PERSONAL PROTECTIVE EQUIPMENT POLICY

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PERSONAL PROTECTIVE EQUIPMENT POLICY This written program documents steps Northern Clearing, Inc. has taken to minimize injury resulting from various occupational hazards present at our field jobs and Corporate Headquarters by protecting workers through the use of Personal Protective Equipment (PPE) when the hazards cannot be eliminated. Northern Clearing, Inc. has developed a written PPE program to document and specify all information relative to our PPE needs, based on 29 CFR 1910.132-140 (Subpart 1.) The Health and Safety Director is the program coordinator, acting as the representative of the President who has overall responsibility for the program. The Health and Safety Director will designate appropriate Company Supervisors to assist in training employees and monitoring their use of PPE. The Health and Safety Director, working in conjunction with Northern Clearing, Inc.’s Supervisors, will review and update the program as necessary. Copies of this program may be obtained from the Personnel Administrator in the Corporate Headquarters. Northern Clearing, Inc. believes it is our obligation to provide a hazard free environment to our employees. Any employee encountering hazardous conditions must be protected against the potential hazards. The purpose of protective clothing and equipment (PPE) is to shield or isolate individuals from chemical, physical, biological, or other hazards that may be present in the workplace. (See separate Chapter on Noise, found in this manual). Northern Clearing, Inc.’s PPE program covers: • Purpose • Hazard • PPE selection • Employee training • Cleaning and maintenance of PPE • PPE specific information If after reading this program, you find that improvements can be made, please contact The Health and Safety Director. Northern Clearing, Inc. encourages all suggestions because we are committed to the success of our Health and Safety Program, and strive for clear understanding, safe behavior, and involvement in the program from every level of the Company. The basic element of any PPE program is an in depth evaluation of the equipment needed to protect against the hazards at the workplace; this is the initial hazard assessment for which written documentation is required. Two basic objectives of any PPE program should be to protect the wearer from incorrect use and/or malfunction of PPE. The purpose of this Personal Protective Equipment (PPE) Program is to document the hazard assessment, protective measures in place, and PPE in use at this Company. PPE devices are not being relied on as the only means to provide protection against hazards, but are used in conjunction with guards, engineering controls, and sound manufacturing 2

practices. If possible, hazards will be abated first through engineering controls, with PPE to provide protection against hazards that cannot reasonably be abated otherwise. HAZARD ASSESSMENT In order to assess the need for PPE the following steps are taken: 1. The Safety Superintendent, with other appropriate employees such as Supervisors, identifies job classifications where exposures occur or could occur. The Supervisors examine the following records to identify and rank jobs according to exposure hazards: • Injury/illness records • First aid logs • Worker’s Compensation records 2. The Safety Superintendent conducts a walk through survey of workplace areas where hazards exist or may exist to identify sources of hazards to employees, using the Hazard Assessment Form found in Appendix A. They consider these basic hazard categories: • Impact • Heat • Penetration • Harmful dust • Compression (roll over) • Light (optical) radiation • Chemical During the walk through survey the Health and Safety Director observes and records the following hazards along with PPE currently in use • Sources of motion; i.e., machinery or processes where any movement of tools, machine elements or particles could exist, or movement of personnel that could result in collision with stationary objects, such as any mobile equipment. •

Sources of high temperatures that could result in burns, eye injury or ignition of protective equipment, etc., are chain saws, and hydraulic/engine oil.



Types of chemical exposures are lubricants, spray paint, flammable/welding gases, and solvents. These are listed in the Hazard Communication Chapter, as well.



Sources of harmful dust are grinding, sand blasting, and digging equipment.



Sources of light radiation are arc welding and sunlight.



Sources of falling objects or potential for dropping objects include overhead cranes, mobile cranes, side boom tractors, excavators, mechanic rigs, loaders, ASV’s, and dump trucks.



Sources of sharp objects, which might pierce the feet or cut the hands include knives, saws, drill bits, nails, barbed wire, rakes and drag mats.

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Sources of rolling or pinching objects which could crush the feet include possible dropped loads, plus tires and treads.



Northern Clearing, Inc. has identified any electrical hazards, and these are mentioned in the Electrical section of this manual.

3. Following the walk through survey, the Health and Safety Director or assistants organize the data and information for use in assessment of hazards to analyze the hazards and enable proper selection of protective equipment. 4. An estimate of the potential for injuries is now made. Each of the basic hazards is reviewed and a determination made as to the frequency, type, level of risk, and seriousness of potential injury from each of the hazards found. The existence of any situations where multiple exposures occur or could occur are considered.

