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					Developing a Company
   Safety Manual
 A Leadership Guide to Developing Safety Standards & Better Practices




               Copyright EPL for Residential Inc.                       1
1.   Introduction

     This safety and better practices guide was and continues to be developed as a
     resource or tool to assist the Company as well as team leaders to develop or
     enhance the safety program at their specific location, for both commercial
     and residential operations. All employees at the Company, at some point in
     time, will need to become familiar with the content of this resource. Safety
     Leaders should utilize it as a flexible tool to build their Company’s safety
     culture and operation.

     Having a Company safety program is more than just a manual, a monthly
     meeting or a video. It is a comprehensive part of each Company’s operation.
     It is many components combined to make up the whole system and then
     infused into the culture of the Company.

     These better practices, when implemented, followed up on and maintained,
     will have a positive affect on the employees and on the company.

     This resource will continue to be developed and revised to meet the needs,
     challenges and opportunities in the field. I appreciate the input from various
     districts, Company’s and individuals over the past months in regard to this
     resource.




                      Copyright EPL for Residential Inc.                          2
1.1   Safety Vision

      Safety. When we hear or see that word, we many times think of it as
      an extra thing we have to do, or we think of that program collecting
      dust on the shelf. Safety, however, is as much a part of the
      Company’s operation as quality service, marketing, sales, and so on.
      If we have injuries and accidents, can we achieve those other aspects
      of the operation to the best of our ability?

      Our “One Company” vision, when it comes to safety is to ensure ALL
      employees have a safe work environment, return home each day
      uninjured, are aware of safety everyday and apply it to each work
      situation. Safety is everyone’s responsibility. Everyone will be held
      accountable to work safely, follow company rules, policy and
      procedure. We all must be proactively involved in the safety process.
      We cannot think that safety is the sole job of management or that
      someone else will take care of it.

      To “Drive Our Accidents and Injuries Down to Zero”, we must take a
      proactive, not a reactive approach. Our safety guidelines and better
      practices will not be built on accidents and the injuries of our
      employees.

1.2   Safety Mission
      The mission of (Company ABC) Inc. safety operation is as follows:

           Facilitate safety for (Company ABC) Inc.; USA and Canada
           Provide “Better practices” and safety guidance
           Be a resource to the Company
           Support the safety team leaders at the Company
           Research and recommend tools for training initiatives
           Conduct accountability audits

      Safety will be co-mingled into the Company’s operation, how that
      happens is the Company’s responsibility.




                 Copyright EPL for Residential Inc.                           3
2.   COMPANY SAFETY TEAM STRUCTURE

     2.1   Purpose

           By having a Company safety team structure, we, as a team, can better
           manage and facilitate safety in the field. It is the vehicle in which
           safety initiatives will be delivered.

           We cannot have content without process.

     2.2   Team Members

           So who are the members?

           Well in essence we all are, but we also need structure. The members
           will consist of a Safety Team Leader, Safety Team of Company
           employees.




                      Copyright EPL for Residential Inc.                           4
2.3   General Safety Responsibilities

      The following are general responsibilities for the Company safety
      team.

      These are also suggested selection criterion for the Safety Team
      Leader.

      The purpose of outlining these responsibilities is to ensure a clear
      understanding of what the Company’s general responsibilities are in
      terms of safety and its administration. We, as a company are
      committed to making sure that everyone is involved in making our
      jobs safer and reducing accidents to zero. But we need everyone’s
      proactive interaction, including yours.

      Please familiarize yourself with these areas of your responsibility.
      These general responsibilities can be added to, but not deleted.

      Company Safety Team Leader Responsibilities
            1.     Leads by example.
            2.     Exhibit a positive attitude.
            3.     Willing to take on the additional responsibilities above.
            4.     Possibly a long-term field employee or supervisor.
            5.     Someone who will take the TIME to properly lead this program.
            6.     Willing to learn, listen, understand and communicate.
            7.     Sees the opportunity to make a positive difference.
            8.     Facilitate safety training and meetings with the Company
                   employees.
            9.     Review safety policy, procedure and “better practices” and ensure
                   the Company employees understand what is expected.
            10.    Assist in New Employee Orientation in regard to safety. Let the
                   new employee know what is expected in terms of safe work
                   practices and review safety material with them.
            11.    In concert with the Company employees and Company
                   management develop the safety management system to facilitate
                   the overall safety program.
            12.    Update the employees on loss trends for their Company’s. Let
                   them know what the loss leaders are.
            13.    Keep abreast of upcoming policy, procedure and better practices,
                   and communicate it to the Company.



                  Copyright EPL for Residential Inc.                                   5
General Employee Safety Responsibilities

     1.     Lead by example.

     2.     Willingly accept safety & operational rules as being for
            your own protection and the protection of your fellow
            employees.

     3.     Take ownership & responsibility for your actions.

     4.     Come forward on issues with solutions in mind & work
            together with the Safety Team Leader and managers to
            achieve a common end result.

     5.     Participate in any safety initiatives, teams or committees.

     6.     Exhibit high standards of quality and overall performance
            in your day-to-day work habits.

     7.     Assist management by participating in job task
            observations. If you observe something on the job that is
            a hazard or unsafe condition, bring it to your supervisor
            manager’s attention.

     8.     Report all injuries and accidents or near misses to
            management, supervisor or Team Leader immediately.

     9.     Be willing to take the lead on safety initiatives, service
            Company program development and execution.

     10.    Provide input on developing safety initiatives and plans
            to eliminate exposures that could cause accidents.

     11.    NO horseplay! It will eventually cause an accident.

     12.    Be PROACTIVE in the prevention of injuries and
            accidents!




           Copyright EPL for Residential Inc.                            6
2.4.1. Our Goal, Commitment & Function


     To develop “Better practices” and safety guidelines to minimize
     the risk of safety related issues in the company.

     This could either assist a Company in starting a program or be
     used to enhance an existing program.

     We are committed to the reduction of employee injuries and
     accidents to drive them down to zero.

     We intend on accomplishing this through better practices at our
     company.




         Copyright EPL for Residential Inc.                           7
3.   PERCEPTION VS. PERFORMANCE

     Perception – The ability to perceive or understand.
     Performance – An accomplishment.

     When we look at these two definitions and relate them to safety, many
     things come to mind.

     The statement “Zero Accidents” is more specific: Is it perception or
     performance? We all need to commit ourselves to driving our accidents
     down to zero. Anything else could be perceived as accepting them.

     So how will we gauge performance each year?

     There will be various measures:

          Develop a written safety business plan for the Company.

          Implementation of the better practices.

          Addressing actual and potential sources of accidents and injuries.

          Safety discussed daily on the job site and persons held accountable
           for their actions, both positive and negative.

          Company program building.




                      Copyright EPL for Residential Inc.                         8
3.1    Zero Accidents – “Are you kidding”?

       As discussed in the previous section, we should always strive for
       “zero” accidents.

       That should always be perceived and understood.

       Wanting anything else sends signals that we accept accidents as a cost
       of doing business – we do not and will not.

       There are not very many people who would want to work for a
       company who would accept it as such.

3.2    Working Left of Zero

       “Working Left of Zero”.
       Time and money are spent, but to the lesser degree when we are
       proactive.

       We also have one less thing when we are proactive, which is the
       injured employee.

       That is priceless. It is obvious which side we are going to work from.

                      Zero Line – Nothing
                          Happening



Proactive Side                              Reactive Side


      More time and more money as you move right




                  Copyright EPL for Residential Inc.                        9
4.   QUANTIFICATION

           As we move forward as a Company we need to understand the scope
           of the human and monetary costs as a company.

           There also needs to be a basic understanding of what Direct and
           Indirect costs mean and how they affect us as a company.

     4.1   Direct and Indirect Costs

            Direct costs – Dollar costs associated with the treatment of the
             injury and benefits paid to the worker. It is also associated with
             damage to equipment, automobiles and property.

            Indirect costs – soft or hidden costs associated with the accident…
                        Loss of customers
                        Supervisory/Administrative time
                        Overtime
                        Training replacement staff if needed
                        Fines or citations
                        Decreased morale
                        Community standing

                 …the list could go on

           It is estimated that indirect costs can be 4 to 6 times the direct costs.
           For example:

                 100 Direct x 4 = 400 Indirect
                             + 100 Direct
                              500 Total Cost Direct and Indirect

           We cannot however, put a price on the cost of human suffering.

             Injuries and accidents to our employees are not and will not be
                           considered a cost of doing business!

                      Copyright EPL for Residential Inc.                           10
5.   SAFETY MANAGEMENT SYSTEM (Process before content)

     5.1   Purpose

           Why have a safety management system?

           Why not just give the Company’s a manual for safety and be on our
           way?

           The reason is we cannot have content (a manual) without a process
           (system to manage).

           Is there any other aspect of the Company operations that runs without
           a process? There is not.

           Safety is no different. We have to have a way to deliver content, raise
           awareness and bring safety into our Company culture. The following
           deals with business planning for safety and eight “Better practices” to
           assist you in this process.




                      Copyright EPL for Residential Inc.                        11
5.2   Planning for Safety

      We need a plan.

      The document should not be restrictive and should be open for
      change. It should address actual and potential hazards for the
      Company.

      The following is an example of one plan.

      Sample Safety Business Plan Column Definitions:

      1. Loss Cause/Critical Area – List Company specific losses i.e. 4
         strains, 10 rear end auto accidents, etc. List areas of improvement,
         training needs etc.

      2. Injury #s – How many injuries or accidents of a specific type.

      3. Previous Loss $ - The severity or direct costs of the injury or
         accidents.

      4. Activities – List activities that will be needed to address #1.

      5. Benefit/Effect – What will be the benefit or what desired effect
         does the Company want to achieve?

      6. Person(s) Accountable – What person or group of people will be
         accountable or responsible for making sure activities are
         completed?

      7. Target Date – List a realistic target date for completion.

      8. Completion Date – List the actual date of completion.

      9. Company – Name

      10.Date – MM/DD/YY




                 Copyright EPL for Residential Inc.                         12
5.3   Safety Management System:
      Eight Better practices needed for Success

      1. Safety Leadership: Service Company Commitment - Demonstrated
         management safety leadership vision, values and commitment.
          Strong Belief in Safety to Maximize Success
          Willingness to Change and be Flexible
          Total Management Involvement (all levels actively participate)
          Commit Necessary Resources
          Productivity, Quality and Safety are Compatible
          Document and Publish a Service Company Specific Safety
            Philosophy
          Establish Service Company Safety Goals and Objectives
          Company management must incorporate Safety in Action Plans
            at all Levels

         SAFETY LEADERSHIP – Company, Vision, Values and
         Commitment

         Owner/management, the Safety Team Leader and employees need
         to develop their own safety vision for their Company.

         A safety mission statement talks about working towards the
         creation of an accident free work environment or Zero Accidents.
         If our organization is able to achieve that vision in the future, we
         need to be able to visualize, conceptualize and verbalize what it
         would mean to the company. Ask the following questions:

               What changes would have to be made in the way we
                motivate and empower people to take ownership and
                responsibility for their actions?

               What changes would be needed in the way the company
                trains people to perform their jobs safely?
               Would there be changes needed in the equipment and tools
                employees use, the work practices and procedures that
                employees are expected to follow?

               What sort of problem identification and problem solving
                skills would have to be developed in the staff?

                 Copyright EPL for Residential Inc.                         13
         How would all of these changes impact the quality of the
          products or the services the company provides to their
          customers?

   In order for these changes to take place the Company first needs to
   identify some core organizational safety values that have to be
   supported and promoted.

   If people don't know where an organization is going, why it is
   going in that direction and what the ultimate benefits will be if they
   follow, they are not likely to get on board.

   People need to be able to "see" the future as management sees it.

   To get people to follow and change, that future has to be more
   attractive and appealing than what they see right now.

   Short and long term safety goals and objectives need to be set. The
   short term ones are needed to keep the business moving forward
   toward the vision while still allowing the organization to meet their
   annual business plan. Goals and objectives need to define
   individual responsibilities. People should be held accountable for
   meeting their goals. Management must provide them with the
   needed support and tools.

   All of these items hinge on one thing: management commitment.
   Without it, attainment of the vision will be difficult, if not
   impossible. There are no easy quick fixes in safety that will
   produce lasting change. Zero Accidents and safety excellence is
   not achieved without dedication, effort and commitment to change.


2. Organization for Safety - An organizational structure that has been
   expressly created for managing safety.

    Safety and Health Committees / Teams Establish Company
     Safety and Health Policies.
    Central Safety and Health Committee / Team chaired by (Insert
     Name)
    Use Team Building Techniques to build a cohesive safety team
    Designated staff Safety Team Leaders
           Copyright EPL for Residential Inc.                          14
Organization for Safety

Safety, like product or service quality, productivity, human
resources, and finance, can be managed effectively. Their needs to
be an organizational structure to plan, lead and assign safety
responsibilities across the entire organization. Safety committees
are the key component of this organizational structure. Section 6 is
devoted to setting up a functional safety committee. Another
element of the safety organization that needs to be addressed is the
assignment of a Safety Team Leaders and Safety Team
Administrator. It should be recognized that this assignment is not
an assignment of all safety responsibilities to one individual or
department but rather the assignment of responsibility to provide a
knowledgeable safety staff resource to the line organization.

The committee is a valuable part of your safety efforts. It is
especially important in identifying and communicating problems
and solutions throughout the organization. Effective safety
committees, through their membership, can help build the safety
and Zero Accident philosophy within a Company. The committees
must work to maximize the involvement of all employees at all
levels in the safety effort.

Since safety is everyone's responsibility, one person or department
cannot develop, communicate and enforce the safety program for
the entire organization. The committee, because it has active
management leadership and involvement, has the support
necessary to effect change throughout the company.




        Copyright EPL for Residential Inc.                        15
Membership: The safety committee should be chaired by a
member of senior management or team leader. It should also
include other managers from the operations side of the
organization. Hourly and salaried employees should be
represented on the committees and task groups on a rotating
basis.

Leadership: The chairperson should be a strong leader who is a
known champion of safety. The safety administrator should serve
as the secretary for the committee. The Safety Team Leader and
senior management should rotate as chair the committee.
Chairmanship by a senior executive also demonstrates to the rest of
the organization management's commitment.

Function: Meetings should be held on a monthly schedule
established in advance. Written minutes of the meetings should be
kept. The agenda of each meeting should follow a standardized
format. The format should include at least the information, which
is shown on the attached sample Safety Committee Meeting
Minutes form. The minutes should be distributed to all members
of senior management and appropriate line management and staff.
Posting of the minutes for all employees to read improves the flow
of information and is further evidence of management's
commitment to safety.

Authority: The safety committee, with senior management
representation and leadership from the line side of the
organization, has the authority to recommend improvements in the
organization's safety management system. Management must be
responsible for implementing the changes and reaching the goals
and objectives that are set by the committee.




       Copyright EPL for Residential Inc.                       16
Activities: Some of the activities addressed by the safety
committee or team leader should include:

      Overall safety program administration
      Safety rules and procedures
      Safety education and training programs
      Safety audits and inspections programs
      Employee health and environmental programs
      Fire and emergency preparedness programs
      Injury review process
      Loss trending and analysis

These activities are really responsibilities that need to be assigned.

The safety committee addresses these responsibilities from an
administrative perspective, as a form of quality control check.

Where the committee identifies that the quality of the programs
need improving they may recommend changes.

Injury Review Process: All workers’ compensation injuries and
other accidents must be reported within 24 hours.

All lost-time injuries should be reviewed.

Senior management, team leader and the safety committee should
routinely review all injury review reports to make certain that the
timeliness and quality of the reviews is satisfactory. Periodic
audits of the recommended corrective actions should be done to
make sure that proper action was taken. The team leader should be
assigned the responsibility of trending accident statistics.




        Copyright EPL for Residential Inc.                          17
3. Line Responsibility and Accountability - The line organization is
   held responsible and accountable for achieving safety performance
   goals and objectives.

      Safety and Health Responsibilities should be clearly defined for
       all Managers, Supervisors, and Employees.
      Implement Safety Policies and Procedures in all Areas
      Conduct Safety Meetings with their Units
      Set a Good Example
      Motivation
      Reward safety performance
      Show that you care
      Encourage ownership and safety participation

       Line Responsibility and Accountability

       Responsibility: All line managers, supervisors, team leaders,
       and leads should have clearly defined safety responsibilities in
       their job or position descriptions. (See section 2.3.1.) Those
       responsibilities should include, but not be limited to, the
       following:

          Communicating the Company and company's safety vision
           and values on a continuing basis to their employees
          Establishing and communicating clear safety performance
           objectives for all employees who report to them
          Verbally communicating to employees about safety on a
           routine basis through various formats such as safety
           meetings, one-on-one job discussions, and performance and
           salary reviews
          Supervisors must continually recognize unsafe acts,
           behaviors and conditions; correct them promptly and coach
           the employee in a positive manner to recognize the unsafe
           act, behavior or condition and how to do the job safely
          Recognize safe work practices, acts and behaviors and
           reinforce them with POSITIVE feedback to the employees




            Copyright EPL for Residential Inc.                        18
          Identifying safety and health training needs among their
           direct report employees and then providing the training
          Actively participating on safety committees and task groups
           when requested
          Enforcing safe work practices, rules and procedures
          Demonstrating through their non-verbal actions that they
           fully support all safety regulations
          Proactively identifying opportunities for safety performance
           improvement in both their areas of responsibility and other
           areas of the organization
          Encouraging employee input into safety matters by
           establishing open, trusting lines of communication


    Authority and Accountability: With clearly defined safety
    responsibilities of management, leadership must provide the
    necessary resources (training, staffing, time, money) and authority
    that will enable the leader to carry out their responsibilities. When
    this support and authority has been transferred, line managers and
    supervisors should be held accountable for meeting their individual
    and department safety performance objectives. Their safety
    performance should be routinely evaluated as a part of
    performance reviews and salary increases.

    Line management must not delegate away or abdicate their safety
    responsibilities to other employees or staff members.

4. Safety Review and Improvement - Continuous improvement of the
   safety management system through a systematic process of
   problem identification, root cause analysis, solution generation,
   and strategy implementation.

   Safety Audits
   Incident / Accident Review
   Conducted by line management/immediate supervisor/Team
    Leader
   Immediate reporting (within 24 hours)
   Basic steps in accident reviews will be expanded on.

            Copyright EPL for Residential Inc.                        19
     Safety Review and Improvement

     Just as quality and service need a process to continually identify
     deficiencies within the organization that cause the quality of the
     product or service to suffer, safety improvement follows the same
     process. There exists a need for a problem identification,
     resolution, implementation and measurement process in any
     company.




  Monitor the impact
                                                    Identify safety
  of solutions on the
                                                      problems
       problems


                          Safety Review and
                        Improvement Process



Develop and implement                         Determine root causes
 solutions to correct                          of safety problems
   safety problems




     Safety problem identification systems: Safety problems are
     identified through a variety of proactive and reactive means. Some
     of these include:

    The accident reporting system. Without a means to report accidents
     or near misses, many opportunities to improve safety performance
     will be lost.

    Accident data analysis and trending activities identify the historical
     sources and nature of loss within the organization so we can learn
     from past mistakes and hopefully prevent future losses.




               Copyright EPL for Residential Inc.                       20
   Safety audits and inspection programs should be designed to
    identify potential sources or causes of loss so they can be
    corrected.

   Feedback systems involving employees on product installation,
    safety, and service must also be in place.


    Identifying root causes of safety problems: Once a problem is
    identified, the root cause has to be determined. Injury review is
    one method. Others include proactive analyses such as Job Safety
    Analysis, Process Safety Hazard Analysis and Safety Management
    System Analysis. Unless the root cause is identified and
    eliminated you will only be working on the symptoms. The
    problem will remain.

    Problem resolution: Solutions to most safety problems usually lie
    within the hearts and minds of the people in the organization.
    Therefore you should involve those people who are affected by the
    problem in coming up with the best possible solution. When you
    do, you increase their buy-in and chances of success.

    Part of the process for developing solutions should include
    developing an implementation plan. That plan should identify who
    is responsible, what actions will be completed by what date, and
    what measurement criteria will be used to determine how effective
    the solution was in eliminating the safety problem.

    Monitoring the impact: By measuring and monitoring the
    implementation of the solution and the ultimate effectiveness, we
    can identify opportunities to improve the safety management
    process. Remember that you should be looking for continual,
    incremental change that is driven by an involved work force and a
    committed, dedicated management.




           Copyright EPL for Residential Inc.                       21
5. Safe Work Practices and Procedures - Through the use of tools
   such as Job Safety and Hazard Analysis, safe work practices and
   procedures are created for all jobs. They then become the
   benchmarks against which behavior can be measured.

      Standardize Work Methods for Each Job
      General and Specific Rules
      Discipline

   BETTER PRACTICES AND SAFE WORK PROCEDURES

   Better practices and safe work procedures should be developed for
   all jobs, job tasks and potential emergencies within the
   organization.

   The development of these should first be prioritized based upon
   prior accident frequency and severity history or the potential
   accident severity in the absence of any meaningful history. Your
   manager should have copies of your frequency and severity history
   in an employee file.

   Safety should be incorporated into the development of any job
   procedure, along with consideration for quality and productivity.

   Where there is a conflict between productivity and safety, safety
   considerations should take precedence.

   Types of safety rules and procedures: The Company’s need to
   develop the “Better practices”, rules and procedures that apply to:

    Housekeeping standards in each department or work unit within
     the department

    Specific job Safety Hazard Analysis, for example driving a
     forklift truck, performing a specific maintenance practice on a
     piece of equipment, lifting properly, or operating a piece of
     machinery.



           Copyright EPL for Residential Inc.                          22
    Non-routine tasks such as entering a confined space or trench or
     performing welding and cutting operations outside of the
     confines of the welding shop. Many of these types of tasks
     frequently require a permit system.

    Emergencies and disasters where advanced planning and strict
     conformance to set procedures is essential to minimize injury or
     damage. Examples include response to chemical spills, medical
     emergencies, fires, and threat of severe weather.

    Frequently overlooked, but equally important, are safety related
     rules and procedures pertaining to the purchasing of equipment
     and supplies and the use of outside contractors to perform work
     on-site.

    Implementation of safety rules, procedures and “Better
     practices” will be up to the team leaders to implement these
     items.

    Job standards, business planning and performance
     improvement: Without adequate job safety procedures,
     planning and standards there can be no real, lasting safety
     performance improvement. Improvement can only come about
     when we know that:
    Correct, safe procedures have been established
    They have been properly communicated
    Employees have been trained and they know, understand and
     are following the procedures.

6. Safety Communications - On going and effective safety
   communication systems are established that address verbal, written
   and more importantly, non-verbal communications with managers,
   employees and the public.

      Two Way with Feedback Loop to Ensure Understanding
      Meaningful and Timely
      Suggestions
      Methods to Communicate
      Evaluate Communication Effectiveness


           Copyright EPL for Residential Inc.                       23
SAFETY COMMUNICATIONS

Communication is one of the most important yet often most
overlooked components of the safety management system. You
need to be acutely aware of the safety communications that you
consciously and unconsciously send to employees, contractors and
communities through your verbal, written and non-verbal actions.
Of these three, the non-verbal actions are generally the most
powerful (positive or negative) in our communication efforts.


Communicating with a purpose: Every safety communication
should be done with a specific purpose in mind.

You first need to define your intended audience and the purpose of
the communication. Are you trying to educate, inform, influence,
motivate or get someone to take action? How you communicate
will affect whether you are able to achieve your goal in each of
these areas.

Once you have determined the audience and the purpose you need
to look at the method and frequency.

Will you’re safety communication be received better by employees
in face-to-face conversation, an individual basis, during a group
training exercise, or by sending a memo?

The importance of the communication issue is generally an
indicator of the frequency in which it needs to be communicated.
Suppose you are trying to change an entire organizational culture
to think about safety in a completely different manner than they
have for the last 20 years. You will have to communicate more
frequently and differently than if you were only announcing a
change in the injury review procedures.




        Copyright EPL for Residential Inc.                          24
                             Top
                             Sr.
                            Mgmt

                        COMMUNICATION
            Employees                   Shareholders
                          FEEDBACK        & public


                           Bottom
                            Line
                            Mgmt




Feedback: Without feedback, there is no communication. By
definition there is no communication unless there is understanding.
The only way to determine if there is understanding is through
feedback. For safety communications to be effective they need to
flow in both directions. Management and employees need to make
sure that they both understand what the other is saying.

The responsibility to develop and cultivate these open, honest
feedback channels within the company rests with senior
management, line management and team leaders. When they are
properly developed, trust grows. And with increasing levels of
trust, comes increased feedback and communication.

Walks the talk: Everyone needs to be acutely aware of their every
action and what it communicates to the employees about safety.
The non-verbal actions should support the safety values you are
trying to promote. If you do not walk the talk, your credibility will
be lost.




        Copyright EPL for Residential Inc.                         25
7. Safety Training - Safety training and education is a continual
   process that is based on performance requirements of the company
   and individual employee job needs to improve knowledge and
   skills in loss prevention.

      Develop a High Level of Safety Awareness
      Training Delivery
      Training Opportunities
      Outside courses and seminars
      Training Effectiveness

   Safety Training

   Safety training is just one component of a strategy to improve
   safety performance. Training is often expected to be the solution
   to organizational safety problems. Without the systems, structures,
   and tools there to support the training and the new skills and
   knowledge, your training dollars & time are being wasted.

   Training is a process: It starts with a needs analysis and is then
   followed by the development of a program that will meet those
   needs. It is then delivered in the appropriate medium (classroom,
   one-on-one, computer based). Finally it is measured through on the
   job performance criteria to determine if it was effective. Properly
   designed and delivered, it usually is.




                   Injury Review for
                 Supervisors Training
                       Program




           Copyright EPL for Residential Inc.                       26
Many companies relate training only to the classroom activity. A
program may be selected, not because it fits the need, but because
it was the only one available or it was the easiest to deliver.
Trainees go through the program and then back to their jobs. If
they don't have the chance to practice their new skills or
receive feedback on their performance from management, the
knowledge is quickly lost. The goal of any training is learning and
the goal of learning is improved performance.

Types of safety training: Every Company generally needs to
provide safety training in three broad areas:

   Regulatory
   Technical
   Safety management.

Regulatory training refers to what is required to comply with
OSHA, state or local regulations and ordinances. This type of
training should be considered a bare minimum. Each Company
has a legal responsibility to find out what standards apply to their
operations and what the training requirements are.

Technical training is job or task specific. This would include
training in the safe procedures to follow for a particular job or
process. Some technical training may also be required regulatory
training, for example lock out tag out.

Safety management training provides managers and employees
with the knowledge and skill they need to better support the safety
management system. This could include training in injury review
procedures; fundamentals of ergonomics, industrial hygiene or fire
protection; how to run an effective safety meeting; how to perform
behavioral based safety audits.

Training audiences: Safety training should include all levels of
management and hourly employees as well as outside contractors,
visitors, and vendors. It should also be included in NEO (New
Employee Orientation). And finally, all training should be
documented!


        Copyright EPL for Residential Inc.                          27
8. Post Injury Management- Providing TRTW or Transitional Return
   to Work to bring the employee back to work.

     Immediate Post-Injury Response
     Transitional Return to Work Program
     Performance Measurement

  Post Injury Management

  A. Immediate Post-Injury Response

      1. Employees consistently report injuries on time.

      2. Supervisors respond in a positive, caring and non-judgmental
         way.


      3. The Company utilizes the (INSERT AGENCY USED)
         injury/accident forms in place to document the details of the
         accident; the workers’ compensation, automobile and general
         liability coordinator is notified of the accident within 24
         hours of its occurrence.

