Safety Manual | 2022

BL Companies

CORPORATE SAFETY MANUAL

Emergency Numbers

“911” can be called directly from any phone in the Company.

POISON CONTROL // 1.800.222.1222

Prepared by: BL Companies’ Safety Committee July 2022

table of contents

Section 1

COMPANY SAFETY PROGRAM

1

1.1 Policy Statement........................1 1.2 Job Safety Analysis and Project-Specific Health and Safety Plans.................1 FUNCTION AND RESPONSIBILITIES 2.1 Responsibilities........................5 2.2 OSHA Inspection Response Procedures.....7

Section 2

5

Section 3

INCIDENT PREVENTION & MANAGEMENT 9

3.1 Incident Reporting......................9 3.2 Incident Investigation and Review.......10

Section 4

EMERGENCY ACTION PLAN

13

4.1 Emergency Action Plan...................13 4.2 Emergency Response Procedures...........13 4.3 First Aid Program.......................14

Section 5

EDUCATION AND TRAINING

17

5.1 Employee Safety Orientation.............17 5.2 Ongoing Health and Safety Training......18

Section 6

SUBCONTRACTOR POLICY

19

table of contents (cont'd) Section 7

OCCUPATIONAL HEALTH PROGRAMS

21

7.1 Respiratory Protection Program...............21 7.2 Hazardous Communications Plan................21 7.3 Hearing Conservation Program.................23 7.4 Heat Stress..................................25 7.5 Cold Stress..................................26 7.6 Weather-Related Safety Concerns..............27 7.7 Bloodborne Pathogens.........................28 7.8 Pandemic Preparedness Plan...................30 7.9 Crystalline Silica Dust......................31 7.10 Lead Awareness...............................32 Section 8 8.1 Confined Space...............................33 8.2 Hot Work.....................................36 8.3 Electrical Circuits and Equipment............38 8.4 Working in State & Municipal Rights-of-Way...39 8.5 Excavations..................................40 8.6 General Office Safety........................41 8.7 Housekeeping and Sanitation..................43 8.8 Ladders and Stairways........................44 8.9 Aerial Lifts.................................46 8.10 Personal Protection Equipment................47 8.11 Tools........................................50 8.12 Lifting and Pulling..........................51 8.13 Biological Hazards...........................52 8.14 Weapons in the Workplace.....................55 8.15 Workplace Violence...........................55 8.16 Unmanned Aerial Vehicles (UAVs)..............57 Section 9 DRIVER SAFETY & COMPLIANCE Section 10 MEDICAL SURVEILLANCE GUIDELINES Section 11 DRUG AND ALCOHOL PROGRAMS

SAFETY PRACTICES AND PROCEDURES 33

59 63 67

LIST OF ACRONYMS

ACGIH ANSI ASTM

American Conference of Governmental Industrial Hygienists

American National Standards Institute American Society for Testing and Materials

CFR CPR

Code of Federal Regulations Cardiopulmonary Resuscitation Confined Space Entry Permit

CSEP

dB

Decibels

dBA DOT EMR EMT

Decibels measured on the A scale Department of Transportation Experience Modification Rate Emergency Medical Technician

FR

Flame Resistant

GFI

Ground Fault Interrupters

GHS

Globally Harmonized System

HASP Health and Safety Plan HAZWOPER Hazardous Waste Site Operations and Emergency Response HCS Hazard Communication Standard HR Human Resources Hz Hertz IDLH Immediate Danger to Life or Health IATA International Air Transport Association ISEA International Safety Equipment Association ISNET ISNetworld