5. The Health and Safety Director documents the hazard assessment via a written certification that identifies the workplace evaluated, the person certifying that the evaluation has been performed, the date(s) of the hazard assessment, and that the document is a certification of hazard assessment. SELECTION GUIDELINES Once any hazards have been identified and evaluated through hazard assessment, the general procedure for selecting protective equipment is to: 1. Become familiar with the potential hazards and the type of protective equipment (PPE) that are available, and what they can do. 2. Compare types of equipment to the hazards associated with the environment. 3. Select the PPE that ensures a level of protection greater than the minimum required to protect employees from the hazards. 4. Fit the user with proper, comfortable, well fitting protection and instruct employees on care and use of the PPE. It is very important that users are aware of all warning labels for and limitations of their PPE. (See the Employee Training guidelines outlined in the next section of this program for a more detailed description of training procedures.) It is the responsibility of the Health and Safety Director and Supervisors to reassess the workplace hazard situation as necessary, to identify and evaluate new equipment and processes, to review accident records, and reevaluate the suitability of previously selected PPE. This reassessment will take place as needed, but at least weekly. For employeeowned equipment, they will also ensure that the equipment is adequate for the hazard, and is kept in a properly maintained and sanitary condition. Elements, which should be considered in the reassessment, include: • Adequacy of PPE program • Accidents and illness experience • Levels of exposure (this implies appropriate exposure monitoring) • Adequacy of equipment selection • Number of person hours that workers wear various protective ensembles 4

• • • • •

Adequacy of training/fitting of PPE Program costs The adequacy of program records Recommendation for program improvement and modification Coordination with overall safety and health program EMPLOYEE TRAINING

The Health and Safety Director provides training for each employee who is required to use personal protective equipment. Training includes: *When PPE is necessary *What PPE is necessary *How to wear assigned PPE, including donning and doffing *Limitations of PPE *The proper care, maintenance, useful life, and disposal of assigned PPE Employees must demonstrate an understanding of the training and the ability to use the PPE properly before they are allowed to perform work requiring the use of the equipment, and sign a training sheet located in Appendix A. Employees are prohibited from performing work without donning appropriate PPE to protect them from the hazards they will encounter in the course of that work. If the Health and Safety Director or Supervisor has reason to believe an employee does not have the understanding or skill required, the employee must be retrained. Since an employee’s supervisor is in the best position to observe any problems with PPE use by individual employees, the Safety department will work with this person’s input when making this retraining determination. Circumstances where retraining may be required include changes in the workplace or changes in the types of PPE to be used which would render previous training obsolete. Also, inadequacies in an affected employee’s knowledge or use of the assigned PPE, which indicates that the employee has not retained the necessary understanding or skills. The Health and Safety Director certifies in writing that the employee has received and understands the PPE training; the form is located in Appendix A. Because failure to comply with Company policy concerning PPE can result in OSHA citations and fines as well as employee injury, an employee who does not comply with this program will be disciplined for noncompliance according to the following schedule: 1. Verbal warning 2. Written warning 3. Dismissal CLEANING AND MAINTENANCE

It is important that all PPE be kept clean and properly maintained by the employee to whom it is assigned. Cleaning is particularly important for eye and face protection where dirty or fogged lenses could impair vision. PPE is to be inspected, cleaned, and maintained by employees at regular intervals as part of their normal job duties so that the 5

PPE provides the requisite protection. Supervisors are responsible for ensuring compliance with cleaning responsibilities by employees. If PPE is for general use, the Purchasing Manager has responsibility for cleaning and maintenance. If a piece of PPE is in need of repair or replacement it is the responsibility of the employee to bring it to the immediate attention of his or her supervisor or the Purchasing Manager. It is against work rules to use PPE that is in disrepair or not able to perform its intended function. Contaminated PPE, which cannot be decontaminated, is disposed of in a manner that protects employees from exposure to hazards. Supervisors are also responsible to ensure proper maintenance and care of employee-owned equipment. PPE SPECIFIC INFORMATION EYE AND FACE PROTECTION – SAFETY GLASSES, GOGGLES AND FACE SHIELDS

It is the policy of the Company that as a condition of employment, all regular full time, part time, and temporary employees working in designated work areas and/or job assignments are required to wear ANSI approved safety glasses/goggles/face shields. These are designed to help prevent eye and face injuries, including those resulting from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or light radiation. Employees that conduct grinding are required to wear goggles/face shields, to protect against flying slag, as well as any other foreign objects. We use Crews brand of safety glasses. All employees required to wear safety glasses must routinely inspect and properly care for their eye protection. FOOT PROTECTION – SAFETY SHOES

