and includes the requirements and procedures for employee protection. 2. Minger Construction Co., Inc. utilizes job safety and health hazards analysis for each site task and operation identified in the work plan. This analysis identifies and predicts hazards associated with our tasks. Once hazards are identified we utilize engineering controls, work practices, and PPE to minimize the exposure to as low as reasonably achievable and below the most stringent recognized exposure levels established by OSHA and NIOSH. 234

MONITORYING AND ENGINEERING CONTROLS 1. Area and personnel air monitoring utilizing direct reading and passive dosimetry for IDLH conditions and to monitor exposures during the following operations: a. Preliminary evaluations prior to site entry. b. Immediately after initial site entry. c. On emergency responses. d. Periodically on a representative cross section of the work force. e. High risk employees / high exposure tasks. 2. The environmental sampling techniques and instrumentation that are used, including methods of maintenance and calibration of monitoring and sampling equipment, are conducted by individuals competent to use and interpret readings from appropriate industrial hygiene equipment. When exposures or potential exposures exist, engineering controls, work practice, and PPE are implemented to minimize the exposures. 3. If a confined space situation is encountered, Minger Construction Co., Inc. has established confined space entry procedures. 4. Feasible engineering controls, work practices, and PPE will be established as necessary to reduce and maintain exposure limits. Engineering controls include the use of pressurized cabs or control booths on equipment, and/or the use of remotely operated material handling equipment. EMERGENCY RESPONSE 1. Prior to the commencement of emergency response operations, an emergency response plan will be developed as part of the site-specific safety and health program. The program addresses at a minimum the following: a. Pre-emergency planning and coordination with outside parties, b. Personnel roles, lines of authority, training, and communication, c. Emergency recognition and prevention, d. Safe distances and places of refuge, e. Site security and control, f. Evacuation routes and procedures, g. Decontamination, h. Emergency medical treatment, i. Emergency alerting and response procedures, j. Critiques and response follow-up, k. Personal protective equipment and emergency equipment, l. Use of local or state emergency plans to avoid duplications. 2. When an emergency arises the Project Manager shall institute the Incident Command System and develop a site-specific safety plan in accordance with the attachment to this written plan. This will ensure that all of the above elements have been covered. 3. Additionally, the “Senior Official”, or Project Manager will ensure: a. Proper PPE is being Selected and worn based on the hazards. Supplied air respirators required for emergency response were inhalation hazards are known or suspected. b. Limit access to response area by emergency responders and ensure the “buddy system” is utilized. 235

c. Back up personnel are available for rescue and provision of advanced first aid and medical support. d. An individual will be assigned as a safety official to monitor operation and predict and identify recognized hazards. e. Operations are altered, modified, or terminated when an IDLH condition is identified to protect all associated personnel. f. Implement appropriate decontamination procedures g. Ensure post emergency response activities are completed such as proper containment, transportation, and disposal of materials, as well as a critique of the effectiveness of containment, control, and mitigation of releases. h. All containerized or controlled materials shall be disposed of in accordance with 40 CFR 260-268 (RCRA) and state and local regulations. SUBCONTRACTOR SAFETY 1. Because we frequently use subcontractors for hazardous waste operation work, we always inform them of the site emergency response procedures and any potential fire, explosion, health, safety, or other hazards of the operation. 2. We routinely make the written safety and health program available to any contractor who will be involved with the hazardous waste operation. 3. Subcontractors must meet all requirements outlined in the Minger Construction Co., Inc. Safety Manual. MEDICAL SURVEILLANCE AND RECORD KEEPING 1. All affected employees, shall have appropriate medical surveillance in accordance with 29 CFR 1910.120(f) if the employees: a. Experience signs/symptoms of possible overexposure to hazardous substances. b. Wear a respirator or are a member of the Hazmat team. c. May be exposed above established exposure levels 30 days or more in a year. 2. Medical surveillance shall be: 1. Provided prior to assignment. 2. Conducted on an annual basis at a minimum (more frequent if recommended). 3. Conducted upon termination of employment. 4. Provided as soon as possible upon development of signs or symptoms. 3. Employee medical records concern the health status of an employee and are made or maintained by a physician, nurse or other healthcare professional. 4. Medical surveillance records and exposure monitoring records shall be available for review by employees, assigned representatives, or OSHA at a reasonable time, place and manner. 5. Medical surveillance records shall be maintained for the period of employment plus 30 years. The exposure records will include both environmental and/or biological monitoring. The employee shall be notified of the record keeping provision upon assignment and annually thereafter. 6. If Minger Construction Co., Inc. were to terminate business activities, records will be transferred to the successor employer. If there is no successor employer or the employer intends to destroy records, the employer shall notify effected current employees three months prior to cessation of the business. 236