      4. Offer to escort the injured employee to get medical attention.
         In the event of an emergency, requiring emergency attention,
         call an ambulance. It is recommended we go with the
         employee.

      5. Team leaders and supervisors review lost-time accidents
         immediately (within 24 hours) and document their findings
         and suggested corrective action.

  B. Transitional Return to Work Program

      1.     The Company is committed to returning employees back
             to work as soon as medically possible in order to
             minimize lost time.




           Copyright EPL for Residential Inc.                        28
  2.    The Company will have written job descriptions on file
        for Transitional Return to Work Duties. The support
        Company will assist and provide examples.

  3.    Company managers get a doctors release with restrictions
        and follow those guidelines.

  4.    An effort is made to return injured employees to their
        own departments first; however, injured employees will
        be shifted to a different department if suitable work is not
        available in their current department.

  5.    Supervisors support the company’s effort to
        accommodate injured employees and participate in this
        process.

  6.    Employees are aware of, and support, the company’s
        transitional return to work program

 C. Performance Measurement

  1.    The Company/district will closely monitor workers’
        compensation, automobile and liability losses, utilizing
        the monthly loss reports.

  2.    The Company will track incidents, lost days, and
        transitional return to work days on a regular basis.

  3.    The Company will share both injury statistics and loss
        data with managers, supervisors and employees to raise
        awareness throughout the company.




DRIVE ACCIDENTS & INJURIES
      DOWN TO ZERO!




       Copyright EPL for Residential Inc.                          29
6. SAFETY COMMITTEES: BETTER PRACTICES

  How do you put them together?

  The section deals with putting together a Company specific safety committee.

  The purpose of a safety committee is to get employees involved with the
  process.

  The team leaders should not shoulder the entire safety operation. Everyone
  should be involved with the process and take responsibility.

                      Responsibility promotes ownership!




                      Copyright EPL for Residential Inc.                         30
6.1   Structure & Organization

      How Should Company Safety Committees Be Structured?

      This is a frequently asked question for which there is no one perfect
      answer for all Company’s. We have learned that the most appropriate
      safety committee structure for a particular company depends upon the
      size and complexity of the company.

      In larger Company’s, there might be three levels of safety committee
      involvement:

      1. Central Safety Committee with responsibility for developing and
         managing overall safety policy and direction.

      2. A Company level Safety Committee responsible for coordinating
         safety activities at the location.

      3. Various Company subcommittees or task forces assigned to deal
         with specific safety problems and safety management system
         issues.

      The organization and function of both the Central and Company
      Safety Committee are essentially the same. Their primary difference
      is in the focus and scope of attention and activity being either
      corporate-wide or Company-specific. For our purposes we will
      focus on the Company safety committee and subcommittees.




                 Copyright EPL for Residential Inc.                        31
The Company Safety Committee

The Company level safety committee should include some
management and representatives from the field to enhance the
committee's credibility and acceptance throughout the Company. It is
a good idea to limit committee membership should normally be
limited to between five to twelve members. Groups larger than this
tend to be less effective in their decision-making processes. The
Company level committee's role is to make recommendations to
management for safety and health program improvements.


Company Safety Subcommittees

Company subcommittees/task forces are often formed to deal with
specific safety and health program areas or problems. Forming these
would depend on the size of the Company. These types of smaller
group activity are common in many companies. Some suggested
issues subcommittees could deal with are:

   Coordination of company-wide safety activities and determining
   annual safety program goals and objectives

   Establishment of general Company wide safety rules and
   procedures, the methods of communicating those rules and
   procedures for all employees

   The coordination and development of effective safety education
   and training programs throughout the company. These programs
   would include both new, existing and transferred employees as
   well as outside vendors and visitors in some situations.

   Coordination and monitoring of safety review and improvement
   processes, including injury review and audit/inspection programs
   or processes. This is done to ensure that the root causes of
   accidents are being identified and appropriate corrective action is
   being taken to help ensure a healthy and safe work environment.




           Copyright EPL for Residential Inc.                            32
   Coordination of programs to safeguard employee health, and
   ensure environmental exposures are recognized and controlled.
   This subcommittee often deals with industrial hygiene, ergonomic,
   employee wellness and internal and external environmental control
   issues.

   Coordination of Company-wide fire prevention and control
   programs, including emergency preparedness programs for fire,
   medical, chemical spill, and natural disaster emergencies.

   Coordination of off-job safety programs. The subcommittee would
   develop or identify the tracking systems to record and analyze off-
   the-job injury and illness statistics. Educational programs aimed at
   those off-the-job causes help to further demonstrate management's
   concern for the total safety of employees and their families.

   Coordination of all company-wide and department specific
   housekeeping, equipment/facilities maintenance and inspection
   programs.

Chairmanship of these important subcommittees could be assigned
either to members of the safety management team or other employees
who have a particular technical expertise in the area the subcommittee
is looking into.

The tenure of the subcommittee chairperson should be at least one
year. Chairpersons may rotate.

The rotational process will, over a period of time, expose more
managers and employees to task groups.

This will help to build and sustain the safety culture.




           Copyright EPL for Residential Inc.                       33
Organizing and Holding Safety Committee Meetings

Every Company is somewhat unique in their internal structure and
decision making/problem solving processes. As previously stated, no
universal formula for success exists for how a Company goes about
organizing a safety committee. However, the effectiveness of a
Company committee will ultimately be determined by a number of
factors:

     How the committee is organized to work within that Company.

     The operating guidelines the committee will follow.

     How well the membership reflects the demographics and interests
     of the workforce.

     The degree of authority and autonomy the committee has.

     Where final authority lies for decisions on the implementation of
     the committee recommendations.

Research on successful safety committees has found common traits
among them, irrespective of class or business and company structure.
Those common elements include:

A.      Company Mission Statement

The safety committee should initially develop a Company mission
statement or charter that reflects a consensus of opinion on what they
want to accomplish.

A mission statement or charter is really a statement of the basic
function of the safety committee or it's "reason for being." All plans
and actions that the committee undertakes should be evaluated against
the agreed upon mission statement. Committee members should be
continuously assessing whether the work of the safety committee is
moving the organization towards mission of the committee. From this
core mission statement should come specific goals and objectives that
will support the mission.

A mission statement addresses four key elements:

             Copyright EPL for Residential Inc.                          34
1. Purpose
   Why does the safety committee exist? What will be the hoped for
   end result from the committee's work and the other organizational
   resources that will be required?

2. Values
   What does the Company and the safety committee believe in
   regarding employee health and safety, customer safety,
   environmental safety, community safety? Are those values
   positive and appealing? How do these values support the overall
   business strategy?

3. Standards and behaviors
   What behavioral standards of the committee members will support
   the business strategy and values of the business? Are the
   behavioral standards sufficiently clear that safety committee
   members will be easily able to judge whether they are
   demonstrating the desired behaviors?

4. Strategy
   Does the strategy of the safety committee support the overall
   business strategy of maintaining or increasing competitive
   advantage, entering or expanding markets.

An example of a mission statement for a safety committee
following the four key elements listed above might be:

"Our mission as the Company safety committee for ABC (Company
ABC) Inc is to identify the sources of actual or potential injury, illness
or other loss to the employees, our customers, the communities in
which we operate and the environment. We believe that the safety
and health of our employees, products and services is of the highest
priority if ABC is going to achieve significant competitive advantage
in the marketplace. As members of the safety committee we
recognize that others look to us for safety guidance. They will judge
our commitment to safety excellence by the safety behaviors that we
exhibit. Therefore we will demonstrate our commitment by exhibiting
safe, positive, pro-active behaviors at work and off-the-job."




           Copyright EPL for Residential Inc.                          35
B. Policies and Procedures

  When a committee is formed, certain policies and procedures
  should be set forth in writing to cover:

  1. Scope of the safety committee activities

  2. Extent/level of the committee's authority

  3. Committee membership and service length

  4. Standing subcommittees

  5. Procedures for accomplishing committee work

      a. Time, place and frequency of meetings

      b. Attendance requirements

      c. Order-of-business to be conducted at each meeting

      d. Meeting protocol (i.e. parliamentary procedures)

      e. Records to be kept. Minutes should be kept of all committee,
         and subcommittee meetings. A standard reporting format
         and distribution convention should be established. As a
         minimum, the minutes should include:

        1) Date of the meeting
        2) Members in attendance and absent
        3) Opening comments by chairperson
        4) Report summaries by each subcommittee or task group
        5) A review of accidents, property losses, and significant
             near misses that occurred since the last meeting, their
             causes, and an evaluation of the quality/thoroughness
             of the accident investigations that were completed.
        6) Committee member assignments for the next meeting
        7) Closing comments
        8) Date, time, and place of next meeting


          Copyright EPL for Residential Inc.                       36
   Minutes should be sent out within a week of each meeting.
   Committees should generally meet at least monthly. The
   chairperson should distribute an agenda beforehand. When a
   committee member is unable to attend a scheduled meeting, a
   qualified representative should be sent in his/her place.

C. Roles and Responsibilities

Many safety committees suffer from a lack of clearly defined roles
and responsibilities of the committee members. People come to the
meetings not knowing what their particular role as a member is and
spend the meeting reacting to situations as the meeting unfolds.

The following are some common roles and responsibilities of safety
committee members. Some roles, such as a facilitator, may be
synonymous with the committee chairperson. On other occasions an
outside facilitator, separate from the chairperson, may need to be
brought in. The committee may be struggling with a problem and
needs an unbiased outsider to help them understand the "process" of
their meetings. Other roles, such as that of the scribe and timekeeper,
may be combined into one role of the safety committee secretary.

1. Safety Committee Chairperson

   The chairperson has several overall primary responsibilities as the
   leader of the committee. Those responsibilities are:

      To help create an open, participative environment in which all
      members can freely take part in discussion and decision-
      making.

      To help the committee as a whole manage the agenda items
      before them within the allotted time frame of the meeting.

      To help the committee build a sense of teamwork working
      towards commonly understood and shared safety and health
      goals.

   The chairperson's specific responsibilities before, during and after
   the meeting should include:


           Copyright EPL for Residential Inc.                         37
  Before the meeting

     Review previous meeting minutes:
     Prepare and distribute the agenda for the upcoming meeting:
     Make necessary arrangements for guests, videos, & training:
     Arrange and/or confirm the meeting time and place with
     members:
     Arrange for any other necessary support materials to be used
     during the meeting:

  During the meeting

     Get each member involved in the discussions and assignments.
     Maintain order.
     Do not allow any one person to dominate the meeting.
     Clarify statements when needed to avoid confusion.
     Keep the meeting moving on schedule per the agenda.

  After the meeting

     Review and approve the meeting minutes before they are
     distributed to the other committee members and management.

    Complete personal committee assignments.

2. Safety Committee Members

  Members’ responsibilities include:

     Making sure they clear their agendas so they can attend all
     committee meetings.

     Arrange for a competent alternate to attend the meeting in their
     place when schedules or conflicts arise.

     Contribute ideas and take an active part in discussions.

     Respect the opinions of other members by listening attentively,
     not criticizing and seeking to understand the perspective behind
     the other person's opinion.

         Copyright EPL for Residential Inc.                         38
      Assist with program development work and committee
      assignments.

      Evaluate past and present safety practices, procedures and
      results against targeted loss reduction goals.

      Set a proper example for safety at all times in the facility when
      outside of the safety committee meeting.

      Be thorough and persistent in all safety matters.

      Be sincere when dealing with safety issues.

      Complete their personal committee assignments and follow up
      on overall committee recommendations in general.

3. The Scribe, Recorder, Note-taker and/or Secretary

During most meeting activities, the leader or facilitator's function is to
direct the discussion, make sure ideas flow freely and clarify
understanding of ideas that are presented. During activities such as
brainstorming, it is difficult, if not impossible, to listen effectively
while at the same time writing. Therefore someone needs to be the
scribe or recorder.

The role of this person is to:

   List the ideas presented during brainstorming or other group
   discussions on a flip chart, board or pad so that the
   leader/facilitator is free to lead discussion.

   Provide a public record of the meeting and avoid having each
   member keep their own notes, which may in fact be in conflict
   with each other's notes.

   Record the stated desired meeting outcomes of each member of the
   group at the start of the meeting, i.e. - "What do you want to
   happen as a result of this meeting?"

   Record/document the meeting ground rules or operating principles
   for reference during each meeting.

           Copyright EPL for Residential Inc.                           39
   Record important decisions made during group discussions and for
   items on the meeting agenda.

   Record action items, assignments and targeted completion dates
   that become "old business" at the next meeting and personal
   assignments for each member.

   Prepare a draft copy of the meeting minutes to submit to the
   committee chairperson for approval.

   Distribute meeting minutes to all committee members and other
   interested members of management, bargaining units and
   employee groups within one week after the meeting.

4. Facilitator

When either the chairperson is acting as the facilitator or an outside
facilitator is brought in, that role should be clearly understood. Good
facilitation skills generally require training and extensive practice.
Some of the skills of a good facilitator are:

   Monitoring input from the group and bringing out the opinions of
   those who are less assertive within group settings.

   Testing for accurate listening by frequently repeating back to the
   message sender what the facilitator thought the person said.
   Clarifying for the group as a whole.

   Acting as a gatekeeper. To control participation so everyone has a
   chance to participate and no one person dominates the discussion.

   Being neutral in discussions. Helping the group to better
   understand their "process" for working together that may be
   constructive, destructive or both at certain times during the
   meeting.

   Reflecting out loud before the group on where they are going with
   the discussion, are they resolving internal conflicts, does the group
   "process" seem to be working?



           Copyright EPL for Residential Inc.                           40
  Knowing the difference between process and content. Content is
  what the group is working on. Process is how the group works. A
  good facilitator helps the group stay focused on process.

  Enabling the group to reach consensus on decisions. This does not
  mean that everyone agrees with every majority vote but that they
  agree to live with and work towards the decision made by the
  committee as a whole.

5. Timekeeper

  The chairperson, facilitator or one other person may play this
  function on the committee who may be designated as the
  timekeeper for that meeting. His/her role is making sure that the
  meeting stays on track with the agenda items and the time allotted
  for the safety committee meeting. When time is extended beyond
  the anticipated time frames, this person needs to feel free to speak
  up to the group about keeping on schedule. It is then up to the
  facilitator or chairperson to suggest either that:

     The discussion item is tabled to another meeting.

     Group consensus is needed on whether they want to continue
       the discussion.

     If they do continue the discussion should they either extend the
         meeting time allotment or cut other items from the agenda?




          Copyright EPL for Residential Inc.                         41
6.2   Forming a New Safety Committee - An Exercise

      When a Company makes a decision to form a new safety committee,
      frequently asked questions are "How do we get started?" and "What
      should we do during our first meeting?" The following exercise may
      be of assistance in this area.

      Objective of the Exercise

      To use team-building exercises for a newly formed safety committee
      that will help the people get acquainted with each other and, as a
      group, set guidelines and procedures for future safety committee
      work.

      Method:

      This exercise uses a four-step method.

      Step 1 is designed to develop a realistic priority level among the
      committee members of where they place the priority of the
      committee's work in relation to their other job priorities.

      Step 2 allows members to share their expectations and concerns about
      the safety committee with each other.

      Step 3 helps the members clarify the new committee's goals and
      objectives.

      Step 4 helps establish operating guidelines that the committee will
      follow when assigning work, making decisions, and solving problems.

      These steps could be accomplished within a two-hour time period.
      Keep track of the time to make sure that you allot ample time for each
      step.




                 Copyright EPL for Residential Inc.                        42
Step 1 - Developing Realistic Priority Levels

The manner in which people are selected to serve on safety
committees varies from organization to organization. Some may be
assigned to the committee by their manager or by virtue of their
position in the company. Other members may be selected from a pool
of volunteers. Because of these variations in selection, the
commitment and time that people are willing to devote to the
committee can range from high to low. The following exercise can be
useful in developing realistic priority levels and assessing the
commitment of the committee members.

1. Draw a vertical line on a flip chart or white board that represents a
   scale ranging from 0 to 100 in increments of 10. One hundred
   represents the highest priority level. Ask each person on the
   committee to rate or quantify how his/her assignment to the safety
   committee ranks with his/her other work priorities. For example, a
   person may feel that the safety committee work rates a 50 on
   his/her priority scale.

   Next ask each person to write down the amount of time that he/she
   reasonably would expect to be able to devote to committee work
   each month.

   Then ask each person what their ranking is on the priority scale
   and their expected time commitment. When all people have
   responded, you should summarize the priority rankings and time
   commitments.

2. Give each person the opportunity to explain his or her individual
   priority and time rankings. From this exercise, the team can begin
   to get an idea of where the safety committees work ranks as a team
   priority overall and how much time the members are going to be
   willing to devote to committee work. People who rate the safety
   committee work higher on their list of priorities and who have the
   time to devote may be able to handle heavier committee
   assignments.

   This open discussion can help reduce future resentment among the
   committee members who may feel that others are not pulling their
   own weight. As the safety committee matures, it may want to

           Copyright EPL for Residential Inc.                         43
   periodically revisit this step as people's commitments and work
   priorities change over time.

Step 2 - Sharing Expectations

Write the following questions on a flip chart and then allow each
committee member five minutes to answer the following questions:

1. What is your greatest concern or worry about working on the
   safety committee?

2. How would the safety committee function if everything were
   perfect?

3. Describe what the safety committee would be like if everything
   possible went wrong.

4. What actions need to be taken to be sure that the safety committee
   becomes an effective, working team?

Write down the major concerns and expectations of the committee
members on the flip chart. These then become the basis for future
agendas and planning sessions, as well as serving as a reality check
from time to time.

Step 3 - Clarifying Goals and Creating a Mission

Lead a group discussion to identify what the members feel is the
safety committee's basic function or reason for existing. From the
responses, the group should compose a charter or core mission
statement for the committee. This mission then becomes the yardstick
by which all plans and actions should be evaluated.

The committee members should be constantly asking themselves:

"If we continue the activities already outlined, will we accomplish
what our mission statement says?"

From the mission statement should come various goals and specific
objectives for both the short term and long term. The committee is
now ready to make specific assignments to the members.

           Copyright EPL for Residential Inc.                          44
Step 4 - Setting the Committee's Operating Guidelines

The newly formed safety committee needs to establish some initial
guidelines covering both how the whole committee and individual
members will work. The guidelines should be changed when they are
found to be inadequate for getting the work done or when other
conditions change. These guidelines should clarify actions and roles
and reduce the confusion about how things are supposed to function.
These areas are often the source of conflict within safety committees
and other working groups.

You should lead the committee through a guided discussion that
addresses the following issues:

   How will the committee make decisions? Will decisions be made
   by majority vote, team consensus, left to subcommittees that report
   to the major committee, or be left ultimately to the decision of the
   committee chairperson? Consensus means that people are able to
   say that the decision is sound, and although it might not be one that
   they would have made, they are nonetheless willing to support and
   implement the decision.

   What will be the committee's basic method for work? Will the
   committee assign work to individuals or will they have various
   subgroups assigned to projects?

   How will the committee make sure that everyone has a chance to
   participate in discussions and present their ideas and concerns?
   For a committee to be effective, people have to feel that they can
   openly discuss issues and concerns. The committee needs to
   consider how members can put items for discussion on the agenda.

   How will differences between members or subgroups be resolved?
   With any committee, there is likely to be differences of opinion
   and open disagreement that can disrupt and sidetrack the
   committee. The committee needs to come to some consensus early
   in their formation about how these types of disagreements will be
   handled. How will compromises be reached? Who will arbitrate
   them? Do we need a time limit for open discussions of
   differences? Should we use simple majority voting to settle any
   differences? Answers to these types of questions will help to form

           Copyright EPL for Residential Inc.                        45
   some initial guidelines that can be improved upon as the committee
   matures.

   How will the safety committee make sure that the assigned work is
   completed?

   A frustrating part of safety committees is how to deal with the
   members who come to meetings unprepared or don't complete their
   committee assignments. The committee may have as one of its
   guidelines a statement to the effect that: "No one will be given or
   will accept work if the person honestly knows they will not or
   cannot put in the required energy that the assignment calls for."

Committees should report in their minutes what the assignments were
who is responsible for each one, the dates for progress reports and
final completion of each assignment.

When assignments are not completed, the committee chairperson or
the joint committee may meet with the member through some
established review mechanism.

How will changes be made when results do not meet expectations?

There should be guidelines that allow periodic reassessment of results
by the committee or individual members. Can these results oriented
discussions be called at any time? Should the committee incorporate
a "How are we doing?" as a part of every committee meeting?

The important thing to remember is that the committee members
should feel free to express their opinions and expect open and honest
discussion from other members on all issues. If there is this type of
atmosphere, coupled with motivated individuals who believe in the
work of the safety committee, there should be infrequent calls to
examine results that are based on poor performance.

The answers to these questions should be captured and used as the
basis for formulating some written guidelines for the safety committee
members to follow. Each member of the committee should receive a
set of the guidelines. As previously stated, the committee should
periodically review all of the guidelines and update or change them
when needed to improve overall performance.

           Copyright EPL for Residential Inc.                       46
NOTE: It cannot be emphasized strongly enough the importance of
taking the time to go through team building exercises. It is especially
important during the formation and initial stages of development of a
new safety committee.

It is important to remember that anytime you have new people joining
a safety committee as active members you are forming a new team.

For this reason, many successful safety committees go through short
team building exercises at the start of their meetings on a continuing
basis.




           Copyright EPL for Residential Inc.                            47
6.3   Creating a Safety Business Plan


      Why a Plan is needed?

      The next step in moving toward improvement is the creation of a
      safety plan. The packaging and presentation of that plan will be
      critical if you hope to gain the commitment of the Company.

      They are unlikely to support the proposed safety management system
      changes if you do not present your action plan in terms of their
      interests. Those interests typically include:

         How will the changes positively impact the strategic goals and
         objectives of the organization?
         How long will it take before results can be expected?
         How much will the proposed plan cost in terms of outright
         expenditures, reallocation of resources, and people's time?
         What problems can be expected during the implementation of the
         action plan?
         What is the expected cost/benefit ratio, ROI (return on investment)
         and/or payback period if the plan is successfully carried out?

      Developing an Safety Plan

      It is highly unlikely that a Company will be able to address all of their
      safety management system deficiencies with one broad, sweeping
      plan. Therefore, you need to prioritize and focus your program
      improvement and development actions. Criteria for prioritizing those
      actions may include:

         What actions need to be conducted in a sequential order so that
         future actions can build upon each other? For example, a
         recommended action may be to set up a computerized hazard
         communication MSDS database that is easily accessible to all
         employees. Before that can happen, there may be a need to buy
         additional hardware to locate throughout the facility to make
         access easier.

         What actions are of highest priority because the present system
         does not provide adequate controls to prevent serious injury or
                 Copyright EPL for Residential Inc.                          48
   illness potential, and/or property or environmental damage
   potential?

   What actions represent easy, quick wins that can help build
   confidence and commitment to the improvement process underway
   in safety?

An example of a priority rating system that is based on hazard
potential uses the following priority classifications:

Priority 1 -- The most serious (unsafe) activity or work practice or
condition, which could cause immediate loss of life, permanent
disability, or significant damage to physical assets?

Priority 2 -- Those unsafe activities, behaviors, or conditions that
could lead to serious injury or illness and/or damage to physical
assets?

Priority 3 -- Those unsafe activities, behaviors, or conditions that
might result in a illness or injury and/or some damage to physical
assets that will be recorded?

Priority 4 -- Those minor unsafe activities, behaviors, or conditions
that are improper but have little chance of causing injury or property
damage?


Presenting Your Action Plan to Company Leaders/Whole

Most people do not have the luxury of several hours in which to
present safety action plans to senior management. 15 - 30 minutes is
the usual.

Because of this, it is important to prepare your presentation to get vital
information across quickly. You must relate your plan to frequency,
severity and time, and how the achievement of the action plan goal
will positively impact the organization's bottom line and/or strategic
direction. Steps to take in your presentation are:

1. Describe the overall areas of concern that you have with the
   present safety program (safety management system) and give some
   specific illustrative examples to support your position.
           Copyright EPL for Residential Inc.                            49
2. Describe one or two problem areas that you feel should be tackled
   first, again using examples to clarify the current situation and
   increase understanding for the Company.

3. Present what you feel is a cost-effective solution. Be sure to
   explain your reasons for choosing the solution. State the effect the
   solution will have on the problem.

4. Describe implementation concerns that management might have
   and how you would address those concerns, such as:

      How much will it cost?
      What manpower will be required?
      How much time will it require before it's completed?
      When would action start?
      What is going to happen when you start to implement the
      proposed solution?
      What other resources might be needed?
      What do you need the senior manager(s) to personally do?
      When might some initial results be expected?
      How will we know the plan has been successfully integrated
      into the operation?

Many International companies have successful employee suggestion
systems. The Toyota suggestion system is the best known. Toyota
encourages their employees to use the 5W2H approach when thinking
about and preparing their ideas before submitting them to the
"Creative Idea Committee." The 5W2H approach also provides a
good benchmark for preparing presentations on action plans to senior
management.

5W2H concentrates on 5 "W" questions of What (object), Why
(purpose), Where (location), When (sequence), and Who (people), and
2 "H" questions of How (method) and How Much (cost)? Looking
further at the 5W2H approach applied to formulating an action plan,
you can ask yourself:

   What (object) -- What is the work that is currently being done or not being
   done? Can this work be eliminated or should new work be started?
   Why (purpose) -- Why does this present work (or lack of work) necessitate
   the need for an action plan? Clarify the purpose of the action plan.

            Copyright EPL for Residential Inc.                                   50
   Where (location) -- Where will the work required to complete the action plan
   take place? Will it require traveling to other places to complete the work?
   When (sequence) -- When is the best time to do the work required in the
   action plan? What is the sequence of the action plan steps?
   Who (people) -- Who will be involved in the action plan? Have the right
   people been selected?
   How (method) -- How will the action plan steps be carried out? Is this the
   best way to carry out the plan?
   How Much (cost) -- How much will it cost to carry out the entire plan? How
   will the cost compare to the benefits?

Toyota evaluates each idea on a common framework of selection
criteria. Many of the criteria can be related to similar criteria that
should be considered when developing an action plan. For example:

   Benefits of implementation -- How will the action plan, if successfully
   carried out, contribute to management goals?
   Feasibility -- How difficult will it be to fully implement the plan?
   Applicability -- Can the solutions and/or steps proposed in the action plan be
   applied to other areas of the organization?
   Effects on others -- What will be the impact on individuals, departments or
   entire locations as a result of the implementation of some or all the action
   plan?
   Continuity -- Will the benefits of the action plan be long lasting or
   temporary?
   Completeness -- Is the action plan complete enough to ensure that it is fully
   carried out and has addressed all the pertinent problem areas that are needed
   to ensure successful change?
   Originality -- Does the action plan show creative, new approaches to safety
   problems or is it the same old approach that has been tried before with limited
   success?
   Research effort -- How much research will be required to carry out the action
   plan steps? Do we have the internal research capability or will outside
   resources be needed?




            Copyright EPL for Residential Inc.                                 51
Why Some Action Plans Fail

There are several common reasons why an action plan might fail.
Many of these are related to communication deficiencies and/or lack
of strong visible support and leadership from management. Common
reasons include:

   People don't know what they are supposed to do. A plan is
   developed but people are either not told or not told in specific,
   understandable terms what actions/results they are expected to
   achieve in a given time frame.