It is the policy of Northern Clearing, Inc. that safety footwear is recommended and required when the Client requires this type of footwear. Employees from temporary work agencies and contractors are encouraged to wear safety shoes/boots if assigned to work in the designated work areas. It is the responsibility of the agency and/or contractor to ensure that the employee reports to his/her temporary assignment at Northern Clearing, Inc. wearing approved safety shoes. Those employees who work in non-designated areas of the Company and vendors and visitors will be allowed to walk through the designated work areas without safety shoes as long as they remain in outlined aisles or walkways. All Supervisors and Managers are responsible for ensuring their personnel are in compliance with this policy. They are also responsible for informing new employees who are assigned to the designated work areas of the safety shoe policy and the procedures for obtaining them. The new employee is responsible for reporting to his/her first day of work wearing approved safety shoes, where required. HAND PROTECTION – GLOVES

It is the policy of Northern Clearing, Inc. that as a condition of employment, all regular full time, part time, and temporary employees working in designated work areas and/or job assignments are required to wear gloves to help prevent hand injuries, including cuts, burns, and chemical exposure; for example abrasions, splinters, welding, solvents, greases and paint.

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Employees in the field and other work areas are required to wear protective gloves where necessary. Cotton, leather, and rubber gloves must routinely inspect and properly care for their assigned gloves. HEAD PROTECTION – HARD HATS

It is the policy of the Company that as a condition of employment, all regular full time, part time, and temporary employees working in designated work areas and/or job assignments are required to wear ANSI approved hard hats to help prevent head injuries, including those resulting from falling objects, bumping the head against a fixed object, or electrical shock. Employees in all areas outside the Corporate Offices encouraged to wear plastic hard hats. All employees required to wear hard hats must routinely inspect and properly care for their hard hats. Employees from temporary work agencies and contractors are required to wear goggles/face shields, hand protection, foot protection, head protection, or any other form of PPE if assigned to work in the designated work areas. These employees are responsible for providing their own PPE. Respiratory protection, if necessary, is covered in a specific chapter in this manual that addresses respirators and program-specific information. All Supervisors and Managers are responsible for ensuring employees under their charge are in compliance with this policy. In addition, they are also responsible for ensuring that the PPE is maintained in a clean, sanitary, and functioning unit, including employeeowned equipment. All employees who work in designated work areas and/or job assignments are responsible for wearing Company provided goggles/face shields to comply with this policy. Failure to comply will result in disciplinary action up to and including discharge.

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APPENDIX A

PPE ASSESSMENT AND CERTIFICATION FORMS

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PPE ASSESSMENT According to OSHA estimates, the revised PPE standards will provide improved protection in 1.1 million workplaces with 11.7 million employees, preventing four deaths and saving 712,000 lost workdays annually. The new standards are more consistent with today’s industry practices, as reflected by the latest American National Standards Institute (ANSI) standards. These standards were revised: *29 CFR 1910.132 General Requirements *29 CFR 1910.133 Eye and Face Protection *29 CFR 1910.135 Head Protection *29 CFR 1910.136 Foot Protection Also, 29 CFR 1910.138 Hand Protection was added as a new standard. (The 1998 Respiratory Protection Standard – 29 CFR 1910.134 – is covered elsewhere in this book). The general requirements section still requires the employer to be responsible for providing PPE wherever it is necessary to mitigate the risk of injury to employees on the job. However, there were two new significant additions to this section. An employer is now required to select PPE for their employees based on an assessment of the hazards in the workplace. The hazard assessment requirement makes the employer responsible for the quality of the hazard assessment as well as the adequacy of the PPE assigned to the employees. Proof of compliance with the hazard assessment requirements is verified through written certification, which at a minimum must include the workplace evaluated, the person who conducted the evaluation, and the date(s) of the hazard assessment. The second significant addition to the General Requirements requires the training of employees in the proper use of the assigned PPE. The hazard assessment and training requirement currently pertain only to four of the above specific PPE standards: eye and face protection, head protection, foot protection, and hand protection. The hazard assessment and training requirements, 29 CFR 1910.132 (d) and (f), currently did not apply to the Respiratory Protection standard, 29 CFR 1910.134, or the Electrical Protective Equipment standard, 29 CFR 1910.137. However, the 1998 revisions to the Respiratory Protection standard now require assessments, evaluations and training. The following information is designed to assist employers in complying with the general requirements standard, specifically hazard assessments and employee training. GUIDELINES FOR HAZARD ASSESSMENTS Each employer is responsible for assessing the workplace to determine whether foot, head, eye and face, or hand hazards exist in occupational and educational operations and processes. Based on the determination made during the assessment, appropriate protective devices for particular hazards are selected. The hazard assessment involves conducting a walk-through survey of the area in question or an evaluation of the tasks conducted within a particular work area(s). Consideration should be given to the basic hazard categories, such as: impact, penetration, compression, chemical, heat, dust and particulates, and light (optical) radiation. During the survey, observe these items to determine whether problem areas exist: *Sources of motion (movement of tools, machinery, or personnel) *Sources of high temperatures *Sources of chemical exposures *Sources of dusts and particulates *Sources of light radiation (from welding, brazing, cutting, furnaces, heat treating) *Sources of falling/dropping objects *Sharp objects that can pierce or penetrate *Rolling or pinching objects *Layout of the work area and location of workers *Sources of electrical hazards.