7. Exposure records will be maintained for a minimum of 30 years. 8. Employees will be trained on the provision of record keeping upon initial assignment and annually thereafter. 9. Personal Identifiers will be removed before access is granted. 10. This program is provided at no cost to the employees. 237

SECTION 34 DEMOLITION PROGRAM 238

SECTION 34: DEMOLITION PROGRAM 29 CFR 1926 Subpart T GENERAL 1. Post all proper permits before any demolition work begins. 2. Meet all applicable EPA requirements. 3. A thorough pre-project/pre-task meeting must be conducted prior to the start of any demolition. 4. If the demolition is or can affect any existing operation, a disruption avoidance plan should be created and implemented. 5. Ensure that the subcontractor responsible for the asbestos abatement contract carries the required insurance. SURVEYS 1. Before starting any demolition operations, an engineering survey of the structure shall be made by a Competent Person to determine: a. The condition of the framing, floors, walls, and any adjacent structures employees will be exposed to. b. Whether there is a possibility of an unplanned collapse of any portions of the structure. c. Note: Request the as-built from the owner. d. Document all surveys and forward a copy of the survey records to the Safety Department for review and filing. STRUCTURE Brace or shore the walls or floors of a structure that has been damaged and is scheduled for demolition when employees are required to work within it. 1. UTILITIES a. Carefully control all utilities. Before work begins: 1. Shut off, cap, or otherwise control all utilities 2. Notify all utility companies involved 3. Locate all lines, using all possible means 4. Check the building to determine where the existing utilities enter the building. 5. Follow Minger Construction Co., Inc.’s Lock Out-Tag Out Program. b. If temporary utilities are required during demolition, protect those utilities from damage and conduct a documented inspection on a daily basis. A temporary utilities inspection will be conducted once a week by the Superintendent, and at the start of the demolition phase of the work. 239

2. INSPECTIONS a. Before the actual demolition begins, the owner, Project Manager, Superintendent, and Foreman shall perform a documented inspection to identify any existing hazards (e.g., chemicals, gases, explosives, asbestos, or flammable materials used in any of the pipes, tanks, or other equipment used on the property). b. If any hazardous material is located or suspected, it must be controlled and rechecked before work begins. 3. FLOOR OPENINGS a. Cover or corral all floor openings 2 inches or greater, then install guardrails. b. Note: If a cover is used, secure it in a way that prevents a person from removing it without some effort. c. Then mark it “Danger - - Hole” in all languages used on the project. 4. STAIRWAYS a. Stairways which are not being used must be completely barricaded, closed, and marked “Danger - - Stairway Closed” in all languages used on the project. b. Stairways which are being used, but will be demolished, must be marked with a notice posted one week before the demolition stating “This stairway will be demolished on this date.” c. After the stairway is demolished, the stairway will be blocked completely and marked “Danger - - Stairway Demolished - Use alternate stairway.” 5. HOT WORK PERMIT procedure should be implemented if the threat of fire exists. 6. CHUTES a. All material dumping areas must be marked and protected. b. Must be used for disposal of debris in excess of 20 feet. c. All chutes over 45° must be completely enclosed except for the opening used for dumping material. d. The opening used for dumping material must not exceed 48” in height and must be closed when not in use. (A chain will suffice.) e. There must be a way to close off the discharge end. f. The area around the discharge end must be closed off. g. Any opening in a floor used for debris removal must be inspected to ensure that the support structures have not been damaged. 7. GENERAL SAFETY a. Enforce all fall protection requirements at all times. b. Protect all employee entrances out to at least eight feet and provide a cover capable of sustaining a load of 150 pounds per square foot. All entrances must have a sign and a controlled access zone to direct the traffic flow. c. Protect to the maximum possible level all possible interfaces with the public. d. Follow proper removal procedures when removing debris from the building. 240