   People don't know how to do what they are assigned to do. For
   example, part of a plan may be to write up a new procedure
   manual. If this task is assigned to someone or a group of people
   who have never written procedures before, or have poor writing
   skills, or don't understand the job task, equipment or process they
   are supposed to write procedures on, the end result will be of poor
   quality without additional training, direction and support.

   People don't know why they should do their piece of the plan.
   If action plans are very detailed, containing many small pieces, it is
   important that all people who will be working on the plan clearly
   see the big picture. They need to know and understand why their
   small piece of the puzzle is a very important part of the overall
   finished puzzle.

   There are obstacles beyond a person's control. An example of
   this would be a plan that has received strong support and
   endorsement from a manager. If the manager leaves and his/her
   successor does not have the same level of commitment to seeing
   the plan carried out, the support may be withdrawn at a high level.
   The failure to achieve the results of the proposed action plan was
   not the fault of the employees working on the individual pieces.

   People don't think the plan will work. When assigning work to
   be carried out, it is important that the people who are assigned the
   work buy into the plan. Successful completion of an action plan is
   difficult enough with highly motivated and supportive people. If a
   person has doubts about the viability of the plan overall or their
   individual assignment, success will be difficult to achieve.
   Convince people the plan will work if carried out.
           Copyright EPL for Residential Inc.                          52
People think their way of achieving results is better than the
action plan's method. This is similar to the above bullet point,
except that in this case the person is already on board with the
concept -- they just have a better idea to achieve it. Their way may
be better. Listen to them. If management does not feel that the
person's new way is better than the planned way, then they will
have to convince them why the original plan is superior.

People aren't motivated or have a poor attitude. Identify the
people with the poor attitudes early. If their attitude can't be
quickly turned round, get them off the project. If they aren't
highly motivated, but are essential for the success of the plan,
identify their perceived consequences that are influencing their
behavior towards the plan. Once that is done, work on changing
their perception by modifying the consequences (reward systems,
recognition, talks from the manager about the importance of the
project).

A person is personally incapable of carrying out their piece of
the plan. This is not usually a problem with most action plans.
An example of such a situation would be if a plan required that a
safety procedure manual be created for Hispanic employees by
translating the existing procedures from English to Spanish. If the
person assigned that translation activity did not speak or
understand Spanish they would be personally incapable of
performing.

Not enough time is allocated for people to effectively perform
and complete their pieces of the plan. This generally happens
because of either poor planning or a lack of understanding of the
assigned task. Using the safety manual example again, an action
plan might be put together in January and call for a safety manual
to be completed in draft form by March 1. Having no previous
safety manual or experience in writing one, the people may find
that they need to do extensive research into existing regulations or
safety standards of other companies. Gathering data may take 6
months before a draft can be started.




        Copyright EPL for Residential Inc.                         53
      People are assigned to work on the wrong priority items. It has
      been said that if everything is a priority then nothing is a priority.
      As mentioned previously, safety action plans can involve many,
      many improvement areas. If the high priority and quick win action
      items are not addressed first, time may be spent on items that do
      not produce any visible results for a long time. Interest may
      decrease, sponsorship may waver and commitment may die.
      Careful prioritization is crucial.

      People give/get no feedback on work that is being carried out
      on the action plan items. Without feedback there can be no
      continuous improvement. Flawed documents and decisions can be
      made, although with the best of intentions behind them.
      Implementation of those documents and decisions will reveal the
      problems eventually that may have been caught earlier by an active
      feedback loop. Unfortunately bad press or poor morale that results
      from the ineffective work may sink the overall purpose of the
      original plan.

      Poor leadership and sponsorship for the action plan. Without
      active, caring and committed management support, and strong
      leadership from those in charge of the overall action plan, any plan
      has little chance of long term success.



Review the Example Safety Business Plan Form on the following page!




               Copyright EPL for Residential Inc.                         54
Team (or committee, task force, subcommittee)                                      Date

Issue (problem or idea) that needs to be worked on?



How does this issue impact safety and health?



What are the tangible (measurable) benefits of a successful improvement
plan?

What are the intangible benefits of a successful improvement plan?



Action plan steps proposed

Subtasks (what)                           Actions Responsibility (who)       Time (when)
                                          (how)




Action Plan Follow-Up

Subtask #     Who (name)?      What will they do?     How will they do it?   When will they do
                                                                             it?




                            Copyright EPL for Residential Inc.                                   55
6.4   Communications and Safety

      Communicating Activities and Successes

      The safety committee members should decide in the early stages of
      the committee's formation how they will be communicating
      committee activities and successes to the rest of the organization.
      They should develop a communication plan. Usually the safety
      committee is trying to help create change within the organization.
      Communication is a fundamental success factor in change
      management. Therefore, a carefully constructed plan is critical.

      The following points that should be included in a communication
      plan:

         What information should be communicated?
         What are the methods for communication?
         Who should information be communicated to?
         How often should we communicate?
         How will we determine the effectiveness of our communication
         plan?

      What information should be communicated?

      The committee needs to decide what type of information needs to be
      communicated to keep people informed about the good work that the
      committee is doing. The committee is a change agent. However, real
      lasting change does not take place unless people are interested in
      changing. Therefore the communications need to be directed at
      keeping people interested, showing them how the work of the
      committee is making the work environment safer and more
      productive.




                 Copyright EPL for Residential Inc.                         56
Meeting Minutes

Many safety committee communications are limited to a posting or
distribution of the safety committee meeting minutes. If this is a
committee's only communication method it is important that at least
the following information be included:

   Date, time, and place of each meeting
   Members in attendance and absent
   Outstanding old business status
   Accident/illness reports since the last meeting
   Year to date safety performance data
   Subcommittee/task group activity reports
   Guest speakers, special presentations/awards, and/or training that
   may have been given
   New business items
   Committee/member assignments for the next meeting
   Date, time and place of the next committee meeting


Safety Committee Mission and Purpose

If the safety committee has developed a mission or vision statement,
that information should be widely communicated to the entire
employee population. This communication tells everyone that the
safety committee is there to help the organization become a safer,
healthier place to work. The interests of the safety committee are in
common with the workforce. We often find that people know the
company has a safety committee but they don't know why it does.
With a powerful mission statement that is fully supported by
management, other employees may wish to become future members
of the committee.

The communication of this important piece of information can be
done at the time of new employee orientation, through mass mailings
to employee homes, incorporated in the (Company ABC) Inc.
newsletters, and by posting on common area bulletin boards.
Safety Success Stories

When individuals, employee work groups and safety committees are
able to achieve a small or large win in the safety arena, this
information should be widely communicated. It will help to build
           Copyright EPL for Residential Inc.                           57
confidence that the organization is able to solve its own safety
problems. It will help to increase or sustain the support of those
managers and employees whose support is needed for success. Others
who may have been sitting on the fence trying to decide if they should
join or support the safety committee may now decide to commit.
People like to be associated with winning teams.

Safety committees should also communicate safety successes from
other locations within their own organizations as they learn of them.
When those successes relate to similar problems the committee is
faced with, they may help to boost morale and increase that "can do"
attitude. Outside success stories can provide help persuade
management to commit to action. "If our competitor can achieve that
kind of reduction in worker's compensation losses, we should be able
to. Let's get going!"

Safety Failures With Important Lessons Learned

While people seldom like to talk about their organization's failures
and mistakes, some of these need to be talked about because they
contain powerful lessons. The lessons learned from analyzing the
safety management system after a major loss can create the desire to
change in people. Compelling changes in organization usually do not
come about without some pain first. The safety committee needs to
carefully examine system failures. They must decide which ones are
worth over-communicating about. Will that communication help to
begin the shift in thinking about safety that is needed?

What are the methods for communication?

Non-verbal: When talking about communication methods for safety
committees, people usually think about the written and verbal
methods. Safety committee members need to be continually thinking
about the non-verbal communications that they personally are sending
to others by their actions on a daily basis.

For example, if a safety committee member is working in an area that
requires certain personal protective equipment he or she had better
make sure they are wearing what is required at all times.

If a member of the safety committee does not take safety seriously,
why should other employees? When people hear one thing ("Wear
           Copyright EPL for Residential Inc.                         58
your PPE") from a person and then see something else (no PPE being
worn), they will be more strongly influenced by the non-verbal
communication.

Verbal: There needs to be consistency among the safety committee
members on the verbal messages they send, particularly so when
addressing a particular subject or policy. When an important safety
message is going to be conveyed by members of the committee it is
worth the time spent to rehearse what people are going to say and how
they are going to say it.

A study done by UCLA found that what people believe when you tell
them something depends 7% on the content, 38% on the tone of your
voice, and 55% on body language.

If the words coming out of a person's mouth contradict the way they
say them, their facial expression and body language, the person may
not be believable?

Written: Written communications should be clear, concise, easy to
read and without a lot of jargon. They should be carefully proofread
before they are released for typographical errors. Distribution of
safety committee meeting minutes that are full of grammatical and
typographical errors can reflect poorly on the committee and its work.

When the safety committee is preparing other types of written
communications, such as kicking off a new safety campaign or
program, it is important that the message be carefully crafted. The
committee knows what they want to say because of numerous
discussions and their own personal involvement in the issues but does
that message come across to the employee population who are not
members of the committee. It is beneficial to have someone outside
the safety committee read written communications before they are
released and then asked what they felt the intent of the release was.

The packaging of important written communications also needs to be
considered. Does the "communication package" provoke interest and
excitement? Does it display a creative new way of conveying a
message that might have been tried before? If a safety committee
thinks about the presentation of their messages in much the same way
that an advertising executive thinks about an advertising campaign,
there would likely be a lot more interest generated in safety.
           Copyright EPL for Residential Inc.                         59
With verbal and written communications, try presenting a safety
message in the context of how it will add value to another important
campaign that is underway (such as trying to achieve ISO 9000
certification). It will be that much more powerful and likely to be
accepted. Above all, with all safety communications - BE HONEST
AND TELL THE TRUTH!

Who should information be communicated to?

Communication methods will vary according to who the intended
audience for the communication is. The safety committee will
generally be communicating regularly to:

   Management
   Unions
   Field management
   Hourly employees

They could also communicate with other team leaders and safety
committees at Company locations, government offices, public
agencies such as fire and emergency services, and to (Company ABC)
International and (Company ABC) safety department and safety
equipment vendors.

A few points to keep in mind are:

   Keep the leadership team informed, particularly if their support is
   needed for the committee to continue to function. This would include
   senior management, middle management and union representatives.

   Keep the employee population informed. This can be through formal
   communications or informal daily contacts. The informal daily contacts
   are the best method of promoting the work of the safety committee and
   to keep in touch with the issues that are of concern to other employees.

   Understand clearly what boundaries senior management expects and
   permits the safety committee to communicate within. Communicating
   outside those boundaries before authority has been granted can seriously
   damage support for the safety committee's activities.

How often should we communicate?

           Copyright EPL for Residential Inc.                             60
There are no set rules on how often a safety committee should
communicate their activities to others in the organization. The
frequency of communication depends on a number of variables:
   Frequency of regular safety committee meetings
   Frequency of separate subcommittee or task group activities and meetings
   Importance of the issue that is being communicated
   Size of the audience that the issue being addressed will potentially impact
   Current gaps in information and understanding surrounding a particular safety
   issue
   Individual communication needs and desires of the Company leadership team
   Culture of the organization regarding communications
   Method of communication (verbal, written, formal presentations, etc.)
If people feel they are getting too much information that they don't
need they will generally tell you. If on the other hand you under-
communicate, people won't know what information they aren't
receiving.

Safety committee members should be consciously communicating
"safety" every day by their actions on the job. Every time a safety
committee member has any interaction with another employee of the
organization it is a potential opportunity to communicate. Members
should be communicating in these daily contacts that they care about
the other person's safety and the safety and health of the organization.

How will we determine the effectiveness of our communication
plan?

Determining the effectiveness of any communication effort can only
happen if there are feedback mechanisms in place. By definition,
communication does not occur unless there is full understanding on
both the message sender and receiver's parts. The following formula
illustrates this point:

INFORMATION + FEEDBACK + ADJUSTMENT =
UNDERSTANDING

The feedback loop in any communication process provides the vital
information that is needed to acknowledge understanding or reframe
and readjust the message so there is a common understanding.

This feedback loop can occur in many settings and situations. Some
of those are:

            Copyright EPL for Residential Inc.                                61
   Face-to-face meetings between safety committee members and departmental
   groups
   One-to-one meetings between a member and another employee
   Opinion polls
   Observation and interviews occurring during safety audits
   Daily observations of work behaviors to define and categorize safe and unsafe
   behaviors
   Training session feedback
   Changes in behavior of management to a more supportive safety posture
   Improvements or decreases in quality, productivity, and morale
   Safety suggestion systems

The safety committee members need to be continually and actively
soliciting feedback. Don't sit back and wait for it to come your way.
Collectively, the committee should be asking themselves "What are
we hearing out there?”, "How can we make our communication
methods more effective?"

The ultimate measure of the effectiveness of the feedback loop will be
the visible and dramatic reduction in employee injuries over time.
The safety committee should be gaining in stature within the
organization as a pro-active, results-oriented group. Recruiting
members should not be a problem. In fact there may even be a
waiting list of people wanting to serve on the committee!




            Copyright EPL for Residential Inc.                                62
6.4.1 Written Examples

      EXAMPLE ONE - Communications

      ABC (Company ABC)

      March 14, 2005


      TO:     All ABC Employees

      The Company Safety Committee has undergone significant changes in the
      last few months. As mentioned in my small group meetings last week, we
      are focused not only on identifying problems, but solving them. With the
      assistance of our corporate safety department we have been conducting
      training to accomplish this end.

      One of the efforts will be a series of subcommittees, which operate under
      the Safety Committee to proactively and aggressively seek to resolve some
      of the problems and issues we face. This approach is on target with the
      "Project Safety" a main objective of the Company. While members of the
      Safety Committee will serve on these committees we are seeking other
      employees from supervision, office, the shop floor of field who would like
      to participate. The five subcommittees initially selected are:

      1     Ergonomics
      2     Safety Policy, Rules and Procedures
      3     Accident Investigation Review
      4     Safety Communications
      5     Emergency Preparedness

      If you are interested in participating on any or these subcommittees of
      would like additional information about them, please contact me, Will B.
      Safe or any of the other Safety Committee members by Friday, March 30,
      2001.

      Safety Committee Members




            Copyright EPL for Residential Inc.                               63
EXAMPLE TWO - Communication

December 11, 2005

TO:            ALL EMPLOYEES

FROM:          SAFETY COMMITTEE

SUBJECT:       VOLUNTEERS NEEDED FOR SAFETY SUBCOMMITTEES


There are currently a limited number of vacancies on various subcommittees. If you would like to serve
on one please sign up below. Put your name, clock number and the number in front of the subcommittee
of which you would like to serve.

       1.      Safety Policy Committee
       2.      Ergonomics Committee
       3.      Emergency preparedness Committee
       4.      Communication Committee
       5.      Accident Investigations Committee
       6.      National Safety Week Observance (Note: This committee will serve from
               April - June only)

NAME                            COMMITTEE #                         ALTERNATE#




                             Copyright EPL for Residential Inc.                                     64
   6.5 SELF HELP MATRIX TO POTENTIAL SAFETY COMMITTEE CHALLENGES

   The following matrices will aid you in addressing some issue that the committee
   may encounter. By no means is this a cure all but it will start the problem solving
   process.
    PROBLEM                    VISIBLE SIGNS                  POSSIBLE CAUSES                  POTENTIAL SOLUTIONS
There is routinely       Ideas and discussion           Members may not be                  Members need to know that
little or no             accepted with little or no     comfortable in dealing with         disagreement is healthy, natural
disagreement             input from the other           conflict in a positive,             and that agreeing to disagree can
between members          members. Hesitancy to          constructive manner. If a new       improve the quality of the
during safety            confront/challenge ideas or    committee, members may not          recommendations if done in an
committee meetings.      raise questions about impact   be fully convinced that             open, honest manner. Review the
                         of proposed solutions. An "I   management really wants their       code of conduct. Are members
                         don't care, do whatever you    input on safety matters. Or, if     encouraged to speak frankly and
                         want to do attitude."          management routinely rejects        state their opinions, even if they
                                                        safety committee                    don't agree. Provide training in
                                                        recommendations with little         conflict resolution. Senior
                                                        feedback, members may be            management should provide
                                                        looking for the easy solutions.     regular feedback on all proposed
                                                                                            recommendations submitted by
                                                                                            the committee.
 Some members are         Heated discussions that         No code of conduct dealing          When an impasse is reached the
 inflexible and           reach a wall with both          with conflict resolution or         chairperson should call a break,
 defensive about          parties not wanting to give     reaching a consensus on             revisit the charter and code of
 their points of          an inch. Emotions run           issues so the committee can         conduct, and identify the parts
 view.                    high and start to erode         move on with their work to          of the inflexible person's
                          team work. Committee            the next issue. Chairperson         position that all/most members
                          begins to divide into           not facilitating the discussion     do agree with and can reach a
                          factions, each supporting a     properly, allowing all sides to     consensus on. If person's
                          given position.                 present their opinions. Are         position is not backed by facts
                                                          facts and data being                and data chairperson could ask
                                                          presented or is the member's        that issue be tabled until more
                                                          point of view based on              facts/data gathered by person
                                                          perception and emotion?             holding the point of view that
                                                                                              has created the impasse.
 Some members             Rambling discussions led        Lack of code of conduct or          Set time limits for presenting
 dominate the             by one or two people that       not following code if one           facts and opinions. Chairperson
 meeting                  don't go anywhere.              exists. Chairperson not             needs to feel comfortable in
 discussions, leaving     Dominant member sees            facilitating discussion and         calling for an end of discussion
 time for little input    committee as ego booster        limiting input from dominant        and need to now reach a
 by other members.        and platform for his/her        member so others have a             consensus on facts that we have
                          agenda. Chairperson does        chance to speak. Members            before the committee. Revisit
                          not try and stop the            not comfortable with dealing        code of conduct at start of each
                          dominant person.                with conflict in constructive       meeting. Actively solicit input
                                                          manner, no training in              from the less vocal members of
                                                          conflict resolution. No clear       the group. Clarify expectations
                                                          instructions given before the       and purpose of the discussion
                                                          discussion begins explaining        topic before the discussion
                                                          purpose/direction of the            begins. Lay some ground rules.
                                                          discussion by chairperson.          Provide training in conflict
                                                                                              resolution to members.




                                        Copyright EPL for Residential Inc.                                                       65
  PROBLEM              VISIBLE SIGNS              POSSIBLE CAUSES                    POTENTIAL SOLUTIONS
Proposed            Members satisfied with     Lack of training in technical,    Provide creativity training to the
solutions to        coming up with             regulatory and safety mgmt.       committee members to get them
safety problems     recommendations that       issues for committee              starting to think outside the box.
are typical         show little or no          members forces them to look       Provide additional safety training as
solutions that      creativity. Low volume     for old solutions that may or     needed so they fully understand the
show lack of        of ideas generated for     may not have worked in the        technical safety, regulatory, and
understanding of    consideration. "Let's      past. The members may feel        management issues involved in any
issues at hand.     slap something together"   inhibited to think outside the    given problem. Train in and then
They only           type of attitude.          box, to be creative and           use different problem solving
address             Members don't seem to      innovative. Chairperson may       approaches such as cause and effect,
symptoms, not       have much fun in           not be trying to stimulate        force field analysis, etc. Instill some
real root causes.   committee meetings.        new ideas. Also, members          sense of fun in the committee
                                               may lack skill and training in    meetings and subgroups. Routinely
                                               basic problem solving skills.     examine past solution strategies to
                                               No feedback or                    see what worked/didn't work and
                                               reinforcement from senior         learn from them. Senior
                                               management when good              management should provide
                                               solid solutions are proposed      feedback on the quality of
                                               and adopted.                      recommendations.

Other employees     Lack of volunteers when    Inadequate communication          Provide formal recognition to the
do not view         openings come up on        channels between committee,       members of the committee from
being on the        the committee.             employees, and management.        senior management. Provide
safety committee    Criticizing, joking, and   Lack of training given to         training to members on a continuing
as worthwhile,      deriding the work of       committee members in the          basis. Publicize the good work of
rewarding or        committee or its           past. Culture/perception that     the group with testimonials from
career enhancing.   individual members         safety committee is the police    those who are affected by the
                    causes committee           force trying to force safety on   committee's work. If the committee
                    members to ask             people. No positive feedback      is viewed as the safety Gestapo,
                    themselves if the time     or public votes of confidence     change that image by shifting the
                    and effort is worth it.    from senior management on         responsibility for the successful
                                               the good work the safety          implementation of safety into daily
                                               committee has done. No            operations to the line managers
                                               visible rewards offered for a     where it belongs. Have senior
                                               person's committee work.          management take an active role and
                                                                                 interest in safety and then
                                                                                 demonstrate their commitment.

The committee       Long meetings, large       Lack of consensus reaching        Train in and practice consensus-
takes a long time   number of carry over       process for committee             achieving skills. Let all committee
to make             items on the agenda        decisions. Chairperson not        members serve as facilitators at
decisions and       from previous meetings.    leading, facilitating             times responsible for bringing the
come to             "Let's table that" is a    discussions within allotted       group to agreement. Chairperson
consensus or        frequently heard phrase.   time frames. Low level of         may need to be more forceful in
majority            All of the items on        personal commitment from          keeping the group on track. Appoint
agreement.          meeting agenda are         members to take                   a time keeper and observer for each
                    seldom covered.            responsibility once decisions     meeting. Get feedback at end of
                                               are made. Lack of training        each meeting on the meeting
                                               for committee members in          process. "How did we do group?
                                               safety, problem solving,          What could we have improved about
                                               effective meetings, and           this meeting to make it more
                                               interpersonal skills.             productive and effective?" Provide
                                                                                 training to all members in basic
                                                                                 problem solving skills, how to
                                                                                 conduct/participate in effective
                                                                                 meetings. Look at code of conduct.
                                                                                 Include items as needed to address
                                                                                 the cause of lengthy, unproductive
                                                                                 meetings.
  PROBLEM              VISIBLE SIGNS              POSSIBLE CAUSES                    POTENTIAL SOLUTIONS

Committee           "You can't do that         Not enough facts and data are     Solicit feedback from senior

                                    Copyright EPL for Residential Inc.                                                     66
recommendations      around here."             presented to management        management on why
are routinely        Recommendations are       with the recommendations to    recommendations not accepted.
rejected by senior   viewed by senior          help them make a decision.     Gather additional information if
management for       managers as "pie in the   No cost/benefit analysis       needed. Conduct cost/benefit
implementation.      sky." Many are            provided. Committee may be     analysis prior to submitting
                     unrealistic and           overstepping their level of    recommendations and include that
                     unworkable.               authority in dealing with      information to support committee's
                     Management gives lip      some safety issues.            solutions. Seed recommendation
                     service to the safety     Chairperson not networking     ideas with members of management
                     committee but little      with major stakeholders        as the solutions are being developed.
                     other emotional or        whose support will be needed   Provide training to committee
                     resources support.        for recommendation             members as needed when solutions
                                               implementation.                aren't accepted because of real lack
                                                                              of understanding of the issues
                                                                              involved. Identify other
                                                                              stakeholders in the solutions and get
                                                                              their input and support when
                                                                              developing solution strategies.




                                     Copyright EPL for Residential Inc.                                               67
7. PROGRAM “BETTER PRACTICES”

  The following sections deal with “Safety Better practices” that make each
  program successful. There can be many components to the better practices that
  make up the entire program.

  This is a “how to” for the Company’s on constructing a program to best fit your
  needs. You must construct a program specific to your Company and use this as
  a resource to develop those. The reason being is that each Company needs are
  different and the Company’s need to take ownership of these programs.

  This entire guide is to be used as a tool to help the Company construct your
  own programs.

  Each Company needs to develop a safety guide to address your current
  accidents and injuries and address your exposures in the Company and on the
  job site.


  We all are responsible for safety in a Company.

  It is up to all of us to make a positive difference and be proactive in the
  prevention of accidents and injuries.




                       Copyright EPL for Residential Inc.                        68
7.1       Sample General Health and Safety Plan for Construction

          All employees in the Company need to understand and follow basic safety
          rules to ensure their safety and that of their co-workers.

          The following General Health and Safety Plan for Construction and
          Company Operations, is intended to provide the core of an effective health
          and safety plan for the Company.

          In addition, the plan contains a sample safety and disciplinary policy to help
          ensure employee compliance with safety rules and regulations.

          There is also an “Accident Repeater” Program in Section 13.

          This plan is for the Company’s use in developing a basic safety
          program. For the plan to be effective, it must reviewed and customized
          to fit the Company’s specific circumstances. Add any categories you
          need. Expand those areas that require more detail. Delete those areas
          that do not apply to your Company.

          This sample plan includes:

         General Company policies, including a Company safety policy letter

         Allocation of health and safety responsibilities between health and safety
          team leaders, project managers, superintendents, foremen, first line
          supervisors, managers, and all other employees

         Sample training rules and policies

         Hazard identification, assessment, and control policy

         Inspection guidelines

         Contractor weekly safety inspection report

         General workplace safety rules for construction sites




                            Copyright EPL for Residential Inc.                         69
   Basic safety rules for the following:
              Aerial lifts

              Compressed gas cylinders

              Cranes
              Electrical work

              Excavations and trenches
              Fire prevention

              ouse-keeping

              Industrial hygiene and occupational health
              Ladders

              Motor vehicles and mechanized equipment (more detail see

                 section)
              Personal protective equipment

              Safety railings and other fall protection
              Scaffolds

              Tools

              Welding and brazing



         This sample plan provides:

             Example safety policies to provide a general framework for a
              construction and Company health and safety plan; and

             Example disciplinary policies to enforce safety rules, a sample
              disciplinary notice, and a sample certification.

    This plan’s disciplinary provisions apply only to safety matters.

    The Company should make sure that this plan does not conflict with any
    material in its employee handbook and should modify any provisions that do
    not fit the employer’s particular needs.

    In addition, this General Health and Safety Plan for the Company’s is
    intended for at-will employees who have no contractual or other right to
    continued employment.

    The employer should modify this General Health and Safety Plan
    (particularly the disciplinary and notice provisions) for employees whose
    possible discharge or discipline is restricted, such as those protected by
    collective bargaining agreements.

                      Copyright EPL for Residential Inc.                        70
    Employers Covered

    All employers in the construction industry need to have a General Health
    and Safety Plan. OSHA requires that all construction industry employers
    effectively enforce safety rules to implement OSHA standards. This
    requires a General Health and Safety Plan as well as individual safety plans
    so that employees are subject to discipline and even discharge for failure to
    follow applicable rules and standards. In addition, OSHA believes an
    effective General Health and Safety Plan makes it less likely that the
    employer’s employees will suffer a fatality or serious injury.