...continued on next page

LIST OF ACRONYMS

JHA JSA LEL MPH MSP MSQ NFPA MSDS NIOSH OPIM OSHA

Job Hazard Analysis Job Safety Analysis Lower Explosive Limits

Miles Per Hour

Material Safety Data Sheets Medical Service Provider

Medical Surveillance Questionnaire National Fire Protection Association

National Institute for Occupational Safety and Health

Other Potentially Infectious Materials

Occupational Safety and Health Administration

PEL PFD PIC PPE ROW

Permissible Exposure Limit Personal Flotation Device

Pilot in Command

Personal Protective Equipment

Right of Way

RQ

Reportable Quantity Safety Data Sheets Threshold Limit Value

SDS

TLV

TRIR TWA UAVs

Total Recordable Incident Rate Time Weighted Average Unmanned Aerial Vehicles

VO

Visual Observer

Section 1 COMPANY SAFETY PROGRAM

BL Companies’ goal is zero incidents and injuries. By each Employee taking responsibility for his or her own safety and for the safety of fellow Employees, this goal can be achieved. 1.2 Job Safety Analysis & Project- Specific Health and Safety Plans Purpose This Manual is not intended to provide all Health and Safety procedures and requirements for every given job site but rather to provide an overview of the procedures and policies related to day-to-day safety. The purpose of this Section is to provide guidelines for job safety analysis and, if necessary, the subsequent writing of a project-specific Job Hazard Analysis (“ JHA ”) or Health and Safety Plan (“ HASP ”) by qualified BL Companies’ Employees. Scope These guidelines apply to all BL Companies’ Employees and all BL Companies’ operations. Policy Careful planning assures that work is performed safely. Hazard analysis is a critical part of the work planning. Work planning ensures the scope of work is understood, appropriate materials and training are available, all known hazards have been identified, mitigation efforts (if needed) have been established and all affected Employees understand what is expected of them during the course of the work. Job safety analysis will be performed in accordance with the procedures set forth below. All JHAs and HASPs will be prepared in accordance with the procedures set forth below and reviewed by a qualified person designated by the Company’s Safety Committee. A job safety analysis is a technique that focuses on job tasks as a way to identify hazards before they occur or are encountered. The analysis focuses on the Employee, the task, the tools and the work environment. By conducting a job safety analysis, an Employee will take steps to eliminate hazards or reduce such hazards to an acceptable risk level. Job Safety Analysis (“JSA”) - What is it?

1.1 Policy Statement

Safety is a Company Responsibility.

All of the Employees of BL Companies, Inc. (the “Company”) share the responsibility for securing a safe work environment by supporting and implementing this Manual. Each Employee is expected to be concerned with his/her own safety, the safety of fellow workers and the safety of the general public. This means not merely willing acceptance, but active support of this Manual including adherence to all of its rules and procedures. Accidents are caused because someone did something he/she should not have done; or because someone failed to do something he/she should have done; or because a hazard was not recognized. These are human failures and can be controlled. Additionally, accidents can be caused by system failure which is the failure to have a procedure or policy in place to protect employees. By exercising self-control, every Employee has an opportunity to demonstrate his/her job skill. By passing on his/her knowledge to others, each demonstrates teamwork. By demanding safe performance and enforcing approved safety procedures, supervisory personnel demonstrate concern for their Employee’s welfare. Hazards represent conditions with increased potential to harm Employees or the general public. Each Employee has a duty to develop an awareness of potentially hazardous situations. Each Employee has an obligation to ensure safe execution of the work, to the extent possible, and to take appropriate action to minimize hazards and/ or in response to hazards. Such actions may include, but are not limited to, obtaining health and safety related certifications and training, following safety standards, alerting the appropriate person to a potential hazard and/or suspending/stopping work on a potentially hazardous activity until such time as proper health and safety procedures can be implemented. This Manual applies to all conditions of the workplace. As such, the workplace is defined to include a BL Companies’ office, job site, or project location containing one (1) or more work areas used by BL Companies’ Employees.

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Section 1 // company safety program //

BL Companies // Corporate Safety Manual //

A job safety analysis may consist of the following steps:

expertise. The JHA should be taken to the site, reviewed and signed off by the Employees prior to the start of the job.

· Job site walk and/or document review · Hazard analysis · Pre-job briefing · Performance of the work

HASP – A HASP is a more detailed document that establishes health and safety protocols that address those concerns directly related to the site hazards identified in the job hazard analysis. Project Managers will need to assess whether the site where the work is being done falls under the OSHA HAZWOPER standard. This will depend on whether the site is regulated and whether there is a possibility for worker exposure to health and safety hazards from planned operations. If that is the case, the HASP must follow certain protocols. The HASP must be either developed or reviewed by a qualified person designated by the Safety Committee. Such qualified person may be either a Certified Industrial Hygienist (CIH), a Certified Hazardous Material Manager (CHMM), a Certified Safety Professional (CSP), or possess equivalent experience. A list of qualified people for 2022 is as follows: Rob Good, PG, LSRP Senior Environmental Scientist | King of Prussia, PA Joy Kloss, CHMM, LEP While a Project Manager or a PM’s designee may develop a draft of a HASP, planning and coordination with the qualified person must take place during development. All HASPs must be reviewed and signed by one of the qualified individuals above. Implementation Directors are responsible for ensuring that this policy is implemented within their discipline. Project Managers are responsible for identifying the degree and severity of the hazards of their job and controlling those hazards through completion of the JSA checklist and subsequent development of a JHA or HASP, if indicated. Safety requirements should be discussed with the project team during the project kick-off meeting and documented in the meeting minutes. Project team members should thoroughly review any JHA and/or HASP requirements prior to beginning field work. The Daily Tailgate Meeting Log can be used to document the team’s safety discussion prior to commencing work in the field. Project Manager | Meriden, CT Michael McGowan, CHMM, LSRP Senior Project Manager | Cherry Hill, NJ

· Post-job review · Record retention

In order to identify the level of job safety analysis and project safety requirements, the Project Manager should ask the following important questions and complete the JSA checklist.

· What work are we performing? · What are the hazards?

· How do I plan for and mitigate them? · How do I communicate them to the team?