29 CFR 1926 Subpart T 1926.850 – PREPARATORY OPERATIONS 1. 1926.850(a) - Prior to permitting employees to start demolition operations, an engineering survey shall be made, by a competent person, of the structure to determine the condition of the framing, floors, and walls, and possibility of unplanned collapse of any portion of the structure. Any adjacent structure where employees may be exposed shall also be similarly checked. The employer shall have in writing evidence that such a survey has been performed. 2. 1926.850(b) - When employees are required to work within a structure to be demolished which has been damaged by fire, flood, explosion, or other cause, the walls or floor shall be shored or braced. 3. 1926.850(c) - All electric, gas, water, steam, sewer, and other service lines shall be shut off, capped, or otherwise controlled, outside the building line before demolition work is started. In each case, any utility company which is involved shall be notified in advance. 4. 1926.850(d) - If it is necessary to maintain any power, water or other utilities during demolition, such lines shall be temporarily relocated, as necessary, and protected. 5. 1926.850(e) - It shall also be determined if any type of hazardous chemicals, gases, explosives, flammable materials, or similarly dangerous substances have been used in any pipes, tanks, or other equipment on the property. When the presence of any such substances is apparent or suspected, testing and purging shall be performed and the hazard eliminated before demolition is started. 6. 1926.850(f) - Where a hazard exists from fragmentation of glass, such hazards shall be removed. 7. 1926.850(g) - Where a hazard exists to employees falling through wall openings, the opening shall be protected to a height of approximately 42 inches. 8. 1926.850(h) - When debris is dropped through holes in the floor without the use of chutes, the area onto which the material is dropped shall be completely enclosed with barricades not less than 42 inches high and not less than 6 feet back from the projected edge of the opening above. Signs, warning of the hazard of falling materials, shall be posted at each level. Removal shall not be permitted in this lower area until debris handling ceases above. 9. 1926.850(i) - All floor openings, not used as material drops, shall be covered over with material substantial enough to support the weight of any load which may be imposed. Such material shall be properly secured to prevent its accidental movement. 10. 1926.850(j) - Except for the cutting of holes in floors for chutes, holes through which to drop materials, preparation of storage space, and similar necessary preparatory work, the demolition of exterior walls and floor construction shall begin at the top of the structure and proceed downward. Each story of exterior wall and floor construction shall be removed and dropped into the storage space before commencing the removal of exterior walls and floors in the story next below. 11. 1926.850(k) - Employee entrances to multistory structures being demolished shall be completely protected by sidewalk sheds or canopies, or both, providing protection from the face of the building for a minimum of 8 feet. All such canopies shall be at least 2 feet wider than the building entrances or openings (1 foot wider on each side thereof), and shall be capable of sustaining a load of 150 pounds per square foot. 241

1926.851- STAIRS, PASSAGEWAYS, AND LADDERS 1. 1926.851(a) - Only those stairways, passageways, and ladders, designated as means of access to the structure of a building, shall be used. Other access ways shall be entirely closed at all times. 2. 1926.851(b) - All stairs, passageways, ladders and incidental equipment thereto, which are covered by this section, shall be periodically inspected and maintained in a clean safe condition. 3. 1926.851(c) - In a multistory building, when a stairwell is being used, it shall be properly illuminated by either natural or artificial means, and completely and substantially covered over at a point not less than two floors below the floor on which work is being performed, and access to the floor where the work is in progress shall be through a properly lighted, protected, and separate passageway. 1926.853 – REMOVAL OF MATERIALS THROUGH FLOOR OPENINGS 1. 1926.853- Any openings cut in a floor for the disposal of materials shall be no larger in size than 25 percent of the aggregate of the total floor area, unless the lateral supports of the removed flooring remain in place. Floors weakened or otherwise made unsafe by demolition operations shall be shored to carry safely the intended imposed load from demolition operations. 242