    Related Plans and Requirements

    This General Health and Safety Plan for the Company’s is not designed as a
    substitute for any specific plans that may be required by OSHA for
    employers in the HVAC industry, including the following:
   Asbestos or Lead Control Plan

   Assured Equipment Grounding Conductor Plan

   Blood borne Pathogens Exposure Control Plan

   Confined Space Plan

   Emergency Action Plan

   Fall Protection Plan for Residential Construction

   Fire Safety Plan

   Forklift Safety Plan

   Hazard Assessment Plan

   Hazard Communication Plan

   Lock-Out/Tag-Out Plan

   Occupational Noise Exposure/Hearing Conservation Plan

   Respiratory Protection Plan




                           Copyright EPL for Residential Inc.                 71
                     GENERAL HEALTH AND SAFETY PLAN




Company Name


Street Address


City                          State                              ZIP code




Prepared by:



Print name of Person who Prepared Plan


________________________________                  ________________________________
Title                                             Phone number


________________________________                  ________________________________
Signature                                         Date




                            Copyright EPL for Residential Inc.                       72
             SAMPLE COMPANY SAFETY POLICY LETTER

It is our policy to provide a safe and healthy
work environment for everyone. A safe
environment does not occur by chance. It
requires everyone’s close attention and open
communication between management and
employees. Workers who notice hazards or
other safety problems, or who believe that they
need additional training, must notify their
supervisors immediately. Supervisors and
management must address the concerns of
workers and make sure that any problems are
fixed quickly.
Everyone is obligated to know and abide by the safety requirements and standards for their area or job.
Through their own “pro-safety” attitudes and practices, supervisors must instill a positive attitude in
workers. In return, employees must give training exercises and safety meetings the utmost attention and
must follow all safety regulations. Compliance with safety policies is a condition of employment and
must be taken very seriously. Failure to comply will result in disciplinary action, including termination of
employment for serious or repeated violations.

Nothing is more important to this company than your safety and that of your co-workers. Do not
think that safety and health are somehow at odds with productivity and quality. In fact, they go hand in
hand. Studies have shown that the safer a workplace, the more productive its workers and the better its
products. Conscientiously follow safety rules at all times. Do not take shortcuts. Do not endanger your
own life and health or that of your co-workers. Be safe so that you can stay healthy and enjoy life to its
fullest.

                                       Signature of Owner/Manager


                                                   Date


                                           Safety Team Leader




                               Copyright EPL for Residential Inc.                                        73
                                            PURPOSE
                                             Company name


is totally committed to employee safety and
proactive accident prevention. It is our
intention:
     That all employees work under the safest conditions possible; and

     That we provide information, training, and supervision to enable employees to perform their jobs
      safely.

Under the Occupational Safety and Health Act, construction industry employers must furnish each
employee with a place of employment that is free from recognized hazards that are likely to cause death
or serious injury. In addition, employers must comply with, and require all employees to comply with,
specific standards and rules that apply to their operations. To accomplish this, employers must educate
and train employees in the rules and regulations that apply to them.

The information in this General Health and Safety Plan for Construction states basic safety rules and
procedures that are to be followed by all company employees. While this plan will help you recognize
and avoid obvious hazards, it is merely intended to highlight some of the fundamentals of safety. The
plan cannot possibly cover all situations or delve into great detail in any particular area of construction
safety. Additional plans may be required for particular areas, such as asbestos control, assured equipment
grounding, confined space entry, fire protection and prevention, hazard communication, hearing
conservation, lock-out/tag-out, and respiratory protection, among others. When in doubt, consult your
Company resource guide for guidance.

This General Health and Safety Plan for Construction is designed to generally reflect company
policy, but it is not intended to be a binding legal contract. Thus, this plan does not alter any
employee'’ at-will status or grant any other legal rights to any employee.




                              Copyright EPL for Residential Inc.                                        74
          ALLOCATION OF HEALTH AND SAFETY RESPONSIBILITIES


Our goals are to make the safety of employees the highest priority
and to avoid any workplace accidents and injuries. To accomplish
these goals, the duties and responsibilities of all personnel must be
clearly defined. The roles of safety managers, project managers,
supervisors, and others are set forth below. Note that many
responsibilities for safety matters are intentionally designed to
overlap. By having employees cross check each other, the risk of
injury from any hazard going undetected is minimized.
Owner/Manager/Safety Team Leader

1. Administration: Administers all aspects of the General Health and Safety Plan.

2. Hazard Control: Develops programs and technical guidance to identify and correct hazards.

3. Safety Training: Assists managers and supervisors in safety training of employees.

4. Inspections: Conducts inspections to identify and correct hazards.

5. Reports: Completes written reports of inspections.

6. Safety Motivation: Develops incentives and programs to motivate employees in health and safety
   matters.

7. Posters and Notices: Properly posts and maintains the OSHA Form 200 (or it’s
   replacement, once adopted), any state health and safety posters, emergency phone numbers,
   and other required notices.

8. Accident and “Near Miss” Recording: Develops and maintains accident and “near miss” investigation
   and reporting procedures and systems to:

       record reportable incidents consisting of fatalities, lost workday cases, and cases without
        lost workdays requiring medical treatment;
        determine accident causes; and
       keep management informed of findings.

9. Accident Reporting: Reports accidents involving an occupational fatality or three or more
   hospitalized workers to OSHA within eight hours of occurrence.




                              Copyright EPL for Residential Inc.                                    75
Project Manager/Superintendent/Foreman

1. Familiarity with Regulations: Familiarizes himself or herself with health and safety
   regulations related to his or her areas of responsibility and oversees their enforcement.

2. Safety Oversight: Oversees health and safety activities within area of responsibility.

3. First Aid/Medical Attention: Ensures proper arrangements have been made for first aid and
   prompt medical attention in case of serious injury.

4. Personal Protective Equipment (PPE): Ensures that needed PPE is available and properly
   used and maintained by employees.

5. Safety Training: Instructs and trains all persons under his or her supervision in job health
   and safety requirements.

6. Regular Inspections: Conducts frequent and regular health and safety inspections of the
   work area.

7. Problem Correction: Directs correction of any unsafe conditions that are discovered or
   brought to his attention or her attention.

8. Weekly Safety Meetings: Conducts weekly safety briefings with supervisors and workers.

9. Foremen Compliance: Ensures that foremen understand and comply with safety
   requirements.

10. Accident and “Near Miss” Investigations: Reviews all accidents and unsafe practices with
    foremen and workers involved and ensures that corrective action is taken immediately.

11. Subcontractor Compliance: Requires subcontractors and their personnel to comply with
    health and safety regulations.

12. On-site Records: Maintains copies of applicable programs and OSHA forms on-site if
    necessary (for example, the Hazard Communication Plan, Material Data Safety Sheets, and
    OSHA 200 Injury Log if not quickly available from the central office).




                            Copyright EPL for Residential Inc.                                    76
First Line Supervisor/Foreman

1. Familiarity with Regulations: Familiarizes himself or herself with safety regulations within his
   or her area of responsibility and enforces these regulations.

2. Personal Protective Equipment (PPE): Ensures that persons under his or her supervision
   use safety devices and proper PPE.

3. Safety Training: Instructs and trains all persons within his or her area of responsibility in job
   health and safety requirements and hazard recognition and avoidance.

4. Employee Compliance: Requires compliance by workers with applicable safety rules.

5. Weekly Safety Meetings: Conducts weekly (more often if needed) safety briefings with all
   workers under his or her supervision.

6. Treatment for Injuries: Ensures that injuries are treated promptly and reported properly.

7. Accident and “Near Miss” Investigations: Investigates all accidents, “near misses,” and
   unsafe practices; obtains all pertinent data; and initiates necessary corrective action.

8. Regular Safety Inspections: Conducts frequent and regular safety and health inspections to
   ensure that no unsafe conditions exist in his or her area of responsibility.

9. Reporting Problems to Upper Management: Reports any needed corrective actions that are
   beyond his or her control to the project manager/superintendent/foreman.

Office Manager/Safety Team Administrator

1. Accident and Inspection Records: Maintains permanent records associated with accidents,
   on-site inspections, and in-house audits (including those required for workers’
   compensation).

2. Medical Records: Maintains all medical records, evaluations, and exposure monitoring
   records for 30 years.

3. Training Records: Maintains all training records for at least three years.




                             Copyright EPL for Residential Inc.                                    77
All Employees

1. Following Safety Rules: Follow applicable safety rules and regulations at all times; refuse to
   take shortcuts.

2. Avoiding Unsafe Acts: Never perform any tasks that appear to be risky or unsafe; report any
   such conditions or practices immediately.

3. Using PPE and Safety Devices: Always wear PPE and use safety devices when needed.

4. Listening to Supervisors: Listen to supervisors in charge of each operation who have been
   instructed to familiarize employees with safe operations and practices.

5. Avoiding Discipline or Discharge: Be responsible for their performance and for following
   safety rules; failure to do so will lead to disciplinary action or discharge.

Subcontractors

In the construction industry, employees of many different subcontractors often work in the same
general contractor. Hazards created by one employer may easily pose a danger to employees
who work for other employers. For example, even though a subcontractor commits a safety
violation, a General Contractor may be cited by OSHA as well. In addition, a subcontractor is
responsible for protecting workers from hazards resulting from any OSHA violation as follows:
(1) the subcontractor’s own employees must not be threatened by hazards that are created by
other contractors; (2) the actions of the subcontractor must not threaten the employees of any
other contractors; and (3) the subcontractor must properly abate any hazard that it has (or
assumes) the responsibility to correct.

Accordingly, subcontractors must with the following rules:

1. Compliance with Safety Standards: Every subcontractor must comply with all state and
   federal safety and health standards.

2. Abating “Correctable” Hazards: Subcontractors must immediately and effectively correct any
   hazards within their power to correct.

3. Reporting “Uncorrectable” Hazards: Subcontractors that become aware of hazards that are
   not within their ability to correct or that threaten other workers must immediately notify the
   general contractor and any subcontractors whose employees may be endangered.

(Note: The workers’ compensation coverage and civil liability for injuries that occur to
employees of subcontractors, as well as the responsibility of general contractors, vary
from state to state. To minimize their potential liability, employers need to make sure
that they comply with any applicable state laws.)




                            Copyright EPL for Residential Inc.                                  78
                      KEY AREAS OF RESPONSIBILITY
The identification of hazards, reporting and recording of injuries, and
training of employees are all especially critical for safety. The identification
of hazards helps employees to prevent injuries and illnesses before they
occur. The reporting and recording of injuries and illnesses is essential for
regulatory compliance and workers’ compensation purposes. In addition,
accidents must be brought to management’s attention so that causes may
be investigated and similar mishaps may be avoided in the future.

Effective training is probably the most important responsibility of all. It is
the key to injury prevention. Experience has shown that most injuries result
from unsafe actions, not unsafe conditions. Unsafe actions can be
eliminated only through the behavior of individual employees, which is
dependent on their education and training.

Hazard Identification, Assessment, and Control

1. Sharing Responsibility: It is the responsibility of everyone (management, supervisors, and all
   employees) to notify others of possible hazards. In addition to the persons who perform
   formal scheduled inspections, employees need to always “have an eye out” for potential
   hazards and promptly notify their foreman, supervisor, etc. of any actual or potential
   problems.

2. Conducting Regular Inspections: To identify hazards and unsafe practices before they
   cause an injury or accident, formal safety and health inspections must be conducted
   according to the following minimum timetables:

        Manager/Safety Team Leader:
          monthly inspection of all fixed facilities and each project or job site
          annual review of the company’s health and safety plan

        Project Superintendent: monthly inspection of his or her project (more often as
         different phases of construction may warrant

        Foremen/Supervisors: weekly inspection of areas of responsibility at job site

3. Fixing Problems: After completing job site or Company’s inspections, the person making the
   inspection will:

        discuss findings with employees or other persons responsible for creating the
         condition and allow for their comments and suggestions;
        discuss the situation with the job superintendent (if hazards are caused by
         subcontractors on the job), and then point out the problem to the owner, contractor,
         and other contractors involved;

        ensure that problems and recommended corrections are brought to the attention of
         the proper supervisor or other person;
                            Copyright EPL for Residential Inc.                                  79
         follow up to ensure that necessary changes and corrections were in fact made; and

         provide a copy to the company safety manager of any checklist and statement of
          corrective actions taken or still required (if applicable).


Reporting Job-Related Injuries and Illnesses

All job-related injuries and illnesses must be reported in accordance with the following rules:

1. Following Orientation Rules: Information on reporting job-related accidents must be covered
   in full time in the employee welcome and orientation class, which is scheduled shortly after
   each employee is hired.

2. Reporting Immediately: All on-the-job injuries and illnesses must be reported to a supervisor
   immediately – no matter how minor they may appear!

3. Cooperating in the Investigation: Employees who are involved in accidents should give full
   details concerning the nature of their injuries, the cause, the time and date, and any other
   relevant information.

4. Securing Medical Treatment: Employees should immediately secure any necessary medical
   treatment. Only designated supervisors and managers can authorize treatment.

5. Recording Information: All accident reporting forms must be filled out. If first aid is applied
   on-site, the nature of the first aid, condition of the individual, and recommendation for further
   treatment must all be recorded.

6. Detecting Symptoms: All employees should learn to detect early signs and symptoms of any
   illnesses or ailments to get proper treatment.

7. Avoiding Discipline or Discharge: An employee who does not promptly or properly report
   accidents or illnesses in accordance with this policy may be disciplined or discharged.




                            Copyright EPL for Residential Inc.                                    80
Recording Job-Related Injuries and Illnesses (OSHA 200 Log)

The OSHA Form 200 log will be maintained at the main office for all recorded occupational
injuries and illnesses. The superintendent is responsible for making sure that the required injury
information is forwarded to the main office for posting onto the master log within six days after
the accident has occurred. The summary section of the OSHA Form 200 must be posted at
each job site by February 1 of the following year and remain in place until March 1.

(Note: If the construction site is open for a year or more, this log may be maintained at
that job site by the superintendent: Employers also need to be on the lookout for the
upcoming replacement for the 200 log [the OSHA 300 log], which is expected to be
adopted in January 2002.)



Training

The importance of training in injury prevention cannot be overemphasized. Most accidents and
injuries occur because of unsafe actions. These usually occur because of inadequate training
and poor judgment. Employees who ignore safety training are gambling with the life and health
of themselves and their co-workers.

1. All employees must follow these rules for safety training:

          Orientation Training: Before exposure to the work environment, attend orientation
           training, during which employees will receive information and literature covering the
           company’s health and safety policies, rules, and procedures.

          Particularized Training: Receive training in the safety regulations that apply to each
           employee’s particular job, including:

              recognition, avoidance, and prevention of unsafe conditions;
              areas and actions requiring personal protective equipment (PPE); and
              proper use of PPE (respirators, goggles, etc.).

          Regular Scheduling: Attend ongoing safety training sessions on at least a
           _______________ basis:

              confined space entry;
              fall hazards and fall protection;
              hazard communication (hazardous chemicals);
              lock-out/tag-out procedures;
              respirator care/use;
              safe handling/use of flammables, poisons, or toxins; and
              scaffold use and erection/dismantling.




                             Copyright EPL for Residential Inc.                                     81
2. Role of Supervisors: Supervisors will be responsible for ensuring that employees are
   scheduled for and receive the individualized training they need (e.g., confined space entry,
   respirator use).

3. Required Documentation: Training in specific areas (e.g., confined space entry, respirator
   use) must be documented in the employees’ personnel records and/or in a master training
   record.

(Note: Company’s should review their training requirements to specify training time
frames or schedules and attach them as an appendix to your specific plan.
Training outlines/guidelines should also be developed to ensure all areas/items are
covered in this training.)




                            Copyright EPL for Residential Inc.                                  82
                           KEY ITEMS FOR INSPECTION

This listing includes some basic items and categories for health and safety inspections for
construction industry employers and employees. It is not intended to be all-inclusive or to deal
with the unique hazards that are faced by each Company. Rather, the listing is intended only to
provide a brief outline of some key areas to be surveyed and possibly developed into a checklist
for use during Company and job site inspection.

1.     First aid safety and health equipment

2.     Safety posters and signs required by occupational safety and workers’ compensation
       laws

3.     Accident reporting records

4.     Effectiveness of training during worker orientation, “tailgate meetings,” etc.

5.     Condition and use of personal and company owned hand and power equipment and
       tools

6.     Protective guards and devices, including their availability, use, and proper maintenance

7.     Maintenance of clean work areas free of tripping and slipping hazards

8.     Adequate lighting

9.     Sanitation: potable water and clean toilets

10.    Noise hazards and necessary hearing protection

11.    Ventilation for gases, vapors, fumes, dusts

12.    Needed personal protective equipment (PPE):

            hard hates/head protection
            respirators
            fall protection equipment, including safety belts and lines
            safety shoes
            eye protection
            gloves
            other items

13.    Fire prevention and control, including the accessibility and condition of fire protection
       equipment

14.    Temporary buildings, trailers, sheds

15.    Open yard storage

16.    Storage of flammable and combustible liquids, including service and refueling areas for
       vehicles


                            Copyright EPL for Residential Inc.                                     83
17.   Condition and location of temporary heating devices

18.   Fall protection equipment: ensuring proper placement and usage

19.   Electrical system and devices:

            condition and use of cords
            ground fault protection or assured grounding conductor protection
            lock-out/tag-out procedures

20.   Guarding of openings: floors, walls, railings

21.   Moving of materials: maintenance and condition of material handling equipment and
      elevators

22.   Ladders: condition and use

23.   Hazardous chemicals: Hazard Communication Plan and Material Safety Data Sheets
      (MSDS)

24.   Excavations and trenches: protective systems

25.   Scaffolds: Safety railings and secured access

26.   Other items as appropriate

Note: In addition to this Key Items for Inspection List, employers should consult the
Contractor’s Weekly Safety Inspection Report at the end of this plan.




                           Copyright EPL for Residential Inc.                             84
         GENERAL HEALTH AND SAFETY RULES FOR COMPANY
                OPERATIONS CONSTRUCTION SITES

To be effective, a general health and safety plan must be understood and implemented by
employees at every level of responsibility. The following lists are meant merely to briefly
highlight some of the key safety regulations that apply to construction industry employers. The
following lists are not meant to be an exhaustive set of safety instructions. A complete set
would run thousands of pages and may be found in the OSHA Rules and Regulations for
Construction (29 CFR 1926) and for General Industry (29 CFR 1910). Company’s should also
consult additional individual plans or policies for specific topics, such as asbestos, confined
space entry, fire protection, hazard communication, hearing conservation, lock-out/tag-out, and
respiratory protection.

Aerial Lifts

1.       Types

                cherry pickers
                extensible boom platforms
                aerial ladders
                articulating boom platforms
                aerial ladders
                articulating boom platforms
                vertical towers
                any combination of the above

2.       Permitted Operators: Only authorized and trained persons are allowed to operate aerial
         lifts.

3.       Lift Controls: Must be tested each day for use.

4.       Safety Harnesses, Lanyards, and Belts:

                   Employees must wear harnesses when elevated in the aerial lift.
                   Lanyards must be attached to the boom or basket.
                   Employees must not belt off to adjacent poles, structures, or
                      equipment while working from an aerial lift.

5.       Basket Use:

                   Always stand firmly on the floor of the basket.
                   Do not sit or climb on the edge of the basket.
                   Do not use planks, ladders, or other devices for work position or
                       additional working height.

6.       Brakes and Outriggers: Set brakes and use outriggers.

7.       Movement Prohibited with Elevated Boom: Do not move the aerial lift with the boom
         elevated and employees in the basket, unless the equipment is specifically designed for
         this use.

                             Copyright EPL for Residential Inc.                               85
Compressed Gas Cylinders

1.    Content Markings: Must be clearly indicated on the outside of each cylinder.

2.    Cylinder Transportation and Storage:

                Always keep in an upright position
                Never leave lying on the ground or floor
                Never use as rollers or supports

3.    Cylinder Valves:

                Protect with caps.
                Close when not in use.

4.    Leaking or Defective Cylinders:

                Remove from service promptly.
                Tag as inoperable.
                Place in an open space removed from the work area.

5.    Oxygen Cylinders and Fittings: Keep away from oil or grease.

6.    Hoisting Cylinders: During this process cylinders must:

                be secured in a cradle, sling-board, or pallet; and
                not be lifted from one vertical level to another with valve protection
                    caps

Cranes

1.    Competent Person: Must inspect all cranes before and during use to ensure they are in
      safe operating condition.

2.    Monthly Certification Inspection and Record: Required for each crane, including date,
      inspector signature, and crane identifier.

3.    Annual Inspection for Hoisting Machinery: Must be made by a competent person or by a
      government or private agency, and records must be maintained.

4.    Swinging Loads: Never swing loads over the heads of workers.

5.    Riding Prohibited: Never ride hooks, concrete buckets, or other material loads being
      suspended or moved by cranes.

6.    Hand Signals: Crane operators must follow the applicable ANSI standard for the type of
      crane in use.

7.    Tag Lines: Must be used to control loads and keep workers away.



                          Copyright EPL for Residential Inc.                                  86
8.    50 KV Electrical Lines: Keep loads, booms, and rigging at least 10 feet from energized
      electrical lines rated 50 kV or lower unless:

                 the lines are de-energized; or
                 applicable OSHA regulations are followed.

      (Note: For electrical lines in excess of 50 kV, the required distance is 10 feet, plus 0.4
      inches for each 1 kV over 50kV, or twice the length of the line insulator, but never less
      than 10 feet.)

9.    Level Surfaces: Cranes must always be:

                 operated on firm, level surfaces; or
                 stabilized through the use of mats or pads.

      (Note: The stability and evenness of surfaces is especially important in cases of near-
      capacity lifts.)

10.   Protective Barricades: Must be used to block access to areas within the swing radius of
      the rear of the rotating superstructure of the crane to prevent employees from being
      struck or crushed.

11.   Suspended Personnel Platforms: If platforms are lifted with a crane, numerous additional
      requirements apply (see 29 CFR 1926.550(g) for specifics).

12.   Inspection of Rigging Equipment: Required for chains, slings, wire ropes, hooks, etc.,
      before use on each shift to ensure safety (defective rigging and equipment must be
      removed from service immediately).

13.   Job or Shop Hooks: Must not be used (including makeshift fasteners made from bolts,
      wire, etc.).

14.   Removal of Wire Rope from Service: Required if any of the following conditions apply:

                 wear of one-third the original diameter of outside individual wires

                 kinking, crushing, bird caging, heat damage, or any other damage
                     resulting in distortion of the rope structure

                 in running ropes if there are:
                  six random distributed broken wires in one lay; or
                  three broken wires in one strand or one lay

                 in standing ropes if:
                  more than two wires are broken in one lay in sections beyond end
                      connections; or
                  more than one wire is broken at an end connection.




                           Copyright EPL for Residential Inc.                                      87
Electrical

1.    Live Electrical Parts: Protect against accidental contact by the use of cabinets,
      enclosures, location, or guarding (ensure that cabinet covers are replaced).

2.    Working Space: Keep clear and accessible space around electric equipment and
      distribution boxes.

3.    Circuit Breakers, Switch Boxes, and the Like: Must be legibly marked to indicate their
      purpose.

4.    Ground-Fault Circuit Interrupters: Required for all 120-volt, single-phase 15- and 20-
      ampere receptacle outlets on construction sites if the outlets are:

                   in use by employees; and
                   not part of the permanent wiring of the building or structure.

      (Note: [A] If the prime contractor has not provided this protection with GFCI receptacles
      at the temporary service drop, portable GFCI protection must be provided; [B] an
      assured equipment grounding conductor program may be used instead of the GFCI
      protection; and [C] this GFCI protection requirement is in addition to any other
      requirements for electrical equipment grounding or double-insulated protection.)

5.    Extension Cords: Must comply with the following:

                   be of the three-wire (grounded ) type;
                   be designed for hard or extra hard usage (Type S, ST, SO, STO, or
                       SJ, SJO, SJT, SJTO);
                   be kept in good condition, along with strain relief devices/clamps; and
                   not have ground prongs removed.

6.    Lamp Bulbs: Must be protected against breakage, if used I lamps for general
      illumination.

7.    Electrical Cords: Cannot be used to suspend temporary or portable lights unless
      designed for suspension and for hard or extra hard usage.

8.    Proximity to Unguarded Circuits: Employees will not work close enough to any
      electrical power circuit to make contact unless the circuit has been:

                   de-energized;
                   grounded; or
                   guarded by insulation.

9.    Lock-Out/Tag-Out: Equipment or circuits that are de-energized must be locked out and
      tagged out, and tags must plainly identify the equipment or circuits being worked on.

10.   Assured Grounding Equipment Program:

            Required, if the employer uses assured equipment grounding (versus ground- fault
                circuit interrupter) to provide employee electrical grounding protection.

                             Copyright EPL for Residential Inc.                                 88
                Must include:
                all cords sets, receptacles, and cord/plug connected equipment and
                    tools;
                a written program;
                quarterly testing;
                recording of each test by logging, color coding, etc; and
                the designation of a competent person to run the program.

Excavations and Trenches

1.    Cave-in Protection:

                Required for:
                any excavation or trench 5 feet or more in depth; and
                any trench less than 5 feet in depth with potential for cave-in.

                 May be accomplished through shoring, sloping, benching, or the use of
      hydraulic shoring, trench shields, or trench boxes.

                  Specific requirements of each system are dependent on the soil
      classification as determined by a competent person.

2.    Required Inspection by “Competent Person”: Inspect each excavation/trench:

                daily before the start of work;
                after every rainstorm or other hazard increasing the risk of a cave-in;
                    and
                as needed throughout the shift.

3.    Means of Egress: Must be provided in trenches 4 feet or more in depth so that no more
      than 25 feet of lateral travel is needed for any employee in the trench.

4.    Spoil Piles/Equipment: Must be kept at least 2 feet from the edge of the trench or
      excavation.




                            Copyright EPL for Residential Inc.                             89
                                  Fire Prevention

1.    Equipment Access, Inspection, and Maintenance: Make sure that all fire-fighting
      equipment is:

                accessible and easy to locate;
                inspected periodically; and
                kept in good operating condition (an annual service check and
                    monthly visual inspections are required for the fire extinguishers).

2.    Equipment Awareness: All employees must know the location of fire-fighting equipment
      in the work area and have knowledge of its use and application.

3.    Safety Can Usage: Use only approved safety cans for handling or storing flammable
      liquids in quantities greater than one gallon (for less than one gallon, the original
      container may also be used).

4.    Heat-Producing Equipment: When heat-producing equipment is used:

                 keep the work area clear of all fire hazards and flammable materials;
                 do not use a salamander or other open-flame device in confined or enclosed
      structures without proper ventilation;
                 ensure that fire extinguishers are available;
                 vent heaters to the atmosphere; and
                 locate heaters an adequate distance from walls, ceilings, and floors.

5.    Prohibition on LPG Storage: Do not store LPG (liquefied petroleum gas) in buildings.

General Workplace Safety Rules

1.    Reporting Hazards and Injuries:

                     Promptly report unsafe conditions to your immediate supervisor.
                     Promptly report all injuries, accidents, and “near misses” to your
            immediate supervisor.

2.    Eye and Face Protection: Use if there is a danger from flying objects or particles
      (whenever there is grinding, chipping, burning and welding, etc.) or from hazardous
      chemical splashes.

3.    Proper Dress: Wear appropriate work clothes, gloves, and shoes or boots. Do not wear
      loose clothing and jewelry.

4.    Safety Guards: Operate machines or other equipment only if all guards and safety
      devices are in place and in proper operating condition.

5.    Equipment Maintenance: Keep all equipment in safe working condition. Never use
      defective tools or equipment. Report any defective tools or equipment to immediate
      supervisor.