Job Safety Analysis - When is it Needed? The JSA checklist should be prepared during the proposal phase of each project to ensure that applicable safety requirements are addressed in the project scope of work and budget. A JSA is required for every project unless it is clearly evident that a JHA or HASP will be needed. In this case, the Project Manager may proceed directly to the JHA or HASP. Once the initial job safety analysis and JSA checklist have been completed, the Project Manager will have assessed the level of complexity surrounding his or her job. The completed checklist should be included in the Project Management job folder. The Project Manager will then know whether the remaining steps can be accomplished by discussing and memorializing the safety considerations at the project kick-off meeting or whether it needs to be more formal by developing a JHA or a HASP. If the scope changes or field conditions change during the project, the project manager should be notified, the JSA should be revised to reflect any additional hazards and, as a consequence, a JHA or HASP may need to be written at that time. JHA – A JHA is a written document listing certain hazards that may be present on a job site and appropriate hazard control measures. It is not as detailed or lengthy as a HASP and may be only a few pages. A JHA should be reviewed by a member of the Safety Committee or a Project Manager in the requisite department with sufficient

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Each Employee has an obligation to take appropriate action to minimize hazards and/or in response to hazards. Such actions may include, but are not limited to, obtaining health and safety related certifications and training, following safety standards, alerting the appropriate person to a potential hazard and/or suspending a potentially hazardous activity until such time as proper health and safety procedures can be implemented.

members and will be corrected at the earliest opportunity prior to project closeout. More serious safety deficiencies that could potentially result in an incident or injury (e.g. lack of a required JHA or HASP, failure to wear required PPE or other unsafe work practices) may result in a temporary suspension of field work until corrective measures are implemented. Post Job Review As part of the project closeout process, Project Managers should review and discuss safety. Any lessons learned should be collected for future projects. Record Retention Copies of completed JSA checklists, project kickoff meeting minutes addressing safety concerns, JHAs and HASPs, Daily Tailgate Meeting Logs and records of any additional safety training or meetings should be saved in the project file. Any project-specific client or subcontractor safety plans and requirements should also be documented in the BL project file.

Safety Committee members will conduct periodic, random reviews of project safety requirements including:

· Proper completion and filing of JSA checklist; · Proper completion, review/approval and filing of required JHAs and HASPs in the office; · Conveyance of safety information to the project team; · Adherence to the policy of having the HASP or JHA on site; and · Employee adherence to project safety and PPE requirements in the field.

Minor administrative deficiencies will be addressed directly with the Project Manager or project team

BL Companies Sample JHA

PROJECT NAME, PROJECT NUMBER, SITE LOCATION (Street address, city and state)

DATE

NEW REVISED

PAGE 1 of 1

WORK ACTIVITY (Description):

Client Name, Contact Person & Phone Numbers:

PROJECT MANAGER

DEPARTMENT

REVIEWED BY:

POSITION / TITLE

MINIMUM REQUIRED PERSONAL PROTECTIVE EQUIPMENT ( SEE CRITICAL ACTIONS FOR TASK-SPECIFIC REQUIREMENTS) FIRE RATED REFLECTIVE VEST

GOGGLES FACE SHIELD HEARING PROTECTION(As

AIR PURIFYING RESPIRATOR SUPPLIED RESPIRATOR PPE CLOTHING

WORK GLOVES OTHER

E-RATED HARD HAT LIFELINE / HARNESS SAFETY GLASSES

Appropriate)

DI-ELECTRIC COMPOSITE TOE

SAFETY SHOES

¹JOB STEPS

²POTENTIAL HAZARDS

³CRITICAL ACTIONS TO MITIGATE HAZARDS

1.

2.

3.

4.

5.

6.

Emergency Phone # and Address of Emergency Facilities:

Signatures of BL Employees recognizing that they have read the JHA and will follow the safety guidelines: Name:_____________________________ Signature:________________________________ Date:________________ Name:_____________________________ Signature:________________________________ Date:________________ Name:_____________________________ Signature:________________________________ Date:________________ ¹ Each Job or Operation consists of a set of steps. Be sure to list all the steps in the sequence that they are performed. Specify the equipment or other details to set the basis for the associated hazards in Column 2. ² A hazard is a potential danger. What can go wrong? How can someone get hurt? Consider, but do not limit, the analysis to: Contact - victim is struck by or strikes an object; Caught - victim is caught on, caught in or caught between objects; Fall - victim falls to ground or lower level (includes slips and trips); Exertion - excessive strain or stress / ergonomics / lifting techniques; Exposure - inhalation/skin hazards. Specify the hazards and do not limit the description to a single word such as "Caught" ³ Aligning with the first two columns, describe what actions or procedures are necessary to eliminate or minimize the hazards. Be clear, concise and specific. Use objective, observable and quantified terms. Avoid subjective general statements such as, "be careful" or "use as appropriate".