1926.854 – REMOVAL OF WALLS, MASONRY SECTIONS, AND CHIMNEYS 1. 1926.854(a) - Masonry walls, or other sections of masonry, shall not be permitted to fall upon the floors of the building in such masses as to exceed the safe carrying capacities of the floors. 2. 1926.854(b) - No wall section, which is more than one story in height, shall be permitted to stand alone without lateral bracing, unless such wall was originally designed and constructed to stand without such lateral support, and is in a condition safe enough to be self-supporting. All walls shall be left in a stable condition at the end of each shift. 3. 1926.854(c) - Employees shall not be permitted to work on the top of a wall when weather conditions constitute a hazard. 4. 1926.854(d) - Structural or load-supporting members on any floor shall not be cut or removed until all stories above such a floor have been demolished and removed. This provision shall not prohibit the cutting of floor beams for the disposal of materials or for the installation of equipment, provided that the requirements of 1926.853 and 1926.855 are met. 5. 1926.854(e) - Floor openings within 10 feet of any wall being demolished shall be planked solid, except when employees are kept out of the area below. 6. 1926.854(f) - In buildings of \"skeleton-steel\" construction, the steel framing may be left in place during the demolition of masonry. Where this is done, all steel beams, girders, and similar structural supports shall be cleared of all loose material as the masonry demolition progresses downward. 7. 1926.854(g) - Walkways or ladders shall be provided to enable employees to safely reach or leave any scaffold or wall. 8. 1926.854(h) - Walls, which serve as retaining walls to support earth or adjoining structures, shall not be demolished until such earth has been properly braced or adjoining structures have been properly underpinned. 9. 1926.854(i) - Walls, which are to serve as retaining walls against which debris will be piled, shall not be so used unless capable of safely supporting the imposed load. 1926.855 – MANUAL REMOVAL OF FLOORS 1. 1926.855(a) - Openings cut in a floor shall extend the full span of the arch between supports. 2. 1926.855(b) - Before demolishing any floor arch, debris and other material shall be removed from such arch and other adjacent floor area. Planks not less than 2 inches by 10 inches in cross section, full size undressed, shall be provided for, and shall be used by employees to stand on while breaking down floor arches between beams. Such planks shall be so located as to provide a safe support for the workmen should the arch between the beams collapse. The open space between planks shall not exceed 16 inches. 3. 1926.855(c) - Safe walkways, not less than 18 inches wide, formed of planks not less than 2 inches thick if wood, or of equivalent strength if metal, shall be provided and used by workmen when necessary to enable them to reach any point without walking upon exposed beams. 4. 1926.855(d) - Stringers of ample strength shall be installed to support the flooring planks, and the ends of such stringers shall be supported by floor beams or girders, and not by floor arches alone. 243