6.    Proper Use and Care of PPE: Wear or use any personal protective equipment (PPE)
      when required. Properly care for all PPE.
                          Copyright EPL for Residential Inc.                                  90
7.     Lock-out/Tag-Out: Perform lock-out/tag-out (or disconnect power) before maintaining,
       un-jamming, or adjusting any machinery or equipment.

8.     Aisle/Walkway Passage: Do not leave materials in aisles, walkways, stairways, work
       areas, or roadways.

9.     Housekeeping: Practice good housekeeping at all times.

10.    Required Training Before Use of Equipment: Training on equipment is required before
       unsupervised operation.

11.    Complete Compliance: Comply with all governmental regulations and all company safety
       rules.

Housekeeping

1.     Critical Role of Housekeeping: Recognize that housekeeping provides the foundation for
       a safe work environment by helping to prevent accidents and fires, and creates a
       positive attitude in the work area.

2.     Material Storage: Pile or store materials in a stable manner to prevent falling.

3.     Removal of Debris: Remove combustible scrap, debris, and garbage at frequent and
       regular intervals.

4.     Safe Passage for Critical Areas: Keep stairways, walkways, exit doors, and the area in
       front of electrical panels and fire-fighting equipment clear of materials, supplies, trash,
       and debris.

Industrial Hygiene and Occupational Health

1.     Toilet Facilities: Must be provided as required for the number of workers.

2.     Potable Water: An adequate supply must be provided (use of a common drinking cup is
       prohibited).

3.     Provisions for Medical Attention: Provisions must be made before beginning the project
       to ensure that:

            prompt medical attention is available in case of serious injury (including provisions
             for transportation and communications); and
            a person with a valid first aid certificate will be available to render first aid if no
             medical facility is “reasonably accessible” to the work-site (i.e., is not more than 4
             minutes away for any life-threatening situation and no more than 15 minutes away
             for less threatening situations).

4.     Protection from Harmful Gases and Fumes: Must be furnished through proper ventilation
       or personal respiratory equipment.

5.     Demolition Work and Asbestos/Lead Exposure: Required assessment for lead and
       asbestos exposure with demolition work, particularly if drywall, painted surfaces, or
       abrasive blasting or grinding is involved.

                            Copyright EPL for Residential Inc.                                    91
6.    Fit Working Condition: Employees must report each morning in fit condition to work and
      must not be intoxicated, hung over, or otherwise impaired because of personal habits.

Ladders

1.    Competent Person: Must identify any unsafe conditions with ladders through periodic
      inspection.

2.    Structural Defects: Ladders with structural defects must be immediately removed from
      service and repaired or replaced.

3.    Unstable or Uneven Surfaces: Straight ladders used on unstable, uneven, or wet
      surfaces must be tied off, held, or secured for stability.

4.    Portable Ladder Side Rails: Must extend at least 3 feet above the upper landing that the
      ladder accesses.

5.    Top Step of Stepladders: Never use as a step.

Miscellaneous

1.    Protruding Reinforcing Steel: Must be guarded to eliminate any impalement hazard for
      falling employees.

2.    Enclosed Chutes:

           Required if material, trash, and debris are dropped more than 20 feet outside the
            exterior walls of a building.
           Must include a substantial gate near the chute’s discharge end and guardrails at
            the chute opening where workers drop material.

3.    Training and Equipment for Servicing Large Truck Wheels: Must be done by trained
      employees that use a cage or other restraining device, plus an air line assembly
      consisting of a clip-on chuck, gauge, and length of hose.

4.    Forklift Operation: Allowed only by trained employees.

Motor Vehicles and Mechanized Equipment (SEE Sec. 7.2 “Sample Fleet Program”)

1.    Required Inspections: For all vehicles and equipment at the beginning of each shift to
      ensure that they are in safe operating condition.

2.    Unattended Equipment Next to Highway: If left unattended at night in normal use, must
      have one of the following:

           lights or reflectors; or
           barricades with lights or reflectors.

3.    Parking Brakes:

           Must be set when equipment is stopped or parked.
           Must chock wheels as well if equipment is on incline.
                           Copyright EPL for Residential Inc.                                  92
4.     Vehicle Condition: Must comply with the following:

            Horn, turn signals, service, parking, and emergency brake system must be fully
             operational.

            Seats must be firmly secured for the number of persons carried (passengers must
             ride in seats).
            Seat belts must be properly installed.

5.     Windshields: Must be made of safety glass for all vehicles with cabs.

6.     Material Handling Equipment: Must be equipped with rollover protective structures.

Safety Railings and Other Fall Protection

1.     General Rule – Six-Foot Threshold: All open-sided floors and platforms 6 feet or more
       above the adjacent floor/ground level must be guarded by:

            a standard railing (top and mid rail, toe-board if required);
            a safety net system; or
            a personal fall arrest system (harness, lanyard, lifeline).

       (Note: Scaffolds generally require fall protection for distances of 10 feet or more.)

2.     Breaks in Elevation: A stairway or ladder will be provided at any point of access where
       there is a break in elevation of 19 inches or more.

3.     Handrails/Stair rails: Required to guard all stairways of 4 or more risers or that are
       greater than 30 inches in height.

4.     Floor Hole/Opening Created During Work: If greater than 2 inches in its least dimension,
       a cover or safety guardrail must be installed immediately.

5.     Safety Nets: Required if:

            workplaces are more than 6 feet above the ground, water, or other surfaces; and
            the use of ladders, scaffolds, catch platforms, temporary floors, safety lines, or
             safety belts is impractical.

6.     Adjustment of Lanyards: Must provide for not more than a 6-foot-fall, and all tie-off points
       must be at least waist high.

       (Note: This section provides a few very basic requirements concerning fall protection.
       Company’s should review the Fall Protection Standard, 29CFR1926 Subpart M, for the
       many specific requirements applicable to fall protection.)




                            Copyright EPL for Residential Inc.                                   93
Scaffolds

1.     Competent Person:

            Must supervise erecting, moving, dismantling, or altering of any scaffold.
            Must determine feasibility of fall protection for employees erecting or dismantling
             supported scaffolds (must be provided if feasible and does not create a greater
             hazard).

2.     Standard Guardrails (Including Top rail and Mid-rail): Must be installed on all open sides
       and ends of scaffold platforms or work levels more than 10 feet above the ground, floor,
       or lower level.

3.     Fall Protection for Scaffolds:

            Required to protect employees from falls of 10 feet or more through either a
             personal fall arrest system or a guardrail system.

            Specific scaffold types require specific types of fall protection:

                Boatswain chairs, catenary scaffolds, float scaffolds, needle beam scaffolds,
                 and ladder jack scaffolds require a personal fall arrest system;
                Single-point or two-point suspension scaffolds require both a personal fall
                 arrest system and a guardrail system, or a ¾-inch-diameter grab line securely
                 fastened beside each crawling board; and
                Self-contained adjustable scaffolds require a guardrail system if the platform is
                 supported by ropes.

4.     Minimum 38-Inch Top rail and Fall Protection: Required for guardrails manufactured or
       placed in service after January 1, 2000, if the guardrail is the primary means of fall
       protection (36-inch guardrail generally is acceptable if the top rail is not to be used for fall
       protection).

5.     Standard Railings: Required on all open sides and ends for all scaffolds 4 feet to 10 feet
       in height with a minimum horizontal dimension in any direction of less than 45 inches.

6.     Full Platform Planking:

            Required at all working levels.
            Planking must:
              be laid tight with no more than 1 inch space between planks;
              overlap at least 12 inches; and
              extend over end supports 6 inches to 12 inches.

7.     Front Platform Edges: Must be no more than 14 inches from the face of the work
       (exception: plastering/lathing may be 18 inches).

8.     Height of Mobile Scaffolds: Must not exceed 4 times their minimum base dimension.

9.     Prohibition on Overloading Scaffolds: Scaffolds must not be loaded beyond their
       designed capacity.


                            Copyright EPL for Residential Inc.                                      94
10.   Use of Scaffold Components: Must not be used as tie-off or anchor point for fall
      protection devices.

11.   Platforms Located More Than Two Feet Above or Below Access Point: Require portable
      ladders, hook-on ladders, attachable ladders, integral prefabricated scaffold frames,
      walkways, or direct access from another scaffold or structure.

12.   Cross-Braces: Must not be used as a means of access to scaffolds.

13.   Scaffolds and Energized Lines: Scaffolds that are erected, used, or moved and any
      conductive material on them must keep at least:

           3 feet from insulated lines of less than 300 volts; or
           10 feet (plus additional specified distances depending on the power level) from
            any other insulated or un-insulated lines.

      (Note: This section provides only a few very basic requirements concerning scaffolds.
      Company’s should review the Scaffold Protection Standard, 29 CFR 1926 Subpart L, for
      the many specific requirements applicable to scaffolds.)




                          Copyright EPL for Residential Inc.                                  95
Tools

1.      Defective Tools: Remove from service immediately.

2.      Safety of Electric Power Tools: Required to be the grounded type or to be double
        insulated.

3.      Setting Down Power Tools: Requires turning tools off and stopping their motion before
        setting them down.

4.      Disconnecting Tools: Required before changing drills, blades, or bits or attempting repair
        or adjustment.

5.      Attending to Tools: Never leave a running tool unattended.

6.      Guards for Saws: Power saws, table saws, and radial arm saws must have operational
        blade guards installed and used.

7.      Prohibition on Use of Unsafe of Defective Hand Tools: Includes sprung jaws on
        wrenches, mushroomed heads of chisels or punches, cracked or broken handles of any
        tool, and any other unsafe conditions.

8.      Required Guards for Portable Abrasive Grinders: Must cover the upper and back
        portions of the abrasive wheel (wheel speed ratings must never be less than the grinder
        RPM speed).

9.      Compressed Air Pressure for Cleaning: Must be reduced to less than 30 psi and
        performed only with effective chip guarding and proper PPE.

10.     Valves for Abrasive Blasting Nozzles: Must be of the type that is held open manually.

11.     Use of Powder-Actuated Tools: Only trained employees will operate powder-actuated
        tools.

12.     Compliance with OSHA and ANSI Standards for Employee Tools: Any employee-
        furnished tools must meet all OSHA and ANSI requirements.




                            Copyright EPL for Residential Inc.                                  96
Welding and Brazing

1.    Combustible Materials: Clear from the area around cutting or welding operations.

2.    Welding Helmets and Goggles: Wear for eye protection and to prevent flash burns.

3.    Eye Protection: Wear to guard against slag while shipping, grinding, and dressing of
      welds.

4.    Electrode Holders: Must be specifically designed for arc welding.

5.    Full Insulation: Required for all parts subject to electrical current.

6.    Current Capacity of Ground Return Cable: Must equal or exceed the maximum output
      capacity of the arc-welding unit that it services.

7.    Placement of Cables, Leads, Hoses, and Connections: Must not create fire or tripping
      hazards.




                            Copyright EPL for Residential Inc.                               97
                       SAMPLE DISCIPLINARY POLICY




                          Company Name

wants its employees to work in a positive, productive atmosphere.
However, employees who violate safety rules must be discipline in
order to protect their own safety and the safety of their co-workers.
Depending on the severity and frequency of a safety violation, an
employee may be:

   immediately discharged;
   suspended; or
   given a written warning.

The following disciplinary guidelines classify violations according to
their seriousness (Groups A, B, and C), and certain penalties are
suggested for each group. Unsafe conduct by an employee may
violate several provisions of the different groups. This list is intended
to suggest examples of inappropriate behavior. It is not a
comprehensive list of all safety violations for which an employee may
be disciplined or discharged.

The following disciplinary policies do not in any way bind the Company to
follow a particular course of conduct. The Company in its sole discretion
may change these policies at any time. In addition, nothing in the policies
changes the at-will nature of employment with the Company. An employee
may still be terminated with or without cause, with or without notice, at the
option of either the Company or the employee, except as otherwise
provided by law.




                      Copyright EPL for Residential Inc.                   98
Group A

1.   Deliberate violation of any security or safety rules.

2.   Being intoxicated or under the influence of any controlled substances
     while at work.

3.   Deliberate or reckless misconduct that endangers the life or safety or
     others.

4.   Possession of alcohol or illegal drugs on Company premises.

5.   Deliberate destruction of or damage to Company property.

6.   Deliberate falsification of any documents related to safety matters.

7.   Fighting or deliberately harmful contact with co-workers.

8. ________________________________________________________

9. ________________________________________________________
10. _______________________________________________________




                     Copyright EPL for Residential Inc.                     99
Group B

1.    Negligence that damages Company property.

2.    Negligence that endangers the safety of others.

3.    Unintentional safety violation that endanger the safety or health of
      others.

4.    Failure to report conditions that one believes to be unsafe.

5.    Smoking or eating in unauthorized areas.

6.    Speeding or unsafe operation of a forklift or any other Company
      vehicle.

7.    Driving a forklift or any other machinery without required approval.

8.    Failure to properly record safety information for which one is
      responsible.

9.    Improper refusal to obey a supervisor’s safety instructions.

10.   Any belligerent or antagonistic conduct toward co-workers,
      supervisors, or customers.

11. ________________________________________________________

12. _________________________________________________________




                      Copyright EPL for Residential Inc.                     100
Group C

1.   Violation of personal protective equipment (PPE) policy that does not
     result in injury to oneself or others.

2.   Poor grooming or lack of cleanliness.

3.   Poor housekeeping.

4.   Failure to participate in the group safety meetings.

5.   Failure to properly and immediately report any accident or injury.

6.   Failure to properly or immediately report any accident involving
     Company equipment.

7.   Failure to perform inspections of tools or machinery.

8.   Failure to report machine or tool deficiencies.

9.   Failure to learn Company safety rules and regulations.

10. ______________________________________________________

11. ______________________________________________________




                     Copyright EPL for Residential Inc.                   101
                 DISCIPLINARY PENALTIES

The following list provides a general guide for disciplinary actions for
     the above violations.

                  1st Offense                     2nd Offense      3rd Offense

Group A           Immediate discharge

Group B           Warning or suspension           Discharge

Group C           Warning                         Warning or suspension
                                                  Discharge


                            WRITTEN WARNINGS

Written warnings may help employees know where they stand and improve
their performance. The Company attempts to issue written warnings that
include the reasons for the supervisor’s dissatisfaction. Warnings usually
include a statement of the actions you need to take or results that need to
be achieved to avoid further problems. However, the written warnings do
not legally obligate or bind the employer or alter the at-will nature of the
employee’s employment with the Company. An employee who has
received a warning may still be terminated with or without cause, and with
or without notice, at any time.

Any employee who receives a written warning must immediately
acknowledge receipt by signing the warning. An employee who disagrees
with the written warning may discuss his or her reasons for doing so with
the General Manager. It is generally best to inform the supervisor of any
error at the time the warning is issued. In fact, there is a place on the form
for the employee to do so.




                      Copyright EPL for Residential Inc.                    102
                 DISCIPLINARY NOTICE TO EMPLOYEE


Company name


_____________________________________
Date



_____________________________________
Employee name

_____ First Notice      _____ Second Notice


_____________________________________
Days suspended (if applicable)


_____________________________________
Department

We believe that an employee wants to know if he or she is violating
Company policy or failing to follow Company rules. This disciplinary notice
is to provide you notice of a violation of Company policy. However, the
Company is not obligated to provide any warnings or to retain an employee
once a warning has been given. All employees are employed at will. “At-
will” employment means that an employee can be terminated with or
without cause, with or without notice, at any time, at the option of either the
Company or the employee.

Your conduct is not in keeping with Company practices, standards, and
policies for the following reasons: (Indicate specific standards and policies
with which the employee has failed to comply)

____________________________________________________________
____________________________________________________________
____________________________________________________________


                      Copyright EPL for Residential Inc.                    103
Suggestions for improvement:

____________________________________________________________
____________________________________________________________
____________________________________________________________
____________________________________________________________
____________________________________________________________


Employee comments: (Note: An employee should state his or her
disagreements with the warning in writing.)

____________________________________________________________
____________________________________________________________
____________________________________________________________
____________________________________________________________
____________________________________________________________
____________________________________________________________
____________________________________________________________
____________________________________________________________
____________________________________________________________


Copy received by:


____________________________________________________________
Employee signature                   Supervisor’s Signature


_____________________________________
Date


Copy to employee file




                        Copyright EPL for Residential Inc.      104
                      CERTIFICATION OF EMPLOYEE

I have received a copy of
_________________________________________________________
Company name

General Health and Safety Plan that outlines Company policies and
employee responsibilities concerning safety, including disciplinary policies
for violation of safety rules and regulations. I will familiarize myself with the
General Health and Safety Plan and will comply with all of its provisions. I
understand and agree that the Company has the right to change, amend,
modify, o withdraw any provision of the General Health and Safety Plan
without notifying me before the effective date of any amendment,
modification, or withdrawal.


I understand that the General Health and Safety Plan is not a contract of
employment and the Company has the right to follow or deviate from the
policies in the General Health and Safety Plan in the Company’s sole and
exclusive discretion. I also understand that the General Health and Safety
Plan does not change the nature of my “at-will” employment with the
Company. “At-will” employment means that I can be terminated with or
without cause, with or without notice, at any time, at the option of either the
Company or myself.

By my signature below, I agree to the terms of the Certification and also
agree to follow the policies and procedures contained in the General Health
and Safety Plan.

____________________________________________________________
employee signature                   date


____________________________________________________________
General Manager                      date




                       Copyright EPL for Residential Inc.                     105
                      SAMPLE COMPANY WEEKLY SAFETY INSPECTION REPORT


Company Name: _________________            Job Name: _____________________________

Superintendent: _________________________ Date: _____________________________

Person(s) Making Inspection:
______________________________________________________

Subcontractors On-Site (List name and trade):
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________

Columns

A = Adequate at time of inspection
B = Needs consideration
C = Needs immediate attention
N/A = Not applicable

                                     A       B        C          N/A   Action Taken
Job Information
OSHA 200 forms posted and
complete?
OSHA poster posted?
Phone number to nearest
medical Company posted?
Tool box talks up-to-date?
Work area signed and
barricaded?
Housekeeping
Work areas generally neat?
Projecting nails removed or bent
over?
Waste containers used?
Passageways/walkways clear?
Cords and leads off of the floor?
Fire Prevention
Adequate fire extinguishers,
checked and accessible?
Phone number of fire
department posted?
“No Smoking” signs posted and
enforced near flammables?




                            Copyright EPL for Residential Inc.                        106
                                    A       B        C          D   Action Taken
Electrical
Extension cords with bare wires
or missing ground prongs
removed from service?
Ground fault circuit interrupters
used?
Terminal boxes equipped with
required covers?
Hand, Power, and Powder-
Actuated Tools
Hand tools inspected regularly?
Guards in place on machines?
Tools suited for their jobs?
Operators of powder-actuated
tools licensed?
Fall Protection
Safety rails and cable secured
properly?
Employees have D-ring of belts
in Company of back?
Employees exposed to fall
hazards tried off?
Employees below protected from
falling objects?
Ladders
Ladders extend at least 36
inches above the landing?
Ladders secured to prevent
slipping, sliding, or falling?
Stepladders used in fully open
position?
No stepping on top two rungs of
stepladder?
Scaffolding
All scaffolding inspected daily?
Erected on sound rigid footing?
Tied to structure as required?
Guardrails, intermediate rails,
toeboards, and screens in
place?
Planking sound and sturdy?
Proper access provided?
Employees below protected from
falling objects?
Floor and Wall Openings
All floor or deck openings
planked over or barricaded?
Perimeter protection is in place?
Deck planks secured?

                           Copyright EPL for Residential Inc.                      107
                                       A       B        C          D   Action Taken
Materials stored away from edge?
Trenches, Excavation, and Shoring
Competent person on hand?
Excavations shored or sloped back?
Materials stored at least two feet
from trench?
Equipment is a safe distance from
edge of trench or excavation?
Materials Handling
Materials properly stored or
stacked?
Employees use proper lifting
methods?
Tag lines used to guide loads?
Proper number of workers for each
operation?
Welding and Burning
Gas cylinders stored upright?
Proper separating distance between
fuels and oxygen?
Burning/welding goggles or shields
used?
Fire extinguishers nearby?
Hoses in good condition?
Cranes
Outriggers extended and swing
radius barricade in place?
Operators familiar with load charts?
Hand signal charts on crane?
Crane operators’ logs-up-to-date?
Employees kept from under
suspended loads?
Chains and slings inspected and
tagged as required?
Concrete Construction
Employees protected from cement
dust?
Exposed skin covered?
Runways adequate?
Personal Protective Equipment
Hard hats being worn?
Safety glasses being worn?
Respirators used when required?
Hearing protection being worn when
required?
Traffic vests being worn?




                              Copyright EPL for Residential Inc.                      108
Unsafe Acts or Practices Observed:

____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
__________

Comments:

____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________




____________________________________________________________________
Signature                                      Date




                        Copyright EPL for Residential Inc.               109
7.2   Fleet Safety Practices

      This section is intended as a guide for the Company to set up and maintain a commercial
      vehicle accident prevention program. Since regulations often change, any information in
      here, which is in conflict with Federal or State regulations, should be ignored. These
      components have been put together from companies who have been successful in
      implementing an effective fleet safety program. There has to be follow up, follow
      through and accountability.




                    Copyright EPL for Residential Inc.                                    110
INSTITUTING A COMPANY COMMERCIAL VEHICLE ACCIDENT PREVENTION
PROGRAM

To implement an effective Company fleet accident prevention program, team leaders & management
must first begin with an analysis of present organizational structure, operations, and fleet related safety
activities.

This analysis can then be used in conjunction with this Commercial Vehicle Accident Prevention Program
Guide to determine areas where improvement is desirable.

At a minimum, an effective Commercial Vehicle Accident Prevention Program would include:

       Management's Statement of Policy

       Management Responsibilities

       Driver and Other Employee Responsibilities

       Vehicle Inspection and Maintenance Programs

       Accident and Emergency Response Procedures

To begin with, a written STATEMENT OF POLICY should be prepared and provided to all
drivers:

       Management's sincere interest in preventing accidents.

       That each organizational member shares in the responsibility for fleet safety; that without
        the total commitment of each member to fleet safety, accidents cannot be averted.

A sample Statement of Policy is provided on the next page. Please try to develop a Company
specific one.




                               Copyright EPL for Residential Inc.                                         111
COMMERCIAL VEHICLE ACCIDENT PREVENTION PROGRAM

SAMPLE STATEMENT OF POLICY


We have developed this Company Vehicle Accident Prevention Program to prevent accidents. The
following Policy Statement is an important part of this program. Specifically, we want to:

           Eliminate human suffering resulting from accidents.

           Reduce uninsured costs of accidents.

           Lower insurance costs.

      Our goal is to reduce to a minimum the injuries employees and members of the public suffer from
      vehicle accidents.

      We must also recognize that accidents have a negative effect on the potential for profit. Uninsured
      costs of accidents, combined with insurance costs, are a serious concern and we intend to reduce
      them by keeping the number of accidents to a minimum.

      Eliminating accidents is an important responsibility of management.

      We will assume this responsibility.

      We consider accident prevention to be of equal importance with our other business procedures that
      relate to quality, volume, and cost of operation. We fully intend to provide, in administering this
      program, the leadership and direction to which supervisors and employees will respond.

      However, for this accident prevention program to be effective, each employee must take an active
      interest in accident prevention. We earnestly request that everyone devote his or her serious
      attention to making this accident prevention program an integral part of day-to-day business
      operations.




            Signed



               _________________________

                (GENERAL MANAGER)




                             Copyright EPL for Residential Inc.                                      112
                              MANAGEMENT RESPONSIBILITY


INTRODUCTION

A team leader may wish to delegate the responsibilities of the fleet accident prevention and safety
program to one or more persons. Responsibilities should be clearly defined before being assigned. Each
person assigned responsibilities should be held accountable for those responsibilities. This could be
included in your Company safety business plan.

COMPANY RESPONSIBILITIES:

         Develop a vehicle accident prevention program.

         Assign responsibilities for the implementation and functioning of the program.

         Coordinate activities between departments.

         Monitor the program to ensure desired results.

         Take appropriate actions to correct any deficiencies.

SOME COMPANY RESPONSIBILITIES, WHICH COULD BE INTERNALLY DELEGATED:

         Reviewing physical exam results (if CDL), checking driving record, road test, and written test.

         Developing and distributing training materials.

         Developing and conducting training.

         Developing and directing a vehicle inspection and maintenance schedule.

         Accident Review, determination of preventability, instituting corrective actions.




                              Copyright EPL for Residential Inc.                                     113
                                        DRIVER SELECTION


INTRODUCTION

Studies have shown that approximately 88% of all accidents are caused by the unsafe acts of people.
Additionally, the majority of accidents are caused by employees with less than two years experience
(regardless of their driving experience). Therefore, considerable emphasis needs to be placed on selection
and placement procedures. Because of the lack of direct supervision during most of the driver's work day,
it is of paramount importance that care be taken in hiring good, qualified employees. Driving is a part of
the job and when driving that should be the employee’s primary focus.


JOB DESCRIPTION

Good driver selection begins with an understanding of what skills a driver must have to perform the job
both safely and efficiently. Begin by making an assessment of job requirements. A job description
should guide you in determining driver function, duties, responsibilities, and job prerequisites.


SELECTION PROCESS

1. Identification - Check driving record with State Motor Vehicle Agency. As verification of the
   person's experience you may ask to review any certifications of road test, written test and physical
   examination (if CDL). However, these certifications should not be accepted in your selection
   procedure. A copy of their DL should be kept on file and should be issued in the state in which they
   reside.

2. Road Test - The driver applicant should be given a planned road test by the driver trainer,
   maintenance manager, dispatcher or other member of management. This road test should incorporate
   as many of the normal trip and road conditions as possible. For example the road test should include
   pre and post trip vehicle inspections, cargo loading and securing, pre-planned route, and other
   ordinary job requirements. By prior planning, the evaluator will be in a better position to evaluate the
   applicant's driving ability.

3. CDL/DOT ONLY Company Physical - Send the applicant to the Company's physician for a physical
   examination. Be sure the physician is aware of the physical requirements of the job and evaluates the
   applicant accordingly. Also, ensure that a certificate of medical examination is properly completed, if
   required by DOT regulations. Any driver not meeting the DOT minimum physical requirements
   should not be hired until such time as he/she meets the minimum requirements, or receives a waiver
   from the Department of Transportation.

4. Written Test - The driver applicant should be given a written test. The written test is an instructional
   tool, and the person taking the test may examine or consult the Federal Motor Carrier Safety
   Regulations or any other material explaining those regulations that you wish to provide. Any
   questions not answered correctly should be discussed with the driver applicant so he/she understands
   the rules and regulations established pertaining to commercial vehicle safety.

5. Paperwork – File any Company conducted written test, road test, medical examination certificate
   (CDL), Driver Data Sheet and any other forms required by the Company or company.




                               Copyright EPL for Residential Inc.                                       114
DRIVER TRAINING


INTRODUCTION

The purpose of training is to teach the new employee to work safely without sacrificing efficiency.
Training is a necessary supplement to the selection process, as no new employee completely understands
Company procedures and job requirements. Additionally, you cannot rely on previous training he or she
may have received because it may have been of poor quality.

Periodic training for the more experienced employee driver is also necessary. Training reinforces good
driving habits, and helps the driver to unlearn bad driving habits. Good training will also improve
customer relations, employee morale and overall operating efficiency. It will, for example, minimize the
effect of delayed service & installation and accidents, and prevent excessive maintenance caused by abuse
of equipment.