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Data and information obtained in the survey must be organized and analyzed to ascertain the hazards and assist in the selection of PPE. Use a hazard assessment form to facilitate this process. HAZARD ASSESSMENT FORMS This form is broken down into three sections. The first section identifies the areas of the body potentially affected by various hazards. A section on respiratory hazard identification has been added to the form, although as stated previously, 29 CFR 1910.132 (g) does not require respiratory hazards to be evaluated under this standard. It will be up to the discretion of the surveyor whether to evaluate respiratory hazards on the form. The surveyor checks off the appropriate hazards identified for each area of the body. The second section requires the surveyor to describe specific tasks or materials that are causing a potential hazard. The third section provides an area to identify the PPE the surveyor has deemed necessary. The PPE determination is based on the surveyor’s familiarity with the hazards identified in sections 1 and 2, the type of PPE available, and what it can do. The PPE selected should ensure a level of protection greater than the minimum required to protect employees from the hazards. Once the PPE has been identified for a work area or task, it is the responsibility of the employer to ensure consideration is given to comfort and fit. Some devices come with adjustable features. Particular care should be taken in fitting devices for eye protection against dust and chemical splashes to ensure the devices seal against the face. Proper fitting of helmets is also important to ensure the helmet won’t fall off during work operations. Selection guidelines for PPE are provided in the Appendices below (for eye and face protection in Appendices A and B, hand protection in Appendix C and respiratory protection in Appendix D). For head protection, see ANSI Z89.1-1986; for foot protection, see ANSI Z41.1-1991. PPE should be inspected, cleaned, and maintained at regular intervals by the employee so it will provide the necessary protection. PPE that cannot be decontaminated should be disposed of, and the employee issued new equipment. It is the employer’s responsibility to reassess the workplace hazards situation as needed by identifying and evaluating new processes, equipment, chemicals, and the effectiveness of the PPE previously assigned to the employees. Accident records are a source to use in this reevaluation.

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WORKPLACE HAZARD ASSESSMENT FORM Facility:_____________________________ Assessor:___________________________________ Area:________________ Task or Job Function:______________ Date of Assessment:_________________ I,___________________________________(Name) certify that the evaluation of_____________(facility). The identified work areas assessments were conducted on _____________________(Date)

SECTION 1. Hazards (Check the appropriate box)

Yes

No

SECTION 2. Describe Specific Hazards

SECTION 3. Identify type of PPE required for those hazards delineated in Sec. 2. (See Appendices A & B for eye and face protection chart.)

Yes

No

SECTION 2. Describe Specific Hazards

SECTION 3. Identify type of PPE required for hazards delineated in Sec. 2 Check one. (Consult ANSI Z89.1 – 1986.) No head protection is needed Class A Class B Class C Class C

Yes

No

SECTION 2. Describe Specific Hazards

SECTION 3. Identify type of PPE required for hazards delineated in Sec. 2. Check One. (Consult ANSI Z41.1-1991)

Yes

No

SECTION 2. Describe Specific Hazards

SECTION 3. Identify type of PPE required for hazards delineated in Section 2; Refer to Appendix C.

EYE HAZARD (29 CFR 1910.133) Impact Penetration Chemical Heat Light/Radiation SECTION 1. Hazards (Check the appropriate box)

HEAD HAZARD Burn Electric Shock Impact Penetration Chemical SECTION 1. Hazards (Check the appropriate box)

FOOT HAZARD (29 CFR 1910.136) Chemical Compression Impact Penetration Puncture SECTION 1. Hazards (Check the appropriate box) HAND HAZARD (29 CFR 1910.136) Burn Electric Shock Impact Penetration Chemical

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WORKPLACE HAZARD ASSESSMENT FORM (CONTD.)