Job Safety Analysis Checklist

Sample JHA

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Section 1 // company safety program //

Section 2 FUNCTION & RESPONSIBILITIES

safety requirement. This includes completion of the JSA checklists (and JHAs or HASPs as necessary); addressing safety during the project kickoff meeting and documenting such conversations in meeting minutes; providing proper PPE and field safety equipment for project use; conducting ongoing safety training and meetings on an as-needed basis; maintaining required safety documentation on a project-specific basis and performing post-job safety reviews. Responsibilities of Employees Employees are responsible for compliance with safety procedures, standards, and rules outlined in this Manual or other applicable directives. They are responsible for promptly reporting to their Supervisor any hazardous condition or procedure that affects them, their fellow workers, or the general public at their workplace or on a job site of which they are aware. They are also responsible for assisting in every way possible with the investigation of any incidents and the job safety analysis as set forth in Section 1.2. · Practice good work habits and follow all safety mandates, Company expectations and regulations. Do not operate equipment without the necessary safety features in place and in working order. · Do not engage in tasks or activities for which they are not properly trained or qualified. · Ensure compliance with safety rules and policies for BL personnel and those under control of the Company. · Wear and maintain appropriate safety equipment as required by the Employee’s Supervisor or site specific safety plans. · Maintain equipment in good condition with all safety features in place when in operation. · Keep the work area in good housekeeping order. · Report all injuries and incidents to the Employee’s Supervisor immediately and complete the required reporting forms. The Company expects all Employees to follow all objectives for safe work performance and be responsible for their own actions and conduct. Employees’ responsibilities for safety include the following:

2.1 Responsibilities

Purpose The purpose of this Section is to provide guidelines for establishing the roles and responsibilities of Discipline Directors, Supervisors, Project Managers and Employees.

Scope This Section applies to all BL Companies’ operations.

Policy An extremely important part of BL Companies’

corporate safety program is clearly defining the roles, responsibilities and expectations for all Employees, from Discipline Directors to front-line Supervisors to individual Employees. Discipline Directors Senior Management, defined as those Employees serving on the Senior Leadership Team are responsible for ensuring the consistent enforcement of all safety procedures outlined in this Manual, special rules issued by Department Directors, or any other applicable safety instruction. This responsibility is discharged through the first line supervisory personnel who are generally designated “Supervisor”. Wherever the title “Supervisor” is used, it shall apply equally to all other personnel charged with supervisory responsibilities, regardless of the actual titles. Responsibilities of Supervisors Supervisors are responsible for safety instruction and job training of every Employee under their supervision, and for making sure that all BL Companies’ tools and equipment that are used by Employees under their direction, are maintained in a safe operating condition. Project Managers All Project Managers are Supervisors and bear the responsibilities above. Project Managers have the additional responsibilities for ensuring that safety is addressed in the scope and budget of each project and that the project team members follow each applicable

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Section 2 // function & responsibilities //

BL Companies // Corporate Safety Manual //

BL Companies’ Safety Committee The Safety Committee is comprised of Employees from every discipline. The Safety Committee’s tasks are as follows: · Annually update the Safety Manual and present to all Employees on Safety Day; · Lead and document quarterly departmental safety meetings; · Review any incident that occurs during the year; · Annually review all incidents to assess trending as well as mitigation strategies; · Continually promote awareness of safety and compliance with safety measures.

Violation and Disciplinary Action To ensure a safe work environment, BL Companies expects Employees to follow rules of conduct that will protect the safety of all Employees and the Company. It is not possible to list all the forms of behavior that are considered unacceptable for a safe workplace. The following are some examples of infractions of rules of safety conduct that are subject to disciplinary action. Discipline for a first offense is at a minimum a verbal warning; for a second offense at a minimum a written warning and for a third offense at a minimum a written performance plan with regard to safety. Discipline at all levels may include termination of employment depending on the severity of the infraction. In all cases, the penalty to be applied is within the discretion of the Company: · Falsification of safety compliance and training records. · Failure to report an injury or incident in the workplace. · Working under the influence of alcohol or illegal drugs and the unauthorized use of alcohol or illegal drugs in the workplace. · Unauthorized possession, distribution, sale or transfer of alcohol or illegal drugs in the workplace. · Fighting or threatening violence in the workplace. · Boisterous or disruptive activity in the workplace. · Negligence or improper conduct leading to unsafe working conditions or damage of employer-owned property. · Insubordination or other disrespectful conduct toward other Employees, Management, or clients, especially failure to comply with safety requirements. · Smoking in prohibited areas. · Possession of dangerous materials, such as explosives or firearms, in the workplace.

The Safety Committee members for 2022 are:

Meriden, CT Will Thiel

Canton, OH Bob Cappelli Charlotte, NC Andrew Mueller Cherry Hill, NJ Mike McGowan Harrisburg, PA Jeremiah Jones King of Prussia, PA Rob Good Melville, NY

Jason Silver Julia O’Brien John Jenney Joy Kloss Kathy Rodo Peter Schirmer Jennifer Li Shannon Powers Ed Barry John Schmitz Hartford, CT Brandon Rojas Dom Celtruda Justine Ziobron Tom Beckman Kevin Kilguss

Michael Nuzzi Norwood, MA Charlie Packer Dan Hodgkins Pittsburgh, PA Andy Koch

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2.2 OSHA Inspection Response Procedures

Due to the legal sensitivity of an OSHA inspection, BL Companies’ Employees should adhere to the following protocol if approached by an OSHA Inspector. · Be polite and professional. · Ask the OSHA Inspector what the basis is for the inspection and for a copy of the complaint, if applicable. · Contact the corporate headquarters before allowing the inspection. The OSHA Inspector will wait a reasonable amount of time for that contact to be made, generally no longer than an hour. · Immediately contact the following members of the BL Companies’ Inspection Team Œ Julia O’Brien, General Counsel Œ Shannon Powers, Human Resources, OSHA Administrator · Do not offer any information, documentation or tour of facility without speaking to a member of the BL Companies’ Inspection Team. A member of the Team will instruct the Employee on how to proceed. · If the Inspector requests an immediate correction be made, the Employee may do so within reason, such as put on proper PPE, properly set-up cones or shut down the operation of machinery. Œ Joy Kloss, CHMM, LEP, Project Manager Œ John Jenney, Senior Construction Manager

Purpose The purpose of this Section is to define and explain the appropriate protocol. Employees shall follow if approached by an OSHA Inspector on a job site or at a BL Companies’ office location.

Scope This Section applies to all BL Companies’ Employees.

Policy BL Companies’ Employees should understand that during an OSHA inspection OSHA has the right to do the following: · Decline to provide advance notice; · Inspect workplaces with probable cause, consent, or when hazards are in plain view; · Inspect records; · Collect evidence, for example, air or noise samples and photograph; · Conduct employee interviews; and · Exercise its authority to issue subpoenas for records and interviews.

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Section 2 // function & responsibilities //

Section 3 INCIDENT PREVENTION & MANAGEMENT

Training All Employees shall be trained in their roles and responsibilities for incident response and reporting. Incident response and reporting training will take place during new hire safety orientation, Safety Day, and as needed prior to the start of any investigation. Incident Reporting Requirements If an incident or job-related injury occurs, it must be reported immediately by the Employee to the Employee’s Supervisor, the Human Resources Department, and Fleet Manager, if applicable.

3.1 Incident Reporting

Purpose The purpose of this Section is to describe the procedures for informing Management of incidents and near misses, to assure timely access to BL Companies' resources to help resolve incidents, and to identify federal and state requirements for reporting and recording occupational accidents, injuries and illnesses. Scope This Section applies to all BL Companies’ operations and Employees. Policy All incidents and near misses having either an immediate or potential effect on the safety and well-being of BL Companies, its Employees and visitors will be promptly reported and addressed. Definitions Incident – An unplanned event resulting in personal injury, occupational illness, property damage, vehicle or equipment accident, loss of assets, fire or explosion, spill or release or adverse publicity. Near Miss – An incident where no property was damaged and no personal injury sustained, but, where given a slight shift in time or position, damage and/or injury easily could have occurred. Spill – Every unplanned escape of material, solid or liquid, from its primary container, vessel, tank, etc. regardless of quantity. Routine or intentional leakage to a drip pan or a sump is not considered to be a spill. Release – Any unplanned escape of a vapor, aerosol or gas from its primary container. RQ Spill or Release – A spill or release of sufficient quantity of material to exceed the established State, Federal and/or local reportable quantities. Inspection – Any inspection or contact by a representative of a regulatory agency, a public safety department or agent of the client.

The following steps shall be taken after initial report of incident is made.

 Employee and Supervisor will complete the “Incident Report Form”. The Form shall be reviewed and signed by the Employee, Supervisor, Director and Executive Director.

 The Incident Report Form will then be forwarded to the Human Resources Department for review and follow-up.

 The Human Resources Department shall notify the Chairperson of the Safety Committee and the General Counsel.  The Chairperson of the Safety Committee will contact the Safety Committee Representative and Project Manager, if applicable.

 It is the Project Manager’s responsibility to alert the client if required by contract or by client safety protocols.

Incident / Injury OSHA Recordkeeping Procedure Required incidents must be verbally called in to OSHA and other applicable regulatory agency(s) within eight (8) hours after the death of any employee from a work- related incident or one or more work-related in-patient hospitalizations, as well as amputations and losses of an eye, to OSHA within 24 hours of the event. Written records will be kept for all fatalities, injuries, and illnesses that are considered to be work-related, a new case and/or meets one or more of the general OSHA recordable criteria.

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Section 3 // incident prevention & management //

BL Companies // Corporate Safety Manual //

Each recordable injury or illness must be entered on an OSHA 300 Log and 301 Incident Report, or other equivalent form, within seven (7) calendar days of receiving information that a recordable injury or illness has occurred. These records must be retained for five (5) years following the end of the calendar year that the records cover. A copy of the annual summary OSHA 300A Log will be signed by an executive of the Company who fully understands the process by which the information was recorded and can confirm that the annual summary is correct and complete. A copy of the signed OSHA 300A Summary will be posted in each office where notices to Employees are customarily posted, no later than February 1 st of the year following the year covered by the records. The posting should be kept in place until April 30 th . 3.2 Incident Investigation and Review Purpose For any incident that involves further investigation beyond use of the Incident Report Form, this Section shall apply. The purpose of this Section is to provide an outline of the measures necessary to investigate and reconstruct the incident scene, analyze the findings and circumstances involved, and ensure the quality of the documentation in order to form an accurate understanding of the immediate and basic causes of an incident as well as determine what steps, if any, can be taken to prevent the incident from occurring in the future. Scope This Section applies to all BL Companies’ operations and Employees. Policy An incident investigation should be completed for those incidents that require more follow up and investigation than what is achieved using the Incident Report Form. The purpose of investigating an incident is to determine the incident cause so that similar incidents can be prevented.

Resources Department and should include the Employee, Supervisor, Project Manager, and the safety person involved in preparing the HASP or JHA and/or approving it, if applicable. This group should document its findings and propose corrective action for the future. It is the responsibility of Human Resources in coordination with the Departmental Discipline Director to follow up with the Employee and the Employee’s Supervisor to ensure that the recommended corrective actions are being taken. Timing and Methodology Each investigation shall be made as soon after the incident as possible but not later than the first work day after the incident. The investigation team will be provided with the necessary equipment needed to assist in the investigation. It is the purpose of the incident investigation to obtain factual information so that the cause can be determined and the incident recurrence prevented, not to fix blame. · Describe actual or potential injuries (or property damage). · Address initial identification of evidence: tasks performed, equipment used, list of witnesses and environmental factors such as weather report or building conditions. · Determine how the incident was caused. · Determine how the incident can be prevented in the future. · Interview witnesses and document statements, if applicable. · Preserve confidentially and secure all collected evidence with the Human Resources Department. While personal information should be kept confidential, general information about the incident, the cause and important lessons should be shared with the Safety Committee and subsequently with all Employees at the Quarterly Safety meetings if appropriate. The following are items which shall be covered in the Incident Investigation:

Responsibilities An incident investigation would be led by the Human

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Trending At the end of the calendar year, the Safety Committee shall meet to review any and all data and information provided by the Human Resources Department concerning all incidents and near misses that have occurred over the course of the year and determine:  what trends (if any) are occurring,  what steps have or could be taken to prevent such events in the future, and  the actions to implement such steps going forward.

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Section 3 // incident prevention & management //

Section 4 EMERGENCY ACTION PLAN

4.2 Emergency Response Procedures

Purpose The purpose of this Section is to define and explain the requirements for effective emergency response procedures. Scope This Section applies to all BL Companies’ operations and Employees. Policy Prior to engaging in emergency response activities, BL Companies will endeavor to anticipate possible scenarios and have on stand-by sufficient inventory and adequately trained manpower to respond. Basic Information Every Employee shall be informed of two (2) pieces of information needed in the event of an emergency: 1) the evacuation route to remove themselves from any dangerous situation, and 2) how to notify professional assistance (ambulance, fire, police, etc.). Employees should always be aware of the immediate surroundings and the correct direction to go in emergency situations. The required number of fire extinguishers, determined by the fire marshal, will be strictly complied with at all times. Small fires should be quickly controlled by the use of the nearest appropriate fire extinguishers. · First, remove himself or herself and other Employees from the dangerous situation. · Second, notify professional assistance if required (ambulance, fire, police, etc.). · Third, notify his or her Supervisor in order to receive direction and to make sure the proper actions will be taken. Unless severely injured and in need of immediate medical attention, no Employee should leave the scene of an accident before such reports have been made. Under no circumstances should Employees fail to report an accident involving Company personnel, vehicles or property damage. Any time there is a medical emergency, vehicle accident, or damage sustained to property, the Employee should:

4.1 Emergency Action Plan

Purpose The purpose of this Section is to stress the necessity of developing a site-specific Emergency Action Plan for each BL Companies’ office. Although there are and may be numerous types of emergencies, BL Companies requires all Supervisors and Directors to be able to respond to three (3) major areas:  General disasters such as fires, explosions, etc.  Natural disasters such as floods, tornadoes, severe storms, etc. and  Emergency spills such as hazardous chemicals, etc. Scope This Section applies to all BL Companies’ operations and Employees. Policy An Emergency Action Plan will be developed for each office. Copies of the Plans will be posted in the respective office and be on the Company’s intranet. Since dealing effectively with any type of emergency situation depends upon prompt notification, coordinated mobilization, quick implementation of specific duties and assignments, and the optimum use of Company’s resources, these plans must be coordinated with Company-wide emergency planning. Emergency Response Plan OSHA Standards, 29 CFR 1926.24, entitled Fire Protection and Prevention and 29 CFR 1926.35, entitled Employee Emergency Action Plans, requires each employer to be responsible for the development and maintenance of an effective Emergency Action Plan at each facility and/or job site. Copies of the Emergency Action Plan must be posted at the facility or job site.

Each plan will address the three (3) major areas bulleted above and the procedures for response.

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Section 4 // emergency action plan //

BL Companies // Corporate Safety Manual //

Scope This Section covers all BL Companies’ operations and Employees. Policy After evaluating hazards in the workplace, BL Companies will furnish appropriate provisions for the attention of simple medical or health problems that require no further treatment and for emergency help to the severely injured until professional medical personnel can take over. On-Site Medical Supplies and Personnel OSHA requires that adequate first aid supplies must be readily available and that a person or persons be identified and adequately trained to render first aid. The Company provides first aid training to Employees at each of its staffed offices so that they may provide first aid to Employees who experience injuries or illnesses on the job if they cannot reach a hospital, infirmary or clinic within 3-4 minutes of the worksite. Where required on a job site, such trained first aid person shall be provided. The person responsible for rendering first aid on-site shall possess a valid certificate in first aid training, American Red Cross or equivalent. The Company will provide proper equipment for transportation and/or an adequate communication system for contacting an ambulance service, in the event the injured person(s) needs prompt transportation to a physician or hospital. In areas where 911 may not be available, a list of numbers for local physicians, hospitals and ambulance services shall be posted in a conspicuous place on-site.

Persons injured on a job site or in the office will assess the level of medical attention required. If minor first aid is required, the medical attention will be administered utilizing the First Aid Kit found in the Company vehicles or in the office. All possible care should be taken to prevent the transmission of bloodborne pathogens between people to prevent additional medical concerns. Medications are not to be issued to an Employee by another Employee unless the administering Employee is certified to administer such items and is operating within the scope of their training (e.g. a certified EMT). Any medications taken for any illness must be taken under the injured person’s own power or issued under the direction of a health care professional. In the event extensive medical treatment is required, “911” should be called to transport the injured worker to the nearest hospital in an ambulance. “911” can be called directly from any phone in the Company. > There is no need to dial “9” prior to dialing “911”. < Site Specific Worksites At ongoing worksites, emergency phone numbers are listed in the site specific plan designed for the individual worksite. On-site emergency procedures may differ from site-to-site. Supervisors at each ongoing worksite will address the relevant emergency procedures for that specific site. At any ongoing worksite, where hazardous materials or conditions exist or may exist, the site specific HASP and emergency procedures are to be reviewed at periodic Health and Safety meetings with each person on the site. Any client or facility emergency response plans should be attached to the HASP or be referred to in the HASP and be reviewed with reasonable frequency. 4.3 First Aid Program Purpose The purpose of this Section is to define the first aid requirements for Employees who become sick or injured on the job.

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First Aid Kits

The Company shall provide First Aid Kits in every office and in every vehicle. If on a job site, if the Client for whom BL Companies is working does not have a First Aid Kit, BL will provide one. The First Aid Kits will contain the following supplies:

ANSI Class A First Aid: ANSI/ISEA Z308.1-2015 – Required supplies for Class A First Aid Kits

Item

Minimum Quantity

Adhesive bandages, 1” x 3” Adhesive tape, 2.5 yards Antibiotic treatment application

16

1

10

Breathing Barrier

1 1

Burn dressing, gel soaked, 4” x 4”

Burn treatment

10

Cold pack

1 2 1 1 1 1 1 2 2 1

Eye covering

Eye wash, 1 ounce

First-aid guide Hand sanitizer Exam gloves

2 pairs

Roller bandage, 2” x 4 yards

Scissor

Sterile pads, 3” x 3” Trauma pads, 5” x 9”

Triangular bandage, 40” x 40” x 56”

An inventory of all First Aid Kits shall be periodically taken to ensure all necessary supplies are available and any additional needed supplies are added. Worksite First Aid Kits shall be checked before being taken to the job site. The First Aid Kits are inventoried by Safety Committee members in the regional offices. The Kits should be consistently kept in one place so that Employees can easily access them. Employees can assist these individuals by performing the check above and directing any requests for replacement supplies to them. Automated External Defibrillator (AED) AED’s have been installed in every BL office. Several employees have received training in how to use the AED. AED’s will be checked annually to ensure they are in working order.

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Section 4 // emergency action plan //

Section 5 EDUCATION AND TRAINING

Department Specific Training The Safety Committee Chair shall designate a Safety Committee Member within each department and/or office to be in charge of specific departmental and office safety concerns and practices. This individual shall acquaint new Employees with the nature of their work, specific safety features and requirements and general safe work expectations for the department. The Safety Committee Designee will go through the Safety Manual with the new Employee pointing out areas specific to the new Employee’s discipline. Additionally, the Safety Committee will discuss various safety training that the new Employee has and needs. All Employees will be required to acknowledge receipt and review of the Safety Manual. Entry Level Employees An entry-level Employee, also known as a short service Employee, is one who is new to the profession and has had limited exposure to field work. When this type of Employee is first assigned to the field, he or she will be accompanied by another Employee who has experience with the type of work the entry-level Employee is being asked to perform. The entry-level Employee will be advised and mentored by the more senior Employee in the specific techniques of the tasks assigned as well as the safe and proper way to accomplish such tasks. As part of such mentoring, the more experienced Employee shall monitor the entry-level Employee for compliance with BL’s health, safety and environmental procedures as well as those specific to the particular task and report back to the entry-level Employee’s Supervisor. Medical Surveillance All new Employees will be required to complete the Medical Surveillance Questionnaire (“MSQ”). The Employee will complete the MSQ with the Employee’s Safety Committee Designee with sign-off from the Employee’s Supervisor. The MSQ will then be forwarded to the Human Resources Department. Safe Driving All new Employees will be required to give a copy of their license to the Human Resources Department and watch a Safe Driving Video. The Driver Safety and Compliance Policy (Sec. 8.3) authorizes the Company to request and review State motor vehicle reports and outlines the Company’s baseline expectations before the use of a vehicle (Company or personal) for a business purpose is permitted.