DRIVER TRAINING PROGRAM

The driver-training program consists of three phases:

        (1) General orientation of new employee drivers.
        (2) Training of the new employee driver.
        (3) A continuing education program for all divers.

1.    Orientation: The purpose of the orientation is to be certain that the new employee understands the
      Company's policies, practices, and procedures. Items to be covered include the purpose and
      objective of the training program; the job description; nature of the job; incentives; disciplinary
      policy; assignment of equipment; paperwork procedure; rules, regulations, and special instructions.

2.    Initial Training

      A. Vehicle Inspection

           Any employee, when hired, should be introduced to the type of vehicle, which he/she will be
           operating, and its specialty equipment and safeguards. If more than one type of equipment
           will be used, introduction to all equipment should be done at this time.

           The Driver Trainer should explain why and when a vehicle should be inspected and what
           happens to the inspection report. Inspection of the vehicle(s) should be demonstrated to the
           driver. The new employee should then perform the inspection(s) under the supervision of the
           Supervisor, Driver Trainer or Team Leader.

      B. Operating Techniques

           If the driver has little or no experience in operating the equipment, time and instruction should
           be given to allow the driver to become familiar with operating or using the equipment (e.g.:
           driving, backing, loading, unloading, etc.)




                              Copyright EPL for Residential Inc.                                        115
     C. Training Exercises

         After the operating techniques have been learned, time must be given to develop proficiency
         and skill in operating the vehicle and equipment. In house training can be supplemented, if
         desired, by readily available schools, seminars, films, and materials from several industry or
         governmental sources.

         Additional road tests or skill tests can be given to evaluate the new driver's performance.

     D. Governmental Rules and Regulations (DOT/CDL)

         All appropriate federal, state and local rules and regulations should be reviewed with the driver.
         Results from the Federal Motor Carrier Safety Regulation's written test (See Exhibit II -
         Employment Kit), can be the basis of this review. Specific instruction regarding logs and log
         preparation should be given at this time. Emphasis throughout this portion is strict adherence to
         the law. Keep in mind that the safety regulations provide a minimum acceptable standard for
         safe commercial vehicle operations.

     E. Accident Reporting Procedures

         Review procedures developed for handling of accidents at the scene, such as first aid,
         completing reports, and reporting accidents (Exhibits - What to do in Case of an Accident, and
         Telephone Accident Report Checklist). Let the employee review accident report forms, review
         the accident review board procedures, the way accident responsibility is determined, possible
         disciplinary actions, and appeal procedures at this time.

     F. Emergency Procedures

         Emergency equipment including fire extinguishers, proper procedures to handle fire fighting
         equipment, emergency warning devices, and training should be given to the driver.

3.   Periodic Training of Drivers

     Periodic training of all drivers is necessary:

     A. To reinforce Company policies and procedures, or because policies or procedures have been
        changed.

     B. As a result of changes in equipment, product, or regulations.

     C. As a result of a specific accident trend, high frequency, or high severity of accidents within the
        fleet.

     D. As part of the disciplinary procedures for a driver involved in a preventable accident or series
        of accidents; or driving violation(s).




                              Copyright EPL for Residential Inc.                                       116
TRAINING DOCUMENTATION

All training should be well documented. Documentation provides a reference to determine future training
needs, and is necessary for legal as well as liability reasons. The New Driver Training Sheet can
document initial training. Additional training can be logged on the reverse side. When completed, the
form should be kept as a permanent part of each driver's file.


DRIVER TRAINERS

Team leaders should designate a Driver Trainer(s) internally if they are going to delegate this task. Driver
trainers should possess the following qualities.

      1.   Above average driving skill.
      2.   Knowledge of the equipment.
      3.   Likable personality.
      4.   Ability to teach and convey knowledge to others.
      5.   Neatness as to his person and vehicles.
      6.   Pride in his job and Company.
      7.   Even temperament.

Driver trainers should be indoctrinated in the Company's current policies, procedures, rules and
regulations prior to giving training to any new driver. Additional training in teaching methods may also
be wise for larger fleets. Many outside organizations within the commercial vehicle industry, insurance
industry, and the government are able to assist in this training.

Periodically the driver trainer should be evaluated with regard to performance of his/her training duties.




                               Copyright EPL for Residential Inc.                                       117
VEHICLE INSPECTION AND MAINTENANCE


INTRODUCTION

The purpose of regularly scheduled vehicle inspections and maintenance is to increase vehicle
dependability. A properly maintained vehicle is not likely to break down enroute and become a traffic
hazard. A properly maintained vehicle is also more easily controlled under emergency conditions.
Maximum return on vehicle investment is achieved through increased life span. Lowered operating costs
are achieved because small problems are corrected before more costly repairs are required. Good
customer relations are maintained through uninterrupted schedules. But, proper inspection and
maintenance are not accomplished by accident; they have to be planned.


INSPECTION

The best contribution a driver can make to good maintenance is in the discovery of defects between
scheduled preventive maintenance. This is accomplished through careful pre-trip, enroute and post-trip
vehicle inspections; and the thorough conscientious reporting of defects. Periodically, drivers should be
trained in proper inspection procedures. And, whenever else the opportunity arises, management should
emphasize to drivers the need for thorough inspections. Management should observe drivers inspecting
their vehicles, and should conduct surprise vehicle inspections to insure that drivers are conscientiously
performing the inspections.

Whenever a vehicle is sent to the shop for maintenance or repairs, mechanics should be instructed to
inspect the vehicle and correct any defects. Any defects reported by the driver after a vehicle has been in
the shop should be considered a failure of the preventive maintenance program, and such failures should
be eliminated.


MAINTENANCE

All good preventive maintenance programs contain five essential elements:

       Regularly scheduled maintenance procedures in accordance with manufacturer's instructions and
        vehicle usage.

       Current maintenance record for each vehicle, containing pertinent operating and maintenance
        information.

       A means to tabulate maintenance, repair, lubrication, and fuel records for analysis. Analysis of
        such information as fleet and individual vehicle costs, frequency of part failure or excessive wear,
        vendor charges, etc. will provide management with the information needed for spacing of
        replacement vehicles, when to replace vehicles, and how to modify the maintenance program to
        obtain maximum benefit.

       Properly trained maintenance personnel with adequate tools, parts, and facilities to do their job.

       Extra vehicles or an operating schedule designed to permit each vehicle to receive its scheduled
        maintenance when due.

                               Copyright EPL for Residential Inc.                                       118
ACCIDENT REPORTING PROCEDURES


Each driver should be required to complete an accident form for every accident in which his/her vehicle is
involved. If possible this report should be turned into the office on the day the accident occurs, but no
longer than 12 hours after the accident.

Drivers should be thoroughly trained in how to complete the accident report form by the driver trainer.
Failure to report an accident, no matter how slight, or falsification of data on an accident report should be
cause for disciplinary action.

The Company should provide an accident package, which should be carried in the glove compartment of
each vehicle Drivers are required to complete the accident report at the scene of the accident. Specially
printed courtesy cards will save time and help the driver get the names of witnesses.

Drivers should understand the importance of getting the names of as many witnesses as possible.
Company management may also want to consider providing an inexpensive throwaway camera for each
vehicle to assist the driver in recording the accident scene. This can prove invaluable in capturing the
accident facts, particularly in those cases where and on-site investigation by the Company is not possible.

As soon as possible following the accident, the team leader or management should investigate the
accident. Depending on the severity, an on-site investigation should be done and witnesses should be
interviewed. A police report of the accident should be obtained. Other useful documents to assist in the
investigation would include driver daily logs, vehicle maintenance records, and shipping papers. The
driver should also be interviewed.

All accident review report forms should be routed to the team leader & administrator so that proper and
accurate reports can be filed.

The report should then be submitted to the Accident Review Board.

Upon completion of action by the Accident Review Board, the accident should be posted in the Vehicle
Accident Register, and on the Driver Record Card.




                               Copyright EPL for Residential Inc.                                        119
ACCIDENT REVIEW BOARD


PURPOSE

The purpose of the Accident Review Board is to provide an impartial forum for the determination of
accident preventability.


MEMBERS OF REVIEW BOARD

The board should consist of an odd number of members. Representatives should be drawn from all
involved departments, such as the safety team, operating department, Company management, mechanics
and one or two drivers. Their peers should elect the driver representatives. The term of office for driver
representatives should be at least one year.


PROCEDURES

The Safety Team Leader, as chairman, should provide sufficient advance notice of meeting dates. Then,
members will have time to arrange their normal work schedule so as to be present at the meeting.

All board members should read the accident report. A blackboard or other device should be used so that
each member of the board will have a thorough understanding of the case. During the discussion of the
case, the board's primary responsibility is to establish preventability. (Exhibit - Guide For Determining
Accident Preventability). At the end of the discussion, the members of the review board will vote by
secret ballot on the preventability of each accident. A simple majority will determine preventability. The
driver should be notified of the decision of the review board not later than 48 hours after the board has
met (Exhibit - Accident Review Board Report).


APPEALS

Should a driver wish to appeal a decision of the review board, he/she may do so by notifying the chairman
before the next regular meeting of the review board. At the meeting, the driver will present his/her case.
The board members may question him/her to help clarify the circumstances of the accident. After the
discussion, the driver is asked to leave the room and a secret ballot is then taken. After the ballots are
tallied the procedures are followed as indicated above.




                               Copyright EPL for Residential Inc.                                      120
EXHIBIT

                               ACCIDENT REPORTING PROCEDURES


WHAT TO DO IN CASE OF AN ACCIDENT


The driver trainer or team leader should instruct all drivers in the following procedures.

1.     As soon as practical after the accident has occurred, stop your vehicle as far off the roadway as is
       possible.

2.     Turn off the ignition switch, set brakes.

3.     Protect the accident scene against further incidents by setting out warning signals or warning
       devices and seeking aid from passing motorists.

4.     Determine your location (telephone pole number, mile post, etc.), town and time of accident, then
       call police. Also, if necessary, request medical aid or fire department assistance.

5.     If someone is hurt give first-aid treatment - but only if you are qualified to do so.

6.     Make certain that valuables, trip sheets, invoices and such on board the truck are secure.

7.     Answer all police questions. Be courteous. Do not argue or try to place blame at the scene of the
       accident. Do not admit responsibility, even if the fault is yours. You might do yourself serious
       harm by any admission. All of that can be taken care of later with the right people.

8.     Obtain the name of the other driver, driver's license, address, and phone number. Give the same
       information about yourself.

9.     Make a sketch showing the point of impact of the vehicles involved, direction of movement, speed
       prior to accident, weather, road conditions, time.

10.    Make note of damage to other vehicle.

11.    Complete driver's accident report and courtesy cards

12.    Report accident to terminal manager as soon as possible.

13.    Do not talk to anyone about the accident, except the police officer, a representative of the
       Company or a properly identified representative of the insurance Company.

14.    Do not sign anything.




                                Copyright EPL for Residential Inc.                                       121
                                                 EXHIBIT


                          TELEPHONE ACCIDENT REPORT CHECK LIST


Date ______________ Time _________ Call was received by: _____________________
                                                      (TEAM ADMIN)

Who is calling? ____________________________ Terminal _____ ___________________
                         (Driver's Name)

Calling from where? __________________________________________________________
                                         (Town and Phone Number)

Have police been called? __ Y __ N       If Yes, what Dept. _____   ____________________

Can you talk without being overheard? ___________         _____________________________

How far are you from scene of accident? __________         ____________________________

Are you injured? __ ___________________________________________________________

Are warning devices placed? ____________________________________ ______________

Is there another vehicle involved? _______________________________         ____________

Are there injuries in other vehicle? _________          ________________________________

Equipment Type: Unit Numbers _____________________ ___________________________

Destination & Consignee _______________________ _______________________________

Loaded? Yes ___ No ___ Commodity: ______ ____________________________________

Exact Location of accident _____________________         ______________________________

___________________________________________________________________________

Time of accident: _________ AM____ PM ____

How badly is other vehicle damaged? __________________ _________________________

What is condition of our vehicle? ____        _______________________________________

Are the brakes, lights and steering operable? _______        _________________________




                              Copyright EPL for Residential Inc.                           122
TELEPHONE ACCIDENT REPORT CHECKLIST (continue)

What part or parts are damaged? __________ ____________________________________

Is our vehicle operable?___            ____________________________________________

Has wrecker been called? ______________ Who? ___ _____________________________

What is the condition of the cargo

___________________________________________________________________________

DESCRIPTION OF ACCIDENT

Describe what happened:
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________

Have you opened insurance packet & filled out Preliminary Report? __ Y   __ N

Used the courtesy forms? _________________________

What were weather and road conditions? _____________________      _________

Do not sign anything or admit liability.

I also instructed driver to:
___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________




                               Copyright EPL for Residential Inc.                     123
                                    EXHIBIT
                        NEW DRIVER TRAINING WORKSHEET




Driver's Name _____________________________________            Date _________________

ORIENTATION

___ Welcome
___ Job Description
___ Work Rules
___ Accident Reporting
___ Organizational Structure
___ Motor Vehicle Regulations and Traffic Laws
       ___ City
       ___ State
       ___ DOT
___ Complaint Handling
___ Credit Cards
___ Parking Facilities
     Call In Procedures
___ Breakdowns/Road Calls


DEFENSIVE DRIVING

___ Personal Factors                                  ___ Traffic Factors
___ Equipment Factors                                 ___ Overall Factors
___ Road Factors


BUILDING TEAMWORK

___ Introduction to Other Employees
___ Tour of Facilities


INTRODUCTION TO EQUIPMENT

___ Equipment Familiarization                      ___ Pre-trip Inspection
___ Mechanical Knowledge                           ___ Post Trip Inspection &
___ Trouble Shooting                                   Report




                          Copyright EPL for Residential Inc.                        124
                  NEW DRIVER TRAINING WORKSHEET (continued)



OPERATING TECHNIQUES

____ Smooth Operations                                 ____ Restricted Clearance
____ Surge-Stopping                                    ____ Distances
____ Signals                                           ____ Public Relations
____ Starting from curb                                ____ Unauthorized Riders
____ Turns-Right, Left                                 ____ Loads
____ Passing                                           ____ Over limit
____ Entering Highway                                  ____ Check Loading
____ Intersection                                      ____ Hazardous Material
____ Following Distance                                ____ Paper work
____ Parking                                           ____ Bad Weather
____ Backing                                           ____ Ice-Snow
____ Night Driving-Visibility                          ____ Rain
____ Use of Lights                                     ____ Delays
____ Night vision aids                                 ____ Vehicle characteristics.
____ Traction-Natural Law                              ____ Coffee-Meal-Sleep
____ RR Crossings-Bridges
____ Coupling/Uncoupling

Driver's Signature_________________________________________

Driver Trainer's Signature___________________________________


ADDITIONAL TRAINING



Date                               Trainer                            Course




                           Copyright EPL for Residential Inc.                          125
                                                EXHIBIT

                                   ACCIDENT REVIEW BOARD

                 GUIDE FOR DETERMINING ACCIDENT PREVENTABILITY


INTRODUCTION

An accident is preventable if the driver could have done something to avoid it. Drivers are expected to
drive defensively. Which driver was primarily at fault? Who received a traffic citation, or whether a
claim was paid has absolutely no bearing on preventability. If there was anything the driver could have
done to avoid the collision, then the accident was preventable.

An accident is non preventable when the vehicle was legally and properly parked, or when properly
stopped because of a highway patrol officer, a signal, stop sign, or traffic condition.

It should be the objective of any person discussing or judging accidents to obtain as many facts as
possible and to consider all conceivable conditions. Adverse weather conditions, actions of other drivers,
or other such excuses must not influence the judgment of preventability.

Company employees are expected to drive in a manner, which allows them to avoid conflicts when they
arise. Whether a driver has a 25-year safe driving record, or started driving the day before has no bearing
on whether an accident is or is not preventable. Taking a fair attitude does not mean leniency. If an
accident is judged non-preventable and the driver knows the accident could have been avoided, he or she
will lose respect for the program.


QUESTIONS TO CONSIDER

When judging or discussing preventable accidents, these are some questions to consider:

1.    Does the report indicate that the driver considers the rights of others or is there evidence of poor
      driving habits, which need to be changed?

2.    Does the report indicate good judgment? Such phrases as "I did not see," "I didn't think," "I didn't
      expect," or "I thought" are signals indicating there is something wrong. An aware driver should
      think, expect, and see hazardous situations in time to avoid collisions.

3.    Was the driver under any physical handicap, which could have been contributory? Did the
      accident happen near the end of a long and/or hard run? Does the driver tend to overeat? Did the
      driver get sufficient sleep before the trip? Is the driver's vision faulty?

4.      Was the vehicle defective without the driver's knowledge? A gradual brake failure, a car which
        pulls to the left or right when the driver applies the brakes, faulty windshield wipers, and similar
        items are excuses, a driver using them is trying to evade responsibility. Sudden brake failure,
        loss of steering, or a blowout may be considered defects beyond the driver's knowledge, however,
        the inspection and maintenance program should work to prevent these hazards.

5.    Would taking a route through less congested areas reduce the hazardous situations encountered?




                               Copyright EPL for Residential Inc.                                        126
                                 SPECIFIC TYPES OF ACCIDENTS

INTERSECTION COLLISIONS

Failure to yield the right-of-way, regardless of stop signs or lights, is preventable. The only exception to
this is when the driver is properly proceeding at an intersection protected by lights or stop signs and the
driver's vehicle is struck in the extreme rear, side, or back.

Regardless of stop signs, stoplights, or right-of-way, a professional driver should recognize that the right-
of-way belongs to anyone who assumes it and should yield accordingly. In addition, a professional driver
is expected to know the turning radius of the vehicle and be able to avoid damaging others. These
accidents are normally considered preventable.

1.     Did the driver approach the intersection at a speed safe for conditions?

2.     Was the driver prepared to stop before entering the intersection?

3.     At a blind corner, did the driver pull out slowly ready to apply the brakes.

4.     Did the driver operate the vehicle correctly to keep from skidding?



                        IF THE ANSWER TO ANY QUESTION IS NO,
              THE DRIVER WAS NOT DRIVING DEFENSIVELY AND IS AT FAULT.




                               Copyright EPL for Residential Inc.                                        127
BACKING ACCIDENTS

Backing a vehicle into another vehicle, an overhead obstruction, or a stationary object are normally
preventable. The fact that someone was directing the operator in backing does not relieve a driver of the
responsibility to back safely.

Backing a Vehicle

1.    Was it necessary to back:

      (a)    Did the driver have to park so close to the vehicle ahead that it required backing to leave the
             parking space?

      (b)    Was it necessary to drive into the narrow street, dead-end alley, or driveway from which he
             or she backed?

2.    If the driver could not see where he or she was backing:

      (a)    Did the driver try to get someone to guide him or her?

      (b)    Did the driver look all around the vehicle before getting in?

      (c)    Did the driver back immediately after looking?

      (d)    Did the driver use the horn while backing?

      (e)    If the vehicle was equipped with a back-up alarm, was it working?

      (f)    Were the back-up lights working?

      (g)    Did the driver look to the rear without depending on the rear-view mirror?

      (h)    If the distance was long, did the driver stop, get out, and look around occasionally?

3.    Did the driver back slowly?




                       IF THE ANSWER TO ANY QUESTION IS NO,
              THE DRIVER WAS NOT DRIVING DEFENSIVELY AND IS AT FAULT




                              Copyright EPL for Residential Inc.                                        128
SIDESWIPE ACCIDENTS

      Sideswipes are often preventable since drivers should not get into a position where they can be
      forced into trouble. A driver should pass another vehicle cautiously and pull back into the lane
      only when he or she can see the other vehicle in the rear-view mirror. A driver should also be
      ready to slow down and let a passing vehicle into the lane. A driver should not make a sudden
      move that may force another vehicle to swerve. Unless the driver is swerving to avoid another car
      or a pedestrian, sideswiping a stationary object is preventable.

Drivers are expected to be able to gauge distances properly when leaving a parking place and enter traffic
smoothly.

A driver is expected, whenever possible, to anticipate the actions of an oncoming vehicle. Sideswiping an
oncoming vehicle is often preventable.

      The doors of a vehicle should never be opened when it is in motion. Nor should they be opened on
      the traffic side, unless clear of traffic, when it is parked.

      A parked vehicle can be seen from a sufficient distance; therefore, the operator of an approaching
      vehicle should be prepared in case the doors of the parked vehicle are opened. This type of
      accident is non-preventable only when the door is opened after the driver has passed it.

1.    Did the driver look to front and rear for approaching and overtaking traffic immediately before
      starting to pull away from the curb?

2.    Did the driver signal before pulling away from the curb?

3.    Did the driver look back rather than depend only upon rear-view mirrors?

4.    Did the driver start into traffic only when this action would not require traffic to change its speed
      or direction in order to avoid his or her vehicle?



                       IF THE ANSWER TO ANY QUESTION IS NO,
              THE DRIVER WAS NOT DRIVING DEFENSIVELY AND IS AT FAULT




                              Copyright EPL for Residential Inc.                                         129
OVERHEAD OBSTRUCTIONS

Overhead obstructions can be avoided if the driver knows the height and width of the vehicle and pays
attention to posted clearances or takes the time to properly judge clearances

A head-on collision with a vehicle traveling in the wrong lane may be preventable if the driver could have
pulled off the road or taken any other action to prevent a collision. The driver should never drive into the
other lane to avoid the oncoming vehicle.

It is a driver's responsibility to park the vehicle so that it will remain stationary. A runaway type of
accident is preventable and blaming such a collision on defective parking brakes of other holding devices
are excuses.

If a driver goes off the highway because of skidding, sliding, or falling asleep at the wheel, the accident is
preventable.

1.     Was the driver aware of the overall height or width of the vehicle?

2.     If the accident was due to mechanical failure, did the driver perform a proper pre-trip inspection of
       the vehicle? Has the driver been properly trained in vehicle inspection?

       Overhead Obstruction, Head-On Collision, of Runaway Vehicle (continued)

3.     Was the driver aware of road conditions or of the affects fatigue, alcohol and/or drugs could have
       on his or

4.     Did the driver judge clearances accurately?


                        IF THE ANSWER TO ANY QUESTION IS NO,
               THE DRIVER WAS NOT DRIVING DEFENSIVELY AND IS AT FAULT




                               Copyright EPL for Residential Inc.                                         130
      SKIDDING

      Many skidding conditions are caused by rain, freezing rain, fog, and snow, which all increase the
      hazard of travel. Oily road film, which builds up during a period of good weather, causes an
      especially treacherous condition during the first minutes of a rainfall.

Loss of traction on a grade can be anticipated, and these accidents usually are preventable. Chains or
other suitable traction devices should be used, if they are available

1.    Was the driver operating at a safe speed considering weather and road conditions?

2.    During inclement weather was the driver keeping at least twice the safe following distance used for
      dry pavement?

3.    Were all actions gradual?

4.    Was the driver anticipating ice on bridges, in gutter, ruts, and near the curb?

5.    Was the driver alert for water, ice or snow in shaded areas, loose gravel, sand, ruts, etc.

6.    Did the driver keep out of other vehicle tracks or cross them at wide angles?



                        IF THE ANSWER TO ANY QUESTION IS NO,
                THE DRIVER WAS NOT DRIVING DEFENSIVELY AND IS AT FAULT




                              Copyright EPL for Residential Inc.                                         131
PEDESTRIAN AND ANIMAL COLLISION

All types of pedestrian accidents, including collision with pedestrians coming from between parked cars,
are usually considered preventable. There are few instances where the action of pedestrians is so
unreasonable that the operator could not be expected to anticipate such an occurrence.

Collisions with animals are normally preventable, unless the movement on the part of an animal was
unusual and unexpected. This is also taking into consideration the fact that the driver was aware of
animals in the vicinity.

1.    Did the driver go through congested sections expecting that pedestrians would step in front of the
      vehicle?

2.    Was the driver prepared to stop?

3.    Did the driver keep as much clearance between his or her vehicle and parked vehicles, as safety
      permitted?

4.    Did the driver stop when other vehicles had stopped to allow pedestrians to cross?

5.    Did the driver wait for the green light or stop for the caution light?

6.    Was the driver aware of children and prepared to stop if one ran into the street?

7.    Did the driver give all pedestrians the right-of-way?

8.    Did the driver stop for a school bus, which was stopped and properly signaling that passengers
      were loading or unloading?



                       IF THE ANSWER TO ANY QUESTION IS NO,
              THE DRIVER WAS NOT DRIVING DEFENSIVELY AND IS AT FAULT




                               Copyright EPL for Residential Inc.                                      132
PARKED VEHICLES

Accidents occurring when vehicles are properly and legally parked are considered non-preventable.
Accidents that occur while the vehicle was double-parked or in a "No Parking" zone are preventable.

1.    Was the vehicle parked on the proper side of the road?

2.    Was it necessary to park near the intersection?

3.    Did the driver have to park on the traveled part of the highway, on the curve, or on the hill?

4.    When required, did the driver warn traffic by emergency warning devices?

5.    Did the driver park parallel to the curb?

6.    Was it necessary to park so close to an alley or directly across from a driveway?


      The accident should be considered preventable if the investigation shows a mechanical defect of
      which the driver was aware, a defect the driver should have found by inspecting the vehicle, or the
      driver caused by rough and abusive handling.

      When a mechanical failure is sudden or unexpected, not resulting from abuse or ordinary wear, it
      may be considered non-preventable. Bad brakes should not be considered a mechanical failure
      unless the failure was sudden and the driver could have had no previous knowledge of the
      condition. However, this type of failure cannot excuse a driver who does not know how to
      properly pre-trip inspect the vehicle or is too lazy to do the inspection correctly.

      It is a driver's responsibility to keep the cargo in mind and be aware of any sudden vehicle
      movements which may cause damage to the cargo. Driving off the highway to avoid a collision
      may be preventable. Drivers should try not to place themselves in such a position. "U" turns are a
      monkey wrench in the smooth flow of traffic. Accidents, which occur while this maneuver is
      attempted are considered preventable.

1.    Could the driver have done anything to avoid the accident?

2.    Was the driver's speed safe for conditions?

3.    Did the driver obey all traffic signals?

4.    Was the driver's vehicle under control?

5.    Did the driver follow the routing and delivery instructions?



                       IF THE ANSWER TO ANY QUESTION IS NO,
              THE DRIVER WAS NOT DRIVING DEFENSIVELY AND IS AT FAULT




                               Copyright EPL for Residential Inc.                                      133
                                            EXHIBIT

                                  Accident Review Board Report




Date of Accident _____________        Review Date ___________________
Accident File No. _____________       Terminal _______________________

Driver's Name _______________________

Members of Review Board Present

________________________________________________________________________

________________________________________________________________________

Witnesses    _____________________________________________________

Final Vote Classification     Preventable    Non-Preventable____

      If the decision has been reversed, give detail reasons, extenuating circumstances, or
      information not listed on original accident report.

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

Action taken by Safety Director

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

   Record Posted __________________          By _____________




                            Copyright EPL for Residential Inc.                                134
7.3   Fall Protection Better practices

      Purpose

      The following information deals with fall protection as it pertains to ladders,
      scaffolding and any other issue, which could involve injuries to our employees
      from falling. It is necessary for all the Company’s to establish a fall protection
      program within their Company utilizing the better practices.




                   Copyright EPL for Residential Inc.                                      135
HAZARD ASSESMENT

All safety team leaders and/or safety committees will need to conduct a hazard
assessment as it pertains to fall protection. You will need to assess your specific
Company’s needs. Ask questions like:

Are we involved in both residential and commercial work?
Do we utilize both ladders and scaffolding?
Could falling objects strike our employees?
Could our employees fall though opening in roofs or openings in floors?