SECTION 1. Hazards (Check the appropriate box)

YES

NO

SECTION 2. Describe Specific Hazards

SECTION 3. (Circle One)

RESPIRATORY HAZARD (29 CFR 1910.134)

Half mask

Dust Mist

Full face Powered Air Purifying (PAPR) Air Line Escape Pack Airline with Escape SCBA SCBA None needed

Fume Nuisance Particulates Gas Vapor Asphyxiant (Including Oxygen deficiencies)

Cartridge Type (See Appendix D)

Note: This form does not cover 29 CFR 1910.137, Electrical Protective Equipment.

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EMPLOYEE TRAINING REQUIREMENTS Every employer is responsible for providing training to each employee who is required to wear PPE during the course of his work activities. Specifically, 29 CFR 1910.132 (f) requires these training components to be addressed: *When is PPE necessary *What PPE is required to be worn by the employees *How the employee is to don, duff, adjust, and properly wear the assigned PPE *The limitations of the assigned PPE *Proper care, maintenance, life span, and disposal of the PPE Employees must be retrained when there is a change in work function/task that renders the previous training obsolete, when there are changes in the type of PPE to be used in a work area, and when the employee(s) are improperly or ineffectively using the PPE, which indicates previous training was not comprehended. This rule also requires that each employee be capable of demonstrating an understanding of the training provided. The verification requirement places a duty on the employer to prove the employee has understood the training. To verify that each employee has received and understands the requisite PPE training, written certification is required. A Training Certification Form is provided below. The employer should maintain these completed forms. PERSONAL PROTECTIVE EQUIPMENT TRAINING CERTIFICATION

I,_____________________________ have received and understood the training (Name) given to me by _______________________(Company) _________________on personal protective equipment to be used: (a)When working in ______________________________________________ (Identify work area) And/or (b) When conducting the following tasks: ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ The following personal protective equipment has been assigned for me to use: (Check applicable boxes) [ ] Eye and Face Protection [ ] Head Protection [ ] Foot Protection [ ] Hand Protection [ ] Respiratory Protection Instructor:___________________________

(Identify specific assigned)

Date of Training:___________________

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Appendix A EYE AND FACE PROTECTION SELECTION CHART

SOURCE

ASSESSMENT OF HAZARD

Impact—Chipping, grinding, machining, masonry work, woodworking, sawing, drilling, chiseling, powered fastening, riveting, and sanding

Flying fragments, objects, large chips, particle sand, dirt, etc.

Heat—Furnace operations, pouring, casting, hot dipping, and welding

Hot sparks

Chemicals—Acid and chemicals handling, degreasing, plating

Dust—Woodworking, buffing, general dusty conditions Light and/or Radiation—Welding: electric ard

PROTECTION Spectacles with side protection, goggles, face shields. (see Appendix B(“B”) notes (1), (3), (5), (6), (10); for severe exposures, use face shields Face shields, goggles, spectacles with side protection; For severe exposure use face shields (see notes B (1), (2), (3)

Splash

Face shields worn over goggles (see notes B (1), (2), (3)

High temperature exposure

Screen face shields, reflective face shields (see notes B (1), (2), (3) Goggles, eyecup and cover types; for severe exposure, use face shields (see notes B (3), (11)

Splash

Irritating mists Nuisance dusts Optical radiation

Welding—Gas

Optical radiation

Cutting, torch brazing, torch soldering

Optical radiation

Glare

Poor vision

Special-purpose goggles Goggles, eyecup and cover types (see note B (8)) Welding helmets or welding shields, typical shades 10-14 (see notes B (9), (12)) Welding goggles or welding face shield, typical shades gas welding 4-8, cutting 3-6, brazing 3-4 (see note B (9) Spectacles or welding face shield, typical shades 1.5-3 (see notes B (3), (9)) Spectacles with shaded or special-purpose lenses, as suitable (See notes B (9), (10))

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Appendix B FILTER LENS FOR PROTECTION AGAINST RADIANT ENERGY OPERATION

Shielded metal arc welding

ELECTRODE SIZE (1/32 in.) Less than 3 3-5 5-8 More than 8

Gas metal arc Welding and flux Cored arc welding Gas tungsten arc welding Air carbon/arc cutting

(Light) (Heavy)

Plasma arc welding

Plasma arc cutting

(Light)** (Medium)** (Heavy)**

ARC CURRENT