5. 1926.855(e) - Planks shall be laid together over solid bearings with the ends overlapping at least 1 foot. 6. 1926.855(f) - When floor arches are being removed, employees shall not be allowed in the area directly underneath, and such an area shall be barricaded to prevent access to it. 7. 1926.855(g) - Demolition of floor arches shall not be started until they, and the surrounding floor area for a distance of 20 feet, have been cleared of debris and any other unnecessary materials. 1926.856 – REMOVAL OF WALLS, FLOORS, AND MATERIAL WITH EQUIPMENT 1. 1926.856(a) - Mechanical equipment shall not be used on floors or working surfaces unless such floors or surfaces are of sufficient strength to support the imposed load. 2. 1926.856(b) - Floor openings shall have curbs or stop-logs to prevent equipment from running over the edge. 3. 1926.856(c) - Mechanical equipment used shall meet the requirements specified in Subparts N and O of this part. 1926.857 - STORAGE 1. 1926.857(a) - The storage of waste material and debris on any floor shall not exceed the allowable floor loads. 2. 1926.857(b) - In buildings having wooden floor construction, the flooring boards may be removed from not more than one floor above grade to provide storage space for debris, provided falling material is not permitted to endanger the stability of the structure. 3. 1926.857(c) - When wood floor beams serve to brace interior walls or free-standing exterior walls, such beams shall be left in place until other equivalent support can be installed to replace them. 4. 1926.857(d) - Floor arches, to an elevation of not more than 25 feet above grade, may be removed to provide storage area for debris: Provided, That such removal does not endanger the stability of the structure. 5. 1926.857(e) - Storage space into which material is dumped shall be blocked off, except for openings necessary for the removal of material. Such openings shall be kept closed at all times when material is not being removed. 1926.858 – REMOVAL OF STEEL CONSTRUCTION 1. 1926.858(a) - When floor arches have been removed, planking in accordance with 1926.855(b) shall be provided for the workers engaged in razing the steel framing. 2. 1926.858(b) - Cranes, derricks, and other hoisting equipment used shall meet the requirements specified in Subpart N of this part. 3. 1926.858(c) - Steel construction shall be dismantled column length by column length, and tier by tier (columns may be in two-story lengths). 4. 1926.858(d) - Any structural member being dismembered shall not be overstressed. 1926.859 – MECHANICAL DEMOLITION 1. 1926.859(a) - No workers shall be permitted in any area, which can be adversely affected by demolition operations, when balling or clamming is being performed. Only those workers necessary for the performance of the operations shall be permitted in this area at any other time. 244

2. 1926.859(b) - The weight of the demolition ball shall not exceed 50 percent of the crane's rated load, based on the length of the boom and the maximum angle of operation at which the demolition ball will be used, or it shall not exceed 25 percent of the nominal breaking strength of the line by which it is suspended, whichever results in a lesser value. 3. 1926.859(c) - The crane boom and load line shall be as short as possible. 4. 1926.859(d) - The ball shall be attached to the load line with a swivel-type connection to prevent twisting of the load line, and shall be attached by positive means in such manner that the weight cannot become accidentally disconnected. 5. 1926.859(e) - When pulling over walls or portions thereof, all steel members affected shall have been previously cut free. 6. 1926.859(f) - All roof cornices or other such ornamental stonework shall be removed prior to pulling walls over. 7. 1926.859(g) - During demolition, continuing inspections by a competent person shall be made as the work progresses to detect hazards resulting from weakened or deteriorated floors, or walls, or loosened material. No employee shall be permitted to work where such hazards exist until they are corrected by shoring, bracing, or other effective means. 1926.860 – SELECTIVE DEMOLITION BY EXPLOSIVES 1. 1926.860 - Selective demolition by explosives shall be conducted in accordance with the applicable sections of Subpart U of this part. 245

SECTION 35 BENZENE – CHEMICAL EXPOSURE PROGRAM 246

SECTION 35: BENZENE – CHEMICAL EXPOSURE PROGRAM GENERAL Benzene, a liquid found in most crude oil and condensate, can also be found in produced gas in a gaseous form, Benzene is known to cause cancer in humans, so it is important that employees limit their exposure to it. Benzene is a clear, colorless liquid with a pleasant, sweet odor, is not soluble in water, and is flammable. The odor of benzene alone does not provide adequate warning of its hazard. Benzene is highly flammable and is heavier than air, which allows it to travel along the ground and potentially be ignited by open flames or sparks in areas remote from the site in which you are working. HEALTH EFFECTS 1. Benzene can affect your health if you inhale it, absorb it through skin contact, or ingest (swallow) it. 2. Effects of short term (acute) overexposure may be: feeling breathless, irritable, euphoric, or giddy; you may experience irritation in eyes, nose, and respiratory tract. Also, you may develop a headache, feel dizzy, nauseated, or intoxicated. Severe exposure could also lead to convulsions and loss of consciousness. 3. Effects of long term (chronic) overexposure may result in various blood disorders such as anemia and leukemia. Many blood disorders associated with benzene exposures occur without symptoms. 4. All Benzene by-products should be considered toxic and the same level of care should be practiced when working around or handling these materials. Always refer to the MSDS for the product or material stream you may handle. TOXICITY/EXPOSURE LIMITS 1. The maximum time-weighted average (TWA) exposure limit is 1 part of benzene vapor per million part of air (1 ppm) for an 8-hour workday. The maximum short-term exposure limit (STEL) is 5 ppm for any 15-minute period. 2. Always prevent eye and skin contact with liquid Benzene. CONTROLS 1. The Host Company is responsible for identifying areas where Benzene containing materials exist and for informing the contactor of these locations. This area is usually demarcated by the use of specific-worded signs or colored barricade tape. Minger Construction will inform its employees and subcontractors of the location of potential Benzene exposures. These areas will be regulated. Access to these sites will be limited to authorized personnel who have been provided with appropriate levels of personal protective equipment and training. 2. Determination of employee exposure will be made from breathing zone air samples that are representative of each employee’s average exposure to airborne benzene. 247