When conducting this assessment for fall protection we need to look at not just our
employees falling from heights or on the same level but;

Can they be hit by falling objects?

Once you have determined that you can start developing your Company specific plan.




              Copyright EPL for Residential Inc.                                      136
LADDERS: GENERAL

The following deals with general ladder use in both our commercial and residential
Company’s. These guidelines will assist you in developing a Company specific program
for ladder safety. This applies to all ladders. Job made ladders are not allowed to be made
or used by employees.

   Must have nonconductive side rails if the employee or ladder could contact energized
    electrical equipment.
   Be kept free of oil, grease and other slipping hazards
   Used only on solid and level surfaces, unless secured to prevent movement
   Be inspected for possible defects on a regular schedule and must be documented and
    kept on file

When employees are going up/down ladders they must:

   Face the ladder
   Have 3-point contact at all times. Two hands and a foot, two feet and a hand etc.

Ladders will not be:

   Moved, shifted or extended while occupied
   Tied or fastened together to make a longer ladder
   Single rail ladders will not be used
   Will not carry an object that could cause loss of balance

LADDERS: PORTABLE

Portable ladders must be able to support safely:

   At least 4 times the maximum intended load
   Or at least 3.3 times maximum intended load for extra-heavy duty type 1A metal or
    plastic

Rungs/Steps

Portable ladders must have rungs and steps that are:

   Corrugated
   Knurled
   Dimpled
   Coated with skid resistant material; or
   Treated to minimize slipping




              Copyright EPL for Residential Inc.                                        137
Structural Defects

Portable ladders with structural defects must be removed from service until repaired. If
not reparable they need to be tagged as defective and disposed of so they are not used.

If they are repairable they must be:

   Marked as defective to identify them; or
   Tagged with “Do Not Use”

Employees need to be made aware that if they see a defect they need to pull the ladder
from service and are not use it under any circumstances. Examples of some defect are:

   Broken or missing rungs, cleats or steps
   Broken or split rails
   Corroded components
   Other faulty components

Accessing Upper Landing Surfaces

When accessing upper landing surfaces, side rails MUST be:

   3 feet above the surface leading edge and secured if possible
   Below 3’ it MUST be secured; and
   Fitted with a side grab rail

The ladder must also be placed:

   At an angle so the rungs are parallel to the ground
   Out of the way of traffic areas (overhead & garage doors, pedestrian walkways and
    doors) anywhere there could be a traffic hazard.




              Copyright EPL for Residential Inc.                                      138
       7.11 ASBESTOS ABATEMENT POLICY & PROCEDURE



GENERAL MANAGER RESPONSIBILTIES



SCOPE: It is the responsibility of the General Manager to review this material in its entirety and
ensure the execution of this package is done properly. It is imperative there be no deviation from
the rules and requirements within this packet due to (Company ABC)’ company policy regarding
asbestos.




                            Copyright EPL for Residential Inc.                                139
         STATE APPROVED ABATEMENT CONTRACTORS

SCOPE: The following instructions on state approved asbestos abatement contractors are provided for
use by the Company’s. The lists of state approved asbestos abatement contractors were developed by the
individual states, not (Company ABC) Inc.

Should the possibility of asbestos be discovered in a residential or commercial job and performance of the
job by (COMPANY ABC) may disturb the asbestos, this package must be adhered to. The following
outlines the steps to take in case of discovering potential asbestos:

 Provide the consumer the list of state approved asbestos contractors unaltered with the cover sheet
  explaining that it is the most recent list (COMPANY ABC) has. If the consumer wants to review a
  more recent list they should contact the state.

 (COMPANY ABC) does not subcontract or pay for any asbestos related activities. It is the
  consumer’s responsibility to contact one of the contractors on the list.

 If the customer asks what abatement companies other Company customers have used, the Comfort
  Advisor may say what contractors he/she knows that have been used.

 It is the consumer’s responsibility to call the abatement company and set up the abatement and pay
  the contractor directly.

 Comfort Advisor can speak with an abatement company if customer chooses. If the customer calls an
  abatement company during the sales appointment, the Comfort Advisor can speak to the abatement
  company to answer questions




                              Copyright EPL for Residential Inc.                                     140
          ASBESTOS POLICY & TRAINING INSTRUCTIONS

SCOPE: The following is a checklist to help GM’s navigate (COMPANY ABC)’s current asbestos
policy and training requirements.

This checklist is in a suggested order to make it easier for all those involved

(Note: AFFECTED employees are those employees who could potentially come into contact with
possible asbestos during the course and scope of their work).

ASBESTOS AWARNESS TRAINING: REQUIRED

        TRAIN ALL POSSIBLE AFFECTED EMPLOYEES (Examples):
           Comfort Advisors
           Service/Maintenance Technicians
           Residential Replacement Crews
           Commercial Replacement Crews

TRAINING
                Post Test: Using booklet with video
                Place Tests in File: 80% passing required.
                Comfort Advisors: Consider using “ Job Safety Preplanning Review”
                Review (COMPANY ABC) policy with all affected employees, sign and place in file
                Review educational piece “Asbestos in Your Home” with Comfort Advisors, which can
                 be used as a tool with the consumer.




                               Copyright EPL for Residential Inc.                             141
              COMFORT ADVISORS
ASBESTOS ABATEMENT CONTRACTOR INSTRUCTIONS
SCOPE: The following is a checklist to use in the event asbestos is discovered in a residential or
commercial job and performance of the job by (COMPANY ABC) may disturb the asbestos. If the
asbestos will not be disturbed, or fragmented, this package need not be adhered to.


1. Have you been trained in Asbestos Awareness?
2. Use the “Job Safety Pre-Planning” sheet when evaluating the job.
3. If you suspect or know asbestos will be disturbed during the course and scope of the job, complete the
   following prior to selling the job:
    Inform the consumer of the possibility of asbestos.
    Use the “Asbestos in Your Home” educational tool to inform the consumer.
    Provide the consumer with the unaltered list of state approved asbestos abatement contractors.
4. If the customer asks what abatement companies other Company customers have used, the Comfort
   Advisor may say what contractors he/she knows that have been used.
5. Comfort Advisor can speak with an abatement company if customer chooses. If the customer calls an
   abatement company during the sales appointment, the Comfort Advisor can speak to the abatement
   company to answer questions
6. (COMPANY ABC) cannot pay for, provide credit or be connected in any monetary way to the
   abatement job.
7. The consumer will need to obtain and present an entry certificate from the abatement company before
   (COMPANY ABC) employees return to the premise, if required by the state. If the state allows the
   consumer to abate the material, they do not need to supply a re-entry certificate.




                              Copyright EPL for Residential Inc.                                    142
                                   “Asbestos in Your Home”

Until the 1970’s, many types of building products and insulation materials used in homes
contained asbestos. Most products today do not contain asbestos, however, those that do require
a label if the asbestos containing material could be inhaled.

As heating and air conditioning contractors, (Company ABC) Inc. employees do occasionally
encounter asbestos at a consumer’s property. The purpose of this information is to help you
understand what asbestos is, how it can affect your health, and offer some suggestions on what to
do about it.

What is Asbestos?

Asbestos is a mineral fiber. It can be positively identified only with a special type of
microscope. There are several types of asbestos fibers. In the past, asbestos was added to a
variety of products to strengthen them and to provide heat insulation and fire resistance.

It is not uncommon for homes built between 1930 and 1950 to have asbestos insulation. Hot
water and steam pipes in older houses may be coated with an asbestos material or covered with
an asbestos blanket or tape. Oil and gas furnace insulation and door gaskets sometimes contain
asbestos, as do protective paper and board materials that are sometimes installed around wood
burning stoves. The same is true for door gaskets in coal and wood stoves. Also, artificial ashes
and embers sold for use in gas fireplaces may sometimes contain asbestos.

How Can Asbestos Affect My Health?

From studies of people who were exposed to asbestos in factories and shipyards, we know that
breathing high levels of asbestos fibers can lead to an increased risk of some different types of
lung cancer. The risk of illness increases with the number of fibers inhaled. People who are
exposed and also smoke have a greater risk.

Most people exposed to small amounts of asbestos, as we all are in our daily lives, do not
develop these health problems. However, if disturbed, asbestos material may release asbestos
fibers, which can be inhaled into the lungs. The fibers can remain there for a long time,
increasing the risk of illness. Asbestos material that would crumble easily if handled, or that has
been sawed, scraped, or sanded into a powder, is more likely to release fibers and create a
health hazard.


What Can You Do About It?

(Company ABC) Inc. highly encourages customers against any attempt to remove or disturb asbestos
containing material in the completion of a job before consulting with a company that is trained and
qualified to handle it.

Asbestos professionals can be consulted to conduct home inspections. During their inspections, they will
typically take samples of suspected material, assess its condition, and advise about needed corrections and
the people qualified to make them. Professional correction (or abatement) contractors repair or remove
asbestos material. A good rule of thumb is to only hire professionals who are trained, experienced,
reputable, and accredited – especially if accreditation is a requirement of your local and state laws.

                              Copyright EPL for Residential Inc.                                      143
Although private homes are usually not covered by the asbestos regulations that apply to schools and
public buildings, asbestos professionals should still use procedures described during federal or state-
approved training. State and local health departments or regional offices of the Environmental Protection
Agency (EPA) can help you with a more detailed understanding of this and may have listings of licensed
professionals in your area.

*Note the following phrase was changed for grammatical correctness and does not change the
meaning. “Asbestos professionals can conduct home inspections, take samples of suspected
material, assess its condition, and advise about needed corrections and the people qualified to
make them”.

(Company ABC) Inc. provides this information to customers to assist them with understanding asbestos.
The American Lung Association, the U.S. Consumer Product Safety Commission, and the U.S.
Environmental Protection Agency are to be credited for its development.

Statement by the American Lung Association: The Statements contained in this information are based in
part upon the results of a workshop concerning asbestos in the home which was sponsored by the U.S.
Consumer Product Safety Commission and the American Lung Association (ALA). The sponsors believe
that this information provides an accurate summary of useful information discussed at the workshop and
obtained from other sources. However, ALA did not develop the underlying information used to create
this and does not warrant the accuracy and completeness of such information.

ALA emphasizes that asbestos should not be handled, sampled, removed, or repaired by anyone
other than a qualified professional.




                              Copyright EPL for Residential Inc.                                    144
                                   JOB SAFETY PREPLANNING
         TO ENHANCE EMPLOYEE SAFETY & MINIMIZE WORK DISRUPTION


COMPANY                                                         JOB NAME:
JOB NUMBER/LOCATION:
JOB TYPE: Residential Replacement                               Residential New Construction
        Commercial Replacement                                  Commercial New Construction


Year Built:                        # of Stories:                    Basement:   Yes                   No
Pier & Beam Crawl Space:           Yes No             Ease of Access: Good Poor

Roof: Pitched <6/12 6/12-12/12 >12/12               Flat Other:
Roof Cover: Asphalt Slate Tin Other:
Type Attic Access: Retractable Stair         Removable Cover
Attic Decking Present:         Yes No        Ventilated: Yes No
Height in Attic:
Inside Ceiling Heights
Location of circuit breakers or power disconnect:
Air-conditioning location
Heating Unit Location
Fireplace(s)
Outdoor Pets                   Are they Secure?:    Yes No

Do you feel any scaffolding, fall protection or special ladders be needed? If yes, explain.



Any unusual internal or external property hazards that could impact our employees’ safety? If
yes, explain.



Any special materials or equipment handling devices needed? If yes, explain:




Asbestos possibly present?         Yes       No       Unknown
       If unknown and we could disturb it during our work, the area would have to be tested by the building owner
       per the company policy.
If present will we disturb during the course and scope of our work?                         Yes       No
       If yes, the property owner to have it abated prior to us starting the job, for their safety and the safety of our
       employees.
       Any hazardous chemicals or processes in the area of our work (Commercial)? If yes, explain:



       Comfort Advisor Name:                                  Comfort Advisor Signature:
       Reviewed By Crew: Yes       No                 Lead Crew Person Signature:
                                 Copyright EPL for Residential Inc.                                                 145
7.11     ASBESTOS POLICY

Purpose

This policy pertains to all (Company ABC) Inc. residential and commercial Company’s and employees who could
come into contact with possible asbestos on the job. This communication is to make sure that everyone understands
the company’s position when it comes to this issue. There are several aspects to consider when it comes to this issue,
the health & safety of worker and consumer, the environment and our operational liability.

POLICY

Asbestos has been linked to asbestosis, lung cancer and other severe lung impairments for which there is no cure or
treatment. The potential exposure to (COMPANY ABC) employees is high and they should understand the
seriousness of this issue. (COMPANY ABC) prohibits its employees from abating asbestos.

(COMPANY ABC) will not and cannot carry insurance to cover this type of exposure. Because (COMPANY ABC)
has no insurance for this type of activity, (COMPANY ABC) must not be involved with asbestos abatement nor sub-
contracting for abatement. The responsibility must remain with the consumer.

Because (COMPANY ABC) has adopted a "hands-off" asbestos policy, under no circumstances
should asbestos containing materials be disturbed, regardless of the quantity or type of material
present. If possible asbestos is identified, the job should only continue if the job could be
completed without disturbing the asbestos or if it is abated by a state approved abatement
company.

It is the policy of (Company ABC) and its subsidiaries not to become involved in direct contact, removal, disposal,
contracting or subcontracting of the abatement of asbestos at any job site.

PROCEDURE

Prior to starting jobs in which (COMPANY ABC) employees could come into contact with asbestos, comfort
advisors should ask the consumer whether or not they have asbestos on the premises that could result in exposure to
(COMPANY ABC) employees during the course of their work. This could be done utilizing the job safety pre-
planning checklist. If asbestos is present:

   It is the responsibility of the consumer to have it abated.
   Companies must utilize the state-approved list, unaltered.
   If the customer asks what abatement companies other Company customers have used, the Comfort Advisor may
    say what contractors he/she knows that have been used.
   Comfort Advisor can speak with an abatement company if customer chooses. If the customer calls an
    abatement company during the sales appointment, the Comfort Advisor can speak to the abatement company to
    answer questions.
   The consumer will need to obtain and present an entry certificate from the abatement company before
    (COMPANY ABC) employees return to the premises, if required by the state. If the state allows the consumer
    to abate the material, they do not need to supply a re-entry certificate.
   Do not reimburse the consumer in any way for the cost of the abatement, including, but not limited to,
    crediting their account, paying cash or offsetting the consumer’s final bill.

Should (COMPANY ABC) employees suspect they could disturb possible asbestos during the course of the job,
they should stop work immediately, contact their supervisor, comfort advisor or general manager. The Company
will immediately notify the consumer and inform them of the possible presence of asbestos and recommend they
have the substance tested. The state approved abatement companies may be able to help them with this. The test

                                  Copyright EPL for Residential Inc.                                             146
results are to be filed in consumer’s permanent file. If the results are negative, (COMPANY ABC) can proceed. If
positive, the information contained in this package must be adhered to.
THERE WILL BE NO EXCEPTIONS TO THE POLICY.

Scenario

Dave, a comfort advisor from ABC HVAC (Company ABC), has been dispatched to spec a
residential replacement job. Upon arrival, the homeowner takes Dave into the basement to look
at the 20-year old system. The ductwork is wrapped with what appears to be possible asbestos
insulation. What should Joe or Jane do?

Dave should do all of the following:

    Notify the consumer that he/she has identified what he/she feels to be asbestos containing
      material.
     Inform the consumer that (Company ABC) does not permit any of their employees to
      jeopardize the health of the consumer, themselves or the environment by
      handling/disturbing asbestos.
    Explain that the service job can only be completed once a professional asbestos survey
      has been completed, and any asbestos containing material properly abated. This is the
      responsibility of the consumer. The abatement work cannot be contracted or
      subcontracted by the (Company ABC) Company, as there are strict training, insurance
      and licensing requirements governing asbestos abatement.
     Provide the consumer with the state-approved list, educate them using the tools in
      the packet and follow the guidelines in the above procedure.
     All documents must be placed in the consumer’s file.

Please make a copy and have all employees who may come in contact with possible asbestos containing material
during the course of his or her work, read and sign-off on this policy and place the signed copy in their personnel
file.

By signing below, I have read, understand and agree to adhere to the (COMPANY ABC) Asbestos Policy.

Employee Name (Printed)

Employee Signature
                                                  Date

General Manager Signature                                     Date_______________________________




                                 Copyright EPL for Residential Inc.                                           147
7.13   SAMPLE HAZARD ASSESSMENT PLAN

       OSHA requires employers to assess their workplace to determine if any actual or potential
       hazards require the use of personal protective equipment (PPE). The regulations require that the
       employer identify hazards and verify the assessment in writing. OSHA requires employers to
       first eliminate or reduce (if elimination is not possible) hazards through engineering controls and
       administrative (work practice) controls before using PPE for hazard protection.

       Company’s must also:

            select PPE to protect employees
            require employees to use selected PPE
            provide necessary training to employees
            not use damaged or defective PPE

       This sample plan includes:

            general guidelines for hazard review and assessment
            general guidelines for eye and face protection
            general guidelines for head protection
            general guidelines for foot protection
            general guidelines for hand protection
            a certification of hazard assessment
            employee training and certification

       Employers Covered

       All Company’s are required to conduct a hazard assessment.

       Related Plan

       Every Company must also require employees to wear respirators when necessary to protect their
       health. Any employer whose employees must wear a respirator as a protective device is also
       required to develop and implement a separate respirator plan.




                             Copyright EPL for Residential Inc.                                      148
                        SAMPLE HAZARD ASSESSMENT PLAN




________________________________________________________________________
Company Name




________________________________________________________________________
Street address

________________________________________________________________________
City                              State                          ZIP code



Hazard assessment certified by:


________________________________________________________________________
Print name


______________________________________           ______________________________
Title                                                                   Number


______________________________________           ______________________________
Signature                                                                  Date




                           Copyright EPL for Residential Inc.                     149
                                      GENERAL REQUIREMENTS

OSHA requires employers to assess their workplaces to determine if any hazards require the use of
personal protective equipment (PPE). Protective equipment must be used whenever hazards or processes
of the environment, chemical hazards, radiological hazards, or mechanical irritants could cause injury or
impairment through absorption, inhalation, or physical contact.

A Company must identify hazards that are either actually present or likely to be present. If such hazards
exist, the Company must:

     select the types of PPE that will protect against the identified hazards
     verify the hazard assessment in writing
     inform employees of the PPE that is selected by the employer
     require employees to use the selected PPE
     ensure that any PPE provided to employees is of the correct type and properly fits each employee
     provide training to each employee who is required to use PPE
     not use damaged or defective PPE

Reassessment of Hazards
The safety team leader is required to reassess the workplace hazard situation as necessary by:

     identifying and evaluating new equipment and processes;
     reviewing accident records; and
     reevaluating the suitability of previously selected PPE.

                            CONTROLLING HAZARDS – IN GENERAL

PPE devices alone should not be relied on to provide protection against hazards. They should be used in
conjunction with guards, engineering controls, and sound business practices. In fact, Company’s should
first attempt to eliminate or reduce hazards through engineering and administrative controls. PPE should
be used if the engineering and administrative controls cannot provide complete protection.

                         ASSESSMENT AND SELECTION – IN GENERAL

General guidelines should be followed for assessing the foot, head, eye and face, and hand hazards that
exist in an operation or process and for matching the protective devices to the particular hazard. The
safety team leader has the responsibility to exercise common sense and appropriate knowledge to make
the assessment and selection. To assess the need for PPE, the following guidelines should be followed:

Conduct Survey

A walk-through survey of the Company and jobsites in question should be conducted. The survey helps
identify sources of hazards to workers. Consideration should be given to the following basic hazard
categories:

     impact
     penetration
     compression (roll-over)
     chemical
     heat
     harmful dust
     light (optical) radiation

                                  Copyright EPL for Residential Inc.                                  150
Observe Sources of Hazards

During the walk-through survey, the safety team leader and department supervisors should observe:

     sources of motion (e.g., machinery or processes where any movement of tools, elements, or
      particles could exits or movement of personnel could result in collision with stationary objects)
     sources of high temperatures that could result in burns, eye injury, ignition of protective
      equipment, etc.
     types of chemical exposures
     sources of harmful dust
     sources of light radiation, i.e., welding, brazing, cutting, furnaces, heat treating, high intensity
      lights, etc.
     sources of falling objects or potential for dropping objects
     sources of sharp objects that might pierce the feet or cut the hands
     sources of rolling or pinching objects that could crush the feet
     layout of workplace and location of workers
     any electrical hazards

Review Injury/Accident Data

In addition to the walk-through survey, injury/accident data should be reviewed to help identify problem
areas. The Company general manager is getting this information monthly.

Organize Data

Following the walk-through survey and review of injury/accident data, the information must be organized
for the hazard assessment. Organization of the information aids in the analysis of the hazards in the
environment. This in turn helps ensure proper selection of protective equipment.

Analyze Data

After workplace data has been gathered and organized, and estimate of the potential for injuries should be
made. Each of the basic hazards should be reviewed and a determination made for each of the hazards
found in the area as to:

     the type of hazard;
     level of risk; and
     seriousness of potential injury.

The possibility of exposure to several hazards simultaneously must be considered.


               GUIDELINES FOR SELECTION AND USE OF PPE – IN GENERAL

     Become familiar with the potential hazards and the type and effectiveness of protective equipment
      available (e.g., splash protection, impact protection, etc.)

     Be sure to recognize the possibility of multiple and simultaneous exposure to a variety of hazards.
      For example, operations involving heat may also involve light radiation. Protection from both
      hazards must be provided.


                               Copyright EPL for Residential Inc.                                            151
     Select the protective equipment that ensures a level of protection greater than the minimum
      required to protect employees from the hazards. Adequate protection against the highest level of
      each of the hazards should be provided. Protective devices do not provide unlimited protection,
      however.
     Compare the hazards associated with the environment (e.g., impact velocities, masses, projectile
      shape, radiation intensities) with the capabilities of the PPE.

     Fit the user with the protective device and give instructions on care and use of the PPE. It is very
      important that end users are made aware of all warning labels for and limitations of their PPE.

Fitting the Device

Careful consideration must be given to comfort and fit. PPE that fits poorly will not afford the necessary
protection. In addition, continued wearing of the devices by employees is more likely if they fit the
wearers comfortably.

Protective devices are generally available in a variety of sizes. Care must be taken to make sure that the
right size is selected. Get employee feedback and input!

Devices with Adjustable Features

Individual adjustments should be made to provide a comfortable fit and maintain the protective device in
the proper position. Particular care must be taken in fitting devices for eye protection against dust and
chemical splash to ensure that they are sealed to the face. In addition, proper fitting of helmets helps
ensure that they will not fall off during work operations. In some cases, a chinstrap may be necessary to
keep the helmet on an employee'’ head. (Chin straps should break at a reasonably low force, however, so
as to prevent a strangulation hazard.) If manufacturer’s instructions are available, they must be followed
carefully.


                     EYE AND FACE PROTECTION – GENERAL GUIDELINES

1.      Company’s must use appropriate eye or face protection when exposed to hazards from:

              flying particles
              molten metal
              liquid chemicals
              acids or caustic liquids
              chemical gases or vapors
              potentially injurious light radiation

2.      Protective eye and face devices purchased on or after July 5, 1994, must comply with ANSI
        Z87.1-1989 or be equally effective. Devices purchased before that date and employers subject to
        OSHA’s construction industry standards must comply with ANSI Z87.1-1968 or be equally
        effective.

3.      Face-shields should be worn only over primary eye protection (spectacles or goggles).

4.      Persons whose vision requires the use of prescription lenses must wear either protective devices
        fitted with prescription lenses or protective devices designed to be worn over regular prescription
        eyewear.


                               Copyright EPL for Residential Inc.                                       152
5.   Wearers of contact lenses must also wear appropriate eye and face protection devices in a
     hazardous environment. Dusty and chemical environments may represent an additional hazard to
     contact lens wearers.

6.   Some occupations (not a complete list) for which eye and face protection should be routinely
     considered are:

                    automotive technicians
                    carpenters
                    electricians
                    machinists
                    mechanics
                    repairers
                    millwrights
                    plumbers
                    pipe fitters
                    sheet metal workers
                    tinsmiths
                    assemblers
                    body shop workers
                    sanders
                    grinding machine operators
                    lathe operators
                    milling machine operators
                    sawyers
                    welders
                    laborers
                    chemical process operators
                    chemical handlers
                    timber cutters
                    logging workers

     Note: We fit into many of these various occupations and could be exposed to these
     occupations by other contractors while on job sites.

     7.        The following chart provides general guidance for the selection of eye and face
               protection to protect against hazards associated with the listed hazard “source”
               operations:




                             Copyright EPL for Residential Inc.                                     153
                             EYE AND FACE PROTECTION SELECTION CHART

            SOURCE                      ASSESSMENT OF HAZARD                         PROTECTION
IMPACT – chipping, grinding,           flying fragments, objects, large     Spectacles with side protection,
machining, masonry work,               chips, particles, sand, dirt, etc.   goggles, face-shields; for severe
woodworking, sawing, drilling,                                              exposure, use face-shield
chiseling, powered fastening,
riveting, and sanding
HEAT – furnace operations,             Hot sparks                           Face-shields, goggles, spectacles
pouring, casting, hot dipping, and                                          with side protection; for severe
welding                                                                     exposure, use face-shield

                                       Splash from molten metals            Face-shields worn over goggles

                                       High temperature exposure            Screen face-shields, reflective
                                                                            face-shields
CHEMICALS – acid and                   Splash                               Goggles, eyecup and cover types;
chemicals handling, degreasing,                                             for severe exposure, use face-
plating                                                                     shield

                                       Irritating mists                     Special-purpose goggles
            SOURCE                      ASSESSMENT OF HAZARD                        PROTECTION
DUST – woodworking, buffing,           Nuisance dust                        Goggles, eyecup and cover types
general dusty conditions
LIGHT AND/OR RADIATION                                                      Welding helmets or welding
– welding: electric arc                Optical radiation                    shields typical shades: gas
                                                                            welding 4-8, cutting 3-6, brazing
                                                                            3-4

Welding: gas                           Optical radiation                    Welding goggles or welding face-
                                                                            shield; typical shades: gas
                                                                            welding 4-8, cutting 3-6, brazing
                                                                            3-4

Cutting, torch; brazing, torch;        Optical radiation                    Spectacles or welding face-
soldering                                                                   shield; typical shades: 1.5-3

Glare                                  Poor vision                          Spectacles with shaded or
                                                                            special-purpose lenses, as suitable




                                     Copyright EPL for Residential Inc.                                           154
        8.         The chart below provides general guidance for the selection of eye protection to protect
                   against radiant energy:


                     FILTER LENSES FOR PROTECTION AGAINST RADIANT ENERGY

      MINIMUM                ELECTRODE SIZE                  ARC                  PROTECTIVE
    OPERATONS                   1/32 INCH                 CURRENT                   SHADE
Shielded metal arc              Less than 3               Less than 60                 7
welding                             3-5                     60-160                     8
                                    5-8                     160-250                   10
                                more than 8                 250-550                   11

Gas metal arc welding                                     Less than 60                 7
and flux cored arc                                           60-160                   10
welding                                                     160-250                   10
                                                            250-550                   10
Gas tungsten arc                                          Less than 50                 8
welding                                                      50-150                    8
                                                            150-500                   10
Air carbon                          (light)               Less than 500               10
Arc cutting                        (heavy)                  500-1000                  11
Plasma arc welding                                        Less than 20                 6
                                                             20-100                    8
                                                            100-400                   10
                                                            400-800                   11
Plasma arc cutting                  (light)               Less than 300                8
                                  (medium)                  300-400                    9
                                   (heavy)                  400-800                   10
Torch brazing                                                                          3
Torch soldering                                                                        2
Carbon arc welding                                                                    14
                            PLATE THICKNESS          PLATE THICKNESS              PROTECTIVE
OPERATIONS                      (INCHES)                  (MM)                      SHADE
Gas Welding:
  Light                          Under 1/8 in.           Under 3.2 mm                    4
  Medium                         1/8 to 1/2 in.          3.2 to 12.7 mm                  5
  Heavy                           over 1/2 in.            over 12.7 mm                   6
Oxygen cutting:
  Light                           Under 1 in.             Under 25 mm                    3
  Medium                           1 to 6 in.             25 to 150 mm                   4
  Heavy                            over 6 in.             over 150 mm                    5




                                 Copyright EPL for Residential Inc.                                      155
                            EYE AND FACE PROTECTION – SELECTION

Requirements for side protection, prescription lenses, filter lenses, and identification of the manufacturer
of safety equipment must be specified below.