5.1 Employee Safety Orientation

Purpose The purpose of this Section is to provide guidelines for the proper safety training of all new BL Companies’ Employees. Scope This Section applies to all BL Companies’ operations and Employees. Policy Upon hire or office relocation by BL Companies, every Employee will receive office-specific basic safety orientation to ensure that such Employee understands the required health and safety training necessary to allow him/her the ability to safely carry out his/her work assignments. Training A key element in the Company’s safety program is the initial training of Employees. They need to know the Company safety program, policies and the rules to begin to develop the proper safety attitude and work procedures immediately. This training also demonstrates Management’s interest in their well-being. · Company safety expectations of the work force, Supervisors and Management; how Employees and Management representatives are held accountable for safe work performance. · Review of fire alarm procedures and the steps to follow in case of fire or related evacuation procedures. · Tour of the office to show the Employee the location of fire extinguishers, First Aid Kits and emergency exits. · Specific job safety requirements as they affect each individual department and task. · Incident reporting procedures, including the need for prompt reporting and follow-up. · Specific PPE requirements, if applicable. · Introduction to the Hazardous Communication Plan, if applicable, and the Emergency Action Plan for the Employee’s specific office. The following areas are to be covered in the new Employee’s orientation:

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Section 5 // education & training //

BL Companies // Corporate Safety Manual //

5.2 Ongoing Health and Safety

Content A specific topic of safety should be addressed at each meeting. The topics will be determined and discussed through a preliminary Safety Committee Meeting. Time The meetings should be scheduled in advance and be divided into two phases – a presentation lasting five to ten minutes followed by a question and answer session and open discussion. Presenters A Safety Committee representative will be responsible for coordinating the presentation. They may enlist other employees to present on special topics if necessary. Meeting Documentation All safety meetings should be documented including attendance and a description of what was discussed. Meeting documentation and materials should be saved in a central location where it is easily accessed by the Safety Committee Chair and Safety Committee Members. Attendance Attendance shall be taken at each meeting.

Training - Quarterly Meetings

Purpose The purpose of this Section is to provide guidelines enabling supervisory personnel to conduct well-planned safety meetings that meet the needs of their individual departments. Scope This Section applies to all BL Companies’ operations and Employees. Policy Safety meetings that are well conducted, interesting and informative are an absolute necessity in order to provide a continuing enhancement in safety awareness. Frequency and Format of Safety Meetings All employees shall attend a quarterly meeting for a brief safety meeting and safety review. Smaller offices or departments may combine this review and perform it as an office or larger group. Some departments may review safety topics more frequently. This does not relieve them of the quarterly safety reviews.

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Section 6 SUBCONTRACTOR POLICY

· Has your company received any citations from a regulatory agency during the last 3 years? · Does your company hold documented onsite safety meetings (Toolbox/Tailgate/Pre-job)? · Does your company have a safety manual with a written safety policy? May we obtain a copy upon request? · Do you have a company safety officer? If Yes, please provide contact information. Acceptable Safety Metrics On certain jobs, a certain benchmark may be set with regard to necessary training, PPE and supervisory activities. All subcontractors applying for the work must meet these benchmarks. Kickoff Meeting and Safety Orientation Subcontractors may be required to attend the kickoff meeting for the project and any required safety orientation prior to commencing work activities for that project, as well as comply with any client specific health and safety requirements required by the client. Job Hazard Assessments and Job Safety Inspections Subcontractors may be required to complete a JHA prior to commencing work activities for a project. Job safety inspections may be performed and would be more specific for each project. Tailgate Safety Meetings Subcontractors may be required to attend scheduled tailgate safety meetings. Job Safety Performance Reviews BL Companies may review the safety performance of all subcontractors at anytime during or after the project.

Purpose The purpose of this Section is to ensure that any subcontractor engaged by BL Companies is following safe work practices and procedures. Scope This Section applies to all projects where pre-qualification of subcontractors is required and is good practice for all projects on which subcontractors or subconsultants are utilized. Policy On some specific projects, as mandated by a BL client, BL Companies’ subcontractors need to be pre-qualified before being hired to perform services. Those that meet the qualifications and are hired will then be required to attend certain meetings and meet certain benchmarks. As a best practice, BL has compiled a list of current subcontractors and subconsultants and has requested safety information from them. This information is found on the Intranet so that all Project Managers are aware of the safety records of subcontractors and subconsultants prior to hiring them for a project. Pre-Qualification Below is a list of safety metrics that are asked of subcontractors on specific jobs. · Does your company have the appropriate licenses, registrations and insurance? · When required, will you provide copies of the required licenses, registrations, insurance? · If asked, can you provide five years of insurance claims history? · Please provide your firm’s Experience Modification Rate (EMR) for the last three years. · Provide the three most recent full years of recordable incidents and rate information for your company. Include a copy of your firm’s OSHA 300 Log from the past three years. · Has your company received any inspections from a regulatory agency, including transportation agencies, during the last 3 years?

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Section 6 // subcontractor policy //