Safety Manual | 2022

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 //