As assessment of this Company and jobsite exposures has been completed in accordance with the above
Eye and Face Protection – General Guidelines, including the applicable ANSI standards. Employees
___________ required to wear eye and face protection.


Required PPE will be used in the specific situations and locations listed below:

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________




                               Copyright EPL for Residential Inc.                                        156
                        HEAD PROTECTION – GENERAL GUIDELINES


1.    Protective helmets purchased on or after July 5, 1994, must comply with ANSI Z89.1-1986 or be
      equally effective. Helmets purchased before that date and employers subject to OSHA’s
      construction industry standards must comply with ANSI Z89.1-1969 or be equally effective.

2.    Employees must wear protective helmets when working in areas where there is a potential for a
      head injury from falling objects. All helmets must be designed to provide this protection.

      Some examples include:

             working below other workers who are using tools and materials that could fall
             working around and under conveyor belts that are carrying parts or materials
             working below machinery or processes that might cause material or objects to fall
             working on exposed energized conductors

3.    Examples (not a complete list) of occupations for which some form of head protection should be
      routinely considered are:

             laborers
             electricians
             linemen
             plumbers
             logging workers
             packers
             auto body shop workers
             automotive technicians
             welders
             freight handlers
             timer cutters
             stock handlers
             warehouse laborers
             carpenters
             sawyers
             mechanics
             repairers
             pipe fitters
             assemblers
             wrappers

4.   When selecting head protection, electrical shock and burn hazards must be guarded against as well
     as dangers from falling objects. Protective helmets designed to reduce electrical shock hazards
     must be work by each affected employee when electrical conductors or other electrical hazards
     could contact the head.




                            Copyright EPL for Residential Inc.                                    157
In selecting head protection, knowledge of potential electrical hazards is essential.

       Class A helmets – in addition to impact and penetration resistance, provide electrical
 protection from low-voltage conductors. (They are proof tested to 2,200 volts.)

       Class B helmets – in addition to impact and penetration resistance, provide electrical
protection from high-voltage conductors. (They are proof tested to 20,000 volts.)

      Class C helmets – provide impact and penetration resistance, but they are usually made of
aluminum, which conducts electricity. They should not be used around electrical hazards.


                          HEAD PROTECTION – SELECTION

An assessment of this Company and jobsite exposures has been completed in accordance with the
above Head Protection – General Guidelines, including the applicable ANSI standards.
Employees ___________ required to wear head protection.


                   are/are not

PPE of the type specified will be used in the specific situations and locations listed below:

__________________________________________________________________

__________________________________________________________________

__________________________________________________________________

__________________________________________________________________

__________________________________________________________________

__________________________________________________________________

__________________________________________________________________




                       Copyright EPL for Residential Inc.                                        158
                FOOT PROTECTION – GENERAL GUIDELINES

1.   Employees must wear protective footwear (safety shoes and boots) when working in
     areas where there is a danger of foot injuries from:

            Falling or rolling objects
            Objects piercing the sole
            Exposure of employees’ feet to electrical hazards

     Protective footwear purchased on or after July 5, 1994, must comply with ANSI Z41.1-
     1991 or be equally effective. Protective footwear purchased before that date and
     employers subject to OSHA’s construction industry standards must comply with ANSI
     Z41.1-1967 or be equally effective.

2.   Protective footwear must provide both impact and compression protection. Safety shoes
     or boots with impact protection would be required, for example, for workers carrying or
     handling materials such as packages, objects, parts, or heavy tools that could be dropped,
     and for other workers performing activities during which objects might fall onto the feet.
     Safety shoes or boots with compression protection would be required, for example, for
     work activities involving skid trucks (manual material handling carts), around bulk rolls
     (such as paper rolls), and heavy pipes, all of which could potentially roll over an
     employee’s feet.

3.   Where necessary, safety shoes must also provide puncture protection. An example would
     be the situation where sharp objects (such as nails, wire, tacks, screws, large staples,
     scarp metal, etc.) could be stepped on by employees and cause a foot injury.

4.   In some special situations, metatarsal protection is required. In others electrical
     conductive or insulating safety shoes would be necessary.

5.   Some occupations (not a complete list) for which foot protection should be routinely
     considered are:

            Automotive technicians
            Shipping clerks
            Receiving clerks
            Carpenters
            Electricians
            Machinists
            Mechanics
            Repairers
            Plumbers
            Pipe fitters
            Structural metal workers
            Body shop workers
            Helpers
            Assemblers
            Drywall installers
            Lathe operators
            Packers
            Wrappers
            Craters
                   Copyright EPL for Residential Inc.                                       159
                        Punch operators
                        Stamping press operators
                        Gas station attendants
                        Sawyers
                        Welders
                        Laborers
                        Freight handlers
                        Gardeners
                        Groundskeepers
                        Timber cutters
                        Logging workers
                        Stock handlers
                        Warehouse laborers

                                  FOOT PROTECTION – SELECTION

An assessment of this Company and jobsite exposures has been completed in accordance with the above
Foot Protection – General Guidelines, including the applicable ANSI standards. Employees
____________ required to wear foot protection.


are/are not

PPE of the type specified will be used in the specific situations and locations listed below:

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________




                               Copyright EPL for Residential Inc.                                160
                          HAND PROTECTION – GENERAL GUIDELINES

1.      Employers must require employee use of appropriate hand protection whenever employees’
        hands are exposed to hazards from:

               Skin absorption of harmful substances
               Severe cuts or lacerations
               Severe abrasions
               Punctures
               Chemicals burns
               Thermal burns
               Harmful temperature extremes

2.      Employers will select appropriate hand protection based on an evaluation of:

               the performance of the hand protection relative to the tasks to be performed;
               the conditions present;
               the duration us use; and
               the actual and potential hazards identified.

3.      Gloves are often relied on to prevent cuts, abrasions, burns, and skin contact with chemicals that
can cause local or systemic effects following skin exposure. We are unaware of any gloves that provide
complete protection against all potential hand hazards. Commonly available glove materials provide only
limited protection against many chemicals. It is important to:

               select the most appropriate glove for a particular application;
               determine how long it can be worn; and
               determine whether it can be reused.


                                  HAND PROTECTION – SELECTION

An assessment of this Company and jobsite exposures has been completed in accordance with the above
Hand Protection – General Guidelines, including the applicable ANSI standards.
Employees __________ required to wear hand protection.


            are/are not

PPE of the type specified will be used in the specific situations and locations listed below:

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________



                               Copyright EPL for Residential Inc.                                     161
                               REQUIRED TRAINING – IN GENERAL


The employer must provide training to each employee required to use PPE. Training will include:

      when PPE is necessary
      what PPE is necessary
      how to wear PPE
      the limitations of PPE
      proper care, maintenance, useful life, and disposal of PPE

The employer must certify in writing that the employee has received and understands the training. The
certification record will identify:

      each employee trained
      the dates of training
      the document that establishes Certification of Training in the use of PPE

When an employee who is already trained no longer has the understanding or skill to be protected from
hazards, the employer must retrain the employee annually. Circumstances requiring retraining include:

      changes in the workplace that render previous training obsolete
      changes in the types of PPE that render previous training obsolete
      the employee’s failure to continue to correctly use the assigned PPE




                              Copyright EPL for Residential Inc.                                    162
                                   TRAINING CERTIFICATON RECORD

For ____________________________________________________________________

Identify subject of PPE training

________________________________________________________________________
Company

________________________                             ____________________________________
Date                                                Trainer

This certifies that the following employees received training on the proper use of necessary PPE on the
dates listed below:

Date
Name
Social Security #
Signature_______________________________________________________________________




                              Copyright EPL for Residential Inc.                                      163
9. OSHA: OCCUPATIONAL SAFETY & HEALTH ADMINISTRATION

The following information is going to provide you guidelines on various pieces of OSHA information.
There is also very helpful information on the OSHA website at www.osha.gov.

Be aware that several states have OSHA approved state plans as well. (Company ABC) Inc. does fall
under both the General Industry (CFR 1910) and Construction (CFR 1926) standards as it pertains to the
code of federal regulations. It is the law…

        OSH Act of 1970

“….to assure far as possible every working person in the nation safe and healthful working conditions and
to preserve our human resources.”

        OSHA’s “General Duty Clause” 5(a)(1)

“Each employer shall furnish to each of his/her employees employment and a place of employment which
are free from recognized hazards that are causing or likely to cause death or serious physical harm to
his/her employees.”

The General Duty Clause is a catch all for citations. Regardless of whether or not an OSHA standard
exists, an unsafe condition can result in citation. In other words just complying with OSHA standards
does not mean you cannot be cited if there is no standard to reference. This means that not only do
we need to be compliant but also we must address all recognized hazards in our Company’s and job
sites.




                              Copyright EPL for Residential Inc.                                     164
9.1 INSPECTIONS

  If you have not already been through an OSHA inspection the following information may be
  useful for you. If you have, this may be extra information you may not be aware of. OSHA
  must have just cause to enter your Company and the following will be cited by the inspector
  for “just cause”.

  Reasons For Inspections

     Imminent Danger (CFR 1903.13)
     Targeted Industries
     Employee Complaints
     Media Generated Complaints
     Follow Up Inspections
     Program Inspection
     Catastrophes & Fatal Accidents


  Employer (Company) Rights

      The Company has the right to deny entry and request a warrant.
      (Not a Company option)

   The Company has the right to allow certain areas of the Company to be inspected
  without a warrant.

  Items Typically Asked For During An Inspection

   OSHA 300 Logs & Supporting OSHA 101’s past 5 years (forms & instructions can be
  found on website)
   Emergency Action Plans
   Hazard Communication Program
   Company & Job site lock out tag out program (generic & specific)
   Safety related work practice program
   Confined space entry program (If applicable to Company operations)
   Written health & safety programs
   Physical Inspection of Company
   Ask to speak to employees during inspection

  What to do before, during & after an inspection

  Pre-inspection Preparation

     Develop procedures for reception personnel to follow when inspector arrives
     Identify management representative who will accompany inspector
     Identify employee representative who will accompany inspector
     Know location of all records required by OSHA




                    Copyright EPL for Residential Inc.                                    165
Opening Conference (Start of Inspection)

    Notify employee and management representatives
    Request to see inspector’s credentials
    Obtain inspectors name, office location and telephone number
    Establish whether the inspector has a warrant
    Determine what documentation the inspector wants to see
    Ask what triggered the inspection (just cause)
    Advise company legal counsel and safety manager of inspection
    Takes notes in detail…….

During Inspection

    ALWAYS accompany inspector!!
    Take notes on:
     What is seen
     Who is spoken to
     What is said
     Any samples or pictures taken
     Documents reviewed
    When in doubt ASK questions!!!

Closing Conference (Post Inspection)

    Provide additional relevant information that might have been overlooked
    DO NOT make admissions or argue your case with the inspector
    Request a receipt for any documents that they might take-give copies only!
    Request copies of any sampling or measurement reports that the inspector may take

If a Citation is Issued

 When you receive the citation post it near the area of violation (minimum 3 days or until
abated)
 Request informational conference to clarify citation
 Submit notice of contest within 15 working days of receipt of citation notice
 Remedy the uncontested violations within the stated abatement period

Inspection procedures should also be set up for the field when OSHA visits job sites. The
same procedures can be followed as stated above. The OSHA inspector does not determine
the fines. The area director determines them and he or she issues the citation based on the
inspectors site visit.




                    Copyright EPL for Residential Inc.                                   166
9.2   Penalties/Fines

      The following are categories of penalties before adjustments based outcomes:

       Fatality: $500,000 Corporation, $250,000 Individual or jail time for intentional
      disregard.
       Willful: $70,000 Maximum, $5,000 Minimum each affected employee and willful
      cannot be reduced.
       Repeated: Same fines as willful but deals with other locations with same type
      violation. Can be reduced.
       Serious, Other Than Serious, Other specific violations: $7,000 Maximum, $1,000
      Minimum.
       Failure to Abate: $7,000 Maximum each day starting from abatement deadline.
       OSHA Notice: $1,000
       Failure to post OSHA 300 Summary: $1,000
       Failure to maintain OSHA 300 & 301: $1,000
       Failure to post issued citation: $3,000
       Failure to report fatality: $5,000 each day from date of fatality
       Records Access: $1,000
       Notification Requirements (CFR 1903.6): $2,000

      Examples of Penalties

          Fatality: Apparent
          Serious, Other than serious, Willful
           Low probability that death or serious injury will occur. $1,000-$7,000.
           Substantial probability that death or serious injury could occur. You know or
          should have known. $1,000-$7,000.
           Intentional disregard or plain indifference. $5,000-$70,000.
          Failure to abate
           You were to have this fixed by mm/dd/yy and you did not. Penalty is assessed
          starting at the fixed by date. $7,000 per day.
          Other Penalties
           Falsifying records, reports or applications. Up to $10,000 and/or six months in
          prison.
           Posting requirements. Up to $7,000.
           Assaulting or interfering with a compliance officer with their duties is a criminal
          offense, subject to fine of not more than $5,000 and imprisonment for not more than
          3 years.

      The area OSHA director can discount maximum penalties based on:
       First time OSHA inspection
       Small size of company
       Good faith

      No discount allowed for willful violations.




                    Copyright EPL for Residential Inc.                                     167
9.3   Postings & Record Keeping

      POSTINGS

      The Plain Language Poster, #3165, is going to be used as OSHA runs out of the other,
      #2203. If you have Poster # 2203 you do not need to get the new one, #3165. The new
      poster must be printed in color and on an 8.5”x14” page. The poster must be placed in a
      conspicuous place so employees can view it. It must also be present on new construction
      job sites If you do not have a color printer you can order it online from the OSHA
      website. You can also contact your local OSHA office to order materials.

      RECORDKEEPING
      OSHA requires all employers to maintain and post their OSHA 300 logs. The only
      exception is employers who have 10 or fewer employees. Since we are one company they
      require all our locations to have them regardless of size. These logs are used to record
      work-related injures. The 300 from the past year log must be posted each February in a
      common area where all employees can see the accidents for the past year. The OSHA 301
      must accompany each recorded injury. This is a supplementary record of the individual
      accidents you record. Other forms such as insurance first reports of injury, in house
      injury reviews are not accepted.

      The OSHA 200 log has been replaced by a more user-friendly form called the OSHA 300
      log. It is smaller and easier to fill out. It is effective January 1, 2002. The old OSHA 200
      & 101 forms must be kept on file for 5 years.

      Recordable vs. Not Recordable

      So what make an incident recordable and not recordable. The following are some
      examples of each. In section 9.3.1 you will find a decision tree to help you in making that
      determination and another tree to decide if it was work related. Even if the injury is not
      recordable on the OSHA log, you still must report all worker injuries to our
      insurance carrier within 24 hours. It is a (Company ABC) International Risk
      Management Policy for all companies.

      Examples

      OSHA Recordable- The following are generally considered medical treatment.

         Treatment of infection
         Application of antiseptics during second or subsequent visit to medical personnel
         Second or third degree burns
         Application of sutures/stitches
         Application of steri strips or butterfly dressings
         Removal of foreign bodies from eye
         Removal of foreign bodies from wound
         Use of prescription medication, except single dose
         Use of hot or cold soak therapies during second visit to medical personnel
         Application of hot or cold compresses during second visit to medical personnel
         Cutting away dead skin
         Use of whirlpool therapy during second visit to medical personnel
         Positive X-ray diagnosis
         Admission to hospital

                    Copyright EPL for Residential Inc.                                        168
Not Recordable- The following are generally considered first aid and should not be
recorded if the work related injury does not involve loss of consciousness, restriction of
work or motion, or transfer to another job.

   Application of antiseptics one visit only to medical personnel
   First degree burns
   Application of bandage during any visit to medial personnel
   Elastic bandages during first visit to medical personnel
   Foreign bodies in eye, irrigation removal only
   Non prescription medications and single dose of prescription medication
   Soaking therapy, hot or cold compresses, ointments, heat therapy,
        whirlpool therapy during first visit
   Negative X-ray diagnosis
   Observation of injury during first visit to medical personnel




              Copyright EPL for Residential Inc.                                        169
9.3.1   SUPPORTING DOCUMENTS

        1. OSHA 2203 & 3165
           Employee Right to Know (2203 okay to use, but is being replaced by 3165)

        2.   OSHA 300 LOG              Recordable Injury Log

        3.   OSHA 301                  Supplementary Record Of Injury

        4.   CHART 1                   Recordability determination

        5.   CHART 2                   Work Injury Relationship

        6.   OSHA INFO
             Locations, Phone Numbers & Addresses, States with approved plans

        The OSHA information is available on line at the OSHA website and can be
        ordered from your local OSHA office.

        Note: The OSHA 301 can be substituted with the insurance first
        report of injury as long as it mirrors the 301 content.




              Copyright EPL for Residential Inc.                                   170
9.3 OSHCON: OCCUPATIONAL SAFETY & HEALTH CONSULTATION (NOT
      MANDATORY)

    OSHA provides free consultative services to employers who request their services. They
    basically would come out and assist the Company in identifying and correcting specific
    hazards, want to improve their safety & health programs or need further assistance in
    training and education. The team leaders and safety committees would need to work with
    OSHCON if they request their services.

    Once you call and they come out they will develop a written report on items for the
    employer/Company to correct based on their meeting and inspection. The items will
    come with specific time frames to complete them.

    YOU MUST COMPLETE OR ABATE THE ITEMS ON THE LIST!

    They can give you more time if you request it, but you will eventually have to abate
    everything on that list. Failure to abate will result in fines and they will notify the OSHA
    office in your area to send an inspector out. Also, they will stop giving you additional
    extensions and will give you a final deadline, so do not think you will be able to extend
    the time indefinitely.

    NOTE: As long as you understand the above the consultative services could be of benefit
    to the Company’s. If you feel like you want to have them in there is no problem to do so.
    The Company will still have to utilize the Safety Better practices & Resource Guide to
    implement a Company specific safety program. Having them come out will not preclude
    future inspections. They can still come out and they can still fine the Company’s.

    In section 9.4.1 there is a listing by state on addresses locations and phone numbers. If
    you have questions about this please feel free to contact us at the support Company.




                  Copyright EPL for Residential Inc.                                         171
12   POST INJURY MANAGEMENT

     12.1    Purpose

     It is (Company ABC) Inc. policy to make every effort to return injured workers back to work into
     transitional return to work (TRTW) opportunities. This is not light duty.

     We want to work with the provider and within the doctor’s guidelines to get our valued
     employees back into the work force and eventually back into their jobs. The following guidelines
     and components will assist general managers in accomplishing this task.




                           Copyright EPL for Residential Inc.                                    172
12.2      COMPONENTS

WHY TRTW?

Various insurance and independent studies have shown that the longer employees remain away
from work the longer it takes them to come back to work. TRTW does not mean light duty. It
means we, as a company, want to bring them back per the doctor’s restrictions and eventually try
to get them back to their original jobs. The benefits are clear:

 Improved employee morale. By coming back the worker remains connected to their job and
co-workers.

 Value to the Company. By coming back into a meaningful job they add production and
value. It keeps them as a member of our team.

      TRTW can result in direct savings to indemnity costs.

 Send a clear message that all employees are valued and that “vacations” on workers
compensation will not be tolerated.


How do you use TRTW?

Here are a few key steps in developing an effective TRTW program:

 The medical provider specifies the physical restrictions from the work-related injury or
illness.

 The Company develops a temporary job that will match the restrictions (see attached job
description examples). Consult with your Kemper or State Fund (Monopolistic States)
representative as necessary.

 Try to keep the TRTW job as close to their original job as and if possible. You may want to
have the Kemper or State Fund representative review the job description.

 Explain the job to the employee and address any concerns or issues. Provide the necessary
training and supervise the employee to make sure they stay within their restrictions.

      Follow up with the employee to make sure they are going to therapy, if applicable.

 As restrictions to the worker are lifted, increase the job demands and move them closer to
his/her regular job.

          A major component to TRTW is to review, as a Company, what tasks need to be done.
          You may want to group less demanding tasks from several jobs or you may have a
          special onetime project that can be done without significant effort. Example could be,
          inventory, Company field training, call backs, etc. Every injury and every recovery
          process is unique. You may find it better to develop a Company TRTW job bank, before
          you need it. That way while continue to drive our accidents down, you would already
          have this completed and not have to scramble to put something together. The following
          are some examples of written job descriptions. Each Company in concert with their safety
          team leader should develop specific task to best fit your needs.

                        Copyright EPL for Residential Inc.                                   173
TRTW Job Examples

Office Support

   Accounts receivable calls.

   Calling, solicitation of Tune-Ups and/or IAQ products.

   Follow up on service calls. Consumer satisfaction survey.

Service Technician

   Verbally assist a maintenance or service technician with technical expertise.

   Train maintenance technician in troubleshooting.

   Inventory and safety check of field service vehicles.

   Assist in parts supply, tools for service calls.

Comfort Consultants

   Telephone marketing.

   Assisting other comfort consultants in sales process.

   Assist in marketing campaigns.

Installation Technicians

   Verbal instruction on installation to other Company team members.

   Job site safety check.

   Perform low voltage wiring: Thermostats

   Light duct fabrication

Company/Shop

   Organize work areas.

   Inventory parts management.

   Wash fleet.

These are various job examples and are being made to jog your mind on opportunities at your
Company. When you determine what are some meaningful TRTW jobs at your Company you
will need to expand on these and describe in detail what those duties entail. Place these in file and
you will have them ready to go if needed.



                       Copyright EPL for Residential Inc.                                        174
13.   ACCIDENT REPEATER PROGRAM

      The following information is being provided to assist the Company’s in addressing
      employees who have had more than one injury or accident in a given year. Accidents and
      injuries do not just happen. There are reasons why. Many times it is easier to say the
      person was careless or was not paying attention. Those things may be contributing causes
      but they are not the “Root Cause” of an accident.

             It is important to note that this program MUST be delivered consistently to everyone who
             may be an accident repeater.




                           Copyright EPL for Residential Inc.                                    175
13.1    How to HELP Repeater Employees

Things NOT to do

In the administration of a program like this, there are a considerable number of things,
which must be done. Equally important there are a few things that must be avoided in
order for this to be successful. These are:

 Do not accuse the employee of any wrong doing.
 Do not threaten employee.
 Do not deliver immediate punitive damages (time off, layoff, etc.) to an employee
because he or she was merely involved in an accident.

Administering the Program

The program works as follows:

 First, establish how many accidents a person could have over a given period of time
to be entered into this program-02 per year any type.
 Meet with all employees to explain the purpose and procedures of the Accident
Repeater Program.

Coach & Counsel

Coaching & counseling employees is a good way to determine why the accidents are
occurring and demonstrates concern for our employees. The main object is to express
concern for the overall accident record of the (Company ABC) Inc. and relate that to the
employee injury. Your efforts should be to discuss the situation in the most non-
threatening manner possible. If this is done, you are sure to get the most valid and useful
information possible. A sample outline will follow.

In order for the program to work effectively it must be evenly applied. Criteria for
operation of the program should be in followed and strictly adhered to.

Procedure with Employee

1st Meeting after 2 Accidents    Discuss the Accident Repeater Program, review prior
                                 injuries, and make initial commitments. Follow up
                                 counseling weekly for 1 month. Document.

2nd Meeting after 3 Accidents    Review all accidents, discuss commitments, where
                                 corrections maybe needed, agree on changes. Follow up
                                 counseling weekly for 1 month. Document.

3rd meeting after 4 Accidents Review all accidents and commitments made, adjust
where needed and agree on changes. Express concern for the employee’s ability to do the
job safely. Make it clear that performing work safely is a requirement of the position.




              Copyright EPL for Residential Inc.                                        176
Things to Do

1. The general manager or departmental manager should meet with the repeater. Group
meetings on sensitive subjects make everyone more uncomfortable.

2. Explain purpose of the meeting:

 The company has been experiencing a number of accidents (detail, cost, types of
accidents, etc.)
 It has come to light that a few individuals have been involved in multiple accidents
in a year’s time.
 Your goal, as the general or departmental manager, is to speak with everyone
involved and try to find out why the accidents are occurring and get input from you on
what type of corrective actions might be implemented to prevent them from occurring
again.

3. Discuss each of the employee’s accidents in detail:

 Back in (date) you reported and accident. Can you tell me how it happened? Let the
employee talk and do not interrupt.
 As I understand it, this is how the accident occurred (in your own words repeat what
you understand about the employees accident). Is that correct?
 At this point if there are any discrepancies, clear them up.
 What can the company & Company do to prevent similar accidents?
 What can you do to prevent similar accidents?
 Repeat these steps for each accident.

4. Develop a specific plan with the employee, using your safety business plan technique,
on things that can be done to prevent future occurrence. This also reaffirms commitments
on both sides.

Examples

Company/Company:        Provide necessary personal protective equipment to do job
                        safely.
                        Repair all equipment report as being faulty.

Employee:               Follow all safety rules.
                        Ask for help when needed
                        Report all unsafe acts/conditions

5. The GM or departmental manager should again explain the purpose of the coaching
and counseling session. Have the employee sign the attached confirmation of counseling
form. Also allow the employee to add any comments to the form if they want too.

If employees refuse to sign the form, ask a staff manager as a witness
to sign the form indicating that the employee has been advised of this issue. The form
should be signed by the witness in front of the employees.




               Copyright EPL for Residential Inc.                                        177
                   ACKNOWLEDGEMENT OF COUNSELING


EMPLOYEES NAME:                                                                   DATE:

JOB TITLE:


You have been involved in            on the job accidents over the past twelve-month period. As your
employer we are dedicated to providing our employees with a safe and healthful workplace. In order to
fulfill that obligation, we met with you on the above date to discuss your following accidents:

ACCIDENT DESCRIPTION




As a result of our discussion, we have agreed to the following:

COMPANY                                           EMPLOYEE




A copy of this form will be placed in your file. By signing it, you make no admission of fault for your on
the job accident. This merely acknowledges that we have discussed the issues as noted above.


Employee                                 Date


General or Departmental Manager                                           Date


Witnessed By                                             Date




                              Copyright EPL for Residential Inc.                                       178

				
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