Representative 8-hour TWA exposures shall be determined on the basis of one sample or samples representing the full shift for each job classification in each different work area. 3. All compliance checks, initial monitoring, periodic monitoring, additional monitoring, and monitoring termination will be performed in conformance with the industry standards set forth by OSAH and NIOSH. 4. Employees are protected from Benzene exposure by the use of various engineering and work practice controls established by the host facility operator and the certified specialty contractor. This plant will be developed prior to shiftwork and will be reviewed and revised prior to each shift based on the most recent exposure monitoring data. 5. Benzene is highly flammable and its vapors may form explosive mixtures in air. Fire extinguishers must be readily available for use. Smoking is prohibited in areas where Benzene is present. 6. Safe work practices will be instituted which could consist of but are not limited to: product line removal, blinding, blanking, draining, cleaning, steaming, purging, high- pressure washing, or neutralizing. Safe-work procedures such as lockout/tagout, hot- work, or confined space entry are implemented to further control exposure potentials. Always don appropriate PPE before commencing work. 7. Benzene will be stored in approved containers in a vented flammable storage cabinet. PERSONAL PROTECTIVE EQUIPMENT 1. Respiratory Protection: whenever the engineering and work practice controls are deemed ineffective at reducing exposure potentials, then respiratory protection will be provided in accordance with the Respirator Protection Program. These requirements will meet or exceeds industry standards set forth by OSHA Regulation 29 CFR 1910.134. Selected respirators will be approved by NIOSH. This equipment will be provided to employees at no cost. 2. PPE will be worn where appropriate to prevent eye contact and dermal (skin) exposure to liquid Benzene. Affected employees will refer to the PPE Program found in this manual for proper PPE requirements. These requirements will meet or exceed the standards set forth by OSHA Regulation 29 CFR 1910.133. Employees will also comply with any host facilities’ PPE rules and regulation. This equipment will be provided to employees at no cost. It can be expected that one or more of the following combinations of equipment will be necessary: a. ANSI Z87.1 Safety Glasses with side shields. b. Chemical splash-proof goggles. c. Full face-shield. d. Chemical / hydrocarbon-resistant body coverings (suit, gloves, boots, Etc…) MEDICAL SURVEILLANCE 1. The company recognizes that some employees might be exposed to Benzene levels that could exceed permissible exposure levels. A medical surveillance program will be established based on the following guidelines. 2. In the event employees are or may be exposed to Benzene at or above the action level of .5 ppm for 30 or more days per year. 3. In the event employees are exposed to a PEL (1 ppm) or greater for 10 or more days per year. 248

4. For employees who have been exposed to more than 10 ppm of Benzene for 30 or more days in a year prior to the effective date of the standard when employed by a former employer. 5. The company will assure that all medical examinations are performed by a licensed physician and that all laboratory tests are conducted by an accredited laboratory. 6. All examinations and procedures are provided at o cost to the employee at a reasonable time and place. 7. The company will provide each affected employee with a medical examination including the following: a. A detailed occupational history. b. A complete physical examination. c. Laboratory tests. d. Any necessary additional tests needed by the physician. e. A pulmonary function test for employees using respirators 30 days or more per year. 249

SECTION 36 HYDROGEN SULFIDE (H2S) AWARENESS 250