FIELD SERVICE SAFETY & ENVIRONMENTAL POLICY€¦ · and can cause disease in humans. These pathogens include, but are not limited to, the hepatitis B virus (HBV), the hepatitis C

November 9, 2012

GAI-TRONICS

®

FIELD SERVICE

SAFETY &

ENVIRONMENTAL

POLICY

2

TABLE OF CONTENTS

Page

Ground Assurance & Ground Fault Circuit Interrupters……………… 5

Bloodborne Pathogens Exposure Control Plan………………………… 6

Hand & Power Tool Procedures …………………………………………… 8

Fall Protection Program…………………………………………….………. 9

First Aid Procedures………………………………………………………… 10

Hearing Conservation……………………………………………………….. 11

Driving Safety…………………………………………………………………. 12

Hazard Communications…………………………………………….……… 15

Ladder Safety………………………………………………………….……… 17

Lockout Tagout / Control of Hazardous Energy………………...……… 18

Personal Protective Equipment / Assessments (PPE)………….…….. 21

Process Safety Management (PSM)………………………………...…….. 23

Waste Management Plan…………………………………………….……… 25

Emergency Action Plan……………………………………………...……… 26

Electrical Safety……………………………………………………….……… 43

Incident Reporting and Investigation Procedure……………….……… 49

Heat Related Illness Prevention…………………………………………… 51

Fatigue Management………………………………………………………… 55

Stop Work Authority………………………………………………….……… 80

Alcohol and Drug Policy…………………………………………….……… 82

Fitness for Duty Policy……………………………………………………… 87

Short Service Employee Mentoring Program…………………………… 92

Technician Off-Shore Certification Requirements……………...……… 94

Service Organization Skill Compensation Plan………………………… 99

Disciplinary Program………………………………………………………… 104

Access to Medical Records………………………………………………… 106

Injury/Illness Recordkeeping……………………………………….……… 108

Hazard Identification and Risk Assessment………………………..…… 110

Behavioral Based Safety Program……...………………………...………. 116

Attachment A – Writing S.M.A.R.T. Expectations……...…………… 121

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Management of Change……………………………………………..……… 124

Attachment A – Guide for Originating an ECN……………………… 127

Attachment B – HCN Procedure and HCN Form…………….……… 140

Attachment C – PCN Procedure and PCN Form…………….……… 143

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Revisions

Date Revision Initials

5/10/2013 Updated Drug & Alcohol Policy

KLA

7/2/2013 Updated PPE Policy KLA

11/5/2013 Updated PPE Policy KLA

11/22/2013 Updated Drug & Alcohol Policy

KLA

7/10/2014 Updated JSA Form KLA

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Ground Assurance & Ground Fault Circuit Interrupters

1.0 Definition

The ground fault circuit interrupter is a fast-acting circuit breaker which senses small imbalances in the circuit caused by current leakage to ground and, in a fraction of a second, shuts off the electricity. The GFCI continually matches the amount of current going to an electrical device against the amount of current returning from the device along the electrical path. Whenever the amount "going" differs from the amount "returning" by approximately 5 milliamps, the GFCI interrupts the electric power within as little as one-fortieth of a second.

The GFCI will not protect a person from line-to-line contact hazards, such as a person holding two "hot" wires, or a hot and a neutral wire in each hand. It does provide protection against the most common form of electrical shock hazard, the ground fault. It also protects against fires, overheating and destruction of insulation on wiring. 2.0 Work Procedures

Prior to the start of work: inspect all portable equipment and extension cords to ensure that all ground conductors are in place and in good condition. Also check all cords for any damage to insulation.

A GFCI must be used when ever portable equipment is used. The test button on the GFCI must be tested at least monthly.

Any damaged GFCI, cords or equipment must be taken out of service until repaired or replaced, and reported to the Field Service Manager. 3.0 Training

All field personnel are trained during the new employee safety orientation and annually in the GFCI use and equipment inspection procedures.

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Bloodborne Pathogens Exposure Control Plan

1.0 Definition

Bloodborne pathogens are pathogenic microorganisms that are present in

human blood and other to a lesser extent other body fluids (saliva, vomit, etc…), and can cause disease in humans. These pathogens include, but are not limited to, the hepatitis B virus (HBV), the hepatitis C virus (HCV), and the human immunodeficiency virus (HIV). 2.0 Job Functions & Classifications

Job Functions impacted by potential exposures include Field Service Technicians, Field Engineers, and Associate Field Engineers.

Job Classifications or tasks in which occupational exposure could occur include First Aid trained employees and others rendering first aid.

Exposure determination is made without regard of personal protective equipment. 3.0 Work Practice Controls

Safe work practices must always be used to minimize the risk of injury on the job site. This includes using appropriate personnel protective equipment (PPE) and following all policies and procedures. Required PPE includes safety glasses and latex or nitrile gloves. PPE is provided to employees by GAI-Tronics at no cost to the employee.

Any blood soaked materials including bandages, gauze, etc. must be placed in leak proof bags/containers for handling, storage and transportation.

Any injury to Field Service personnel that results in blood or body fluid contamination of equipment, environmental surfaces, or other customer property must be reported immediately to the project coordinator (customer site contact). Clean up activity of contamination must be coordinated with the project coordinator.

All clean up activity must be conducted by trained personnel. All personnel involved in the clean-up of Bloodborne Pathogen must follow universal precaution and wear safety glasses and latex or nitrile gloves.

Any blood soaked materials including bandages must be disposed of in accordance with the local plant policies and procedures. Field Service personnel must coordinate with the plant personnel.

Antiseptic hand cleaner is issued to each Field Service employee.

An incident report must be completed by a GAI-Tronics supervisor or manager within two hours of the incident.

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4.0 Training

All field service personnel are trained during the new employee safety orientation and annually in universal precautions and Bloodborne Pathogens clean up procedures.

A copy of this policy/procedure is provided to each Field Service employee. 5.0 Vaccinations & Medical Records

Hepatitis B vaccines are made available to all First Aid trained employees. The vaccines are provided at no cost to the employee.

All employee medical and training records are maintained the by the Human Resources department in accordance with OSHA 29 CFR 1910.1020(h) requirements. Medical records are available for review by the employee and by the Assistant Secretary & Director for examination and copying. Medical records must have written consent of the employee before release.

Medical records are maintained for a minimum of employment plus 30 years. Training records are maintained for a minimum of 3 years.

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Hand & Power Tool Procedures

1.0 Typical Field Service Tools

Tools used by Field Service personnel are limited to small hand tools and electronic instrumentation.

All tools and instrumentation must be maintained and used in a safe manner. 2.0 Guarding and Other Safe Guards

All safe guards and guarding must be used in accordance with manufacturers specifications. Personal protective equipment including work gloves and eye protection must be worn when appropriate. 3.0 Damage

Any damaged or defective tools or instrumentation must be taken out of service until repaired or replaced.

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Fall Protection Program

1.0 Procedures

Fall protection is required when ever personnel are working at a height of 6 feet or higher. This includes working near or around excavations. Guard rails, safety nets or personal fail arrest systems should be used whenever possible.

Specific site plans and safety monitoring are not warranted because controlled access zones are not utilized.

All accidents and serious incidents (near accidents/misses) are investigated and changes to the fall protection program are implemented when necessary.

All fall protection equipment meets the requirements of applicable ANSI, ASTM, or OSHA requirements. 2.0 Rescue

Prompt rescue of an employee in the event of a fall is addressed with site personnel when ever fall protection is required. 3.0 Training

Training is required for all new employees. Topics include recognition of fall hazards and how to minimize these hazards. All training is documented including the date of training, names & signatures of personnel trained.

Retraining will occur when:

1. Deficiencies in training are identified.

2. Work place conditions change.

3. Fall protection systems or equipment changes render previous training obsolete

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First Aid Procedures

1.0 Minor Injuries

All Field Service personnel have access to First Aid kits in the company service vans. First Aid will be self administered for minor injuries. Special attention must be given to clean any injury to reduce the risk of infection. First Aid kits include basic materials appropriate for minor injuries including bandages, gauze, antiseptic wipes, first aid cream, and eye wash.

Any foreign matter or chemicals that splash into the eyes must be flushed out immediately using the eye wash solution or a job site eye wash station.

First Aid kits are inspected weekly and prior to each new job assignment to replenish missing materials.

The contents of the first aid kits are periodically assessed to ensure availability of adequate supplies. 2.0 Other Injuries

In the absence of medical assistance that is reasonably accessible in terms of time and distance to the worksite, each technician shall have a valid certificate in first aid and shall be available at the worksite to self-administer first aid.

Any injury beyond the employee’s capabilities will be treated by the customer’s First Aid team. 3.0 Advanced Care

Injuries or illnesses of a serious or potentially life threatening nature will also require local emergency medical services for treatment and transport to a local hospital/advanced care facility.

Air Medical Services requirements are reviewed on a job by job basis. 4.0 Incident Report

An incident report must be completed by a GAI-Tronics supervisor or manager within two hours of the incident. 5.0 Additional Requirements

All Field Service technicians will complete training and obtain a valid certificate in First Aid and CPR from the American Red Cross or the American Heart Association that can be verified by documentary evidence.

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Hearing Conservation

1.0 Definition

A Hearing Conservation program is required by OSHA 1910.95 when an employee is exposed to 85dbA or greater. 2.0 Procedures

Field Service personnel will determine hearing protection requirements during the on-site safety briefing. Personnel will comply with hearing protection requirements when required by the customer and detailed in the customer’s hearing conservation program. Hearing protection devices are issued to all field personnel at no cost to the employee.

3.0 Training

All Field Service personnel are trained during the new employee safety orientation and annually in the correct use, care and fitting of hearing protective PPE.

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Driving Safety

1.0 Purpose

This program is written to provide directives to managers, supervisors, and employees of GAI-Tronics Corporation about their responsibilities in the operations and management of GAI-Tronics Corporation vehicle safety. 2.0 Key Responsibilities

GAI-Tronics Corporation Safety Manager

The designated Safety Manager is responsible for developing and maintaining the program and related procedures. These procedures are kept in the designated safety manager’s office.

Service Managers

The Service Managers are responsible for the implementation and maintenance of the program for their site and ensuring all assets are made available for compliance with the plan.

Employees

All shall be familiar with this procedure and the local workplace vehicle safety program.

Follow all requirements, report unsafe conditions, and follow all posted requirements.

3.0 Vehicle-Related Driving Safety

Operators of GAI-Tronics Corporation vehicles shall be qualified by possession of a valid, current driver’s license for the type of vehicle being driven. Only authorized employees will drive a motor vehicle in the course and scope of work or operate a GAI-Tronics Corporation-owned vehicle. Drivers shall have 3 years of driving experience on the vehicle he/she is licensed to drive & regularly drives. Drivers will be appropriately assessed, licensed and trained to operate the vehicle they have been authorized to operate. Passenger compartments are to be free from loose objects that might endanger passengers in the event of an incident. Signs, stickers or labels are to be fitted in such a manner that they do not obstruct the driver's vision or impede the driver's use of any controls.

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4.0 Safe Driving Practices

Employees driving vehicles are required to follow safe driving practices: • Obey all federal and local driving laws or regulations as well as

requirements of clients;

• Immediately report any citation, warning, traffic violation, collision, vehicle damage or near miss associated with a GAI-Tronics Corporation vehicle operation to the supervisor;

• Immediately report any restriction or change to their driving privileges to the supervisor.

• Seat belts shall always be worn by all occupants whenever the vehicle is in motion; only seats fitted with three-point inertia-reel type seatbelts shall be used. All vehicles capable of more than 10 mph shall have seat belts installed.

• Defensive drivers continually assess conditions and hazards and remain prepared for any challenge that may approach them;

• When speaking with a passenger, always keep your eyes on the road;

• Both hands on the wheel;

• No use of cell phones, radios or other electronic devices while driving any vehicle - vehicle must be safely parked prior to using a mobile phone or 2-way radio.

• Slow down around construction, large vehicles, wildlife, fog, rain, snow, or anything else that adds a hazard to your driving;

• Drive for conditions, not just the speed limit;

• Alcohol or illegal drugs are not allowed to be in a GAI-Tronics Corporation, rented or leased vehicle at any time;

• Drivers shall not operate a motor vehicle while under the influence of alcohol, illegal drugs, or prescription or over-the counter medications that might impair their driving skills.

• Drivers are to be prepared before leaving:

• Perform 360 walk around – report new damage;

• Check windshield for cracks that could interfere with vision;

• Inspect for vehicle damage and immediately report any damage to the supervisor if not previously observed;

• Make sure dirt or snow is removed from lights on all sides of the vehicle;

• Brush or clean off snow or ice on all windows to ensure complete vision;

• Check fuel level to be certain the destination can be reached;

• Check to ensure the license plates and inspection tag on vehicle are current;

• Ensure that there is a first aid kit and inspected fire extinguisher in the GAI-Tronics Corporation vehicle;

• Ensure driver is rested and alert for driving;

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Employees are not to perform repairs or maintenance other than routine fluid additions. 5.0 Vehicle Requirements

• All vehicles shall be fit for the purpose, and shall be maintained in safe

working order.

• Tires, including spares if full size, are to be of same type, profile and tread

pattern, except when the vehicle or tire Manufacturer recommends a

different type for certain axles.

• Tire type and pattern is to be recommended by the vehicle or tire

manufacturer for use on the vehicle in the area of operation.

• Vehicles are to be fitted with a spare wheel and changing equipment to

safely change a wheel, or a suitable alternative.

• Vehicles longer than 20 feet or with restricted rear view (i.e. pickup trucks

that are fully loaded) are to be fitted with an audible reversing alarm.

• All seats are to be fitted with headrests.

• All light duty vehicles are to be equipped with adjustable left, right and

central rear view mirrors.

• All vehicles are to be equipped with a multipurpose fire extinguisher. The

fire extinguisher shall be securely mounted on a bracket and located so

that it is easily accessible in an emergency without becoming a hazard in

case of an incident.

• All light vehicles shall be equipped with a securely stowed first aid kit.

• All light duty vehicles carry a minimum of one collapsible hazard warning

triangle.

• All loads shall be secured and shall not exceed the manufacturer’s

specifications and legal limits for the vehicle.

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Hazard Communications

1.0 Background

Hazardous chemicals can have various hazards. To protect employees, these hazards most be known to the personnel working with chemicals in the workplace and on the job site.

Material Safety Data Sheets (MSDS) are on file for all chemicals in the workplace and used on job sites. MSDS’s are obtained from chemical manufacturers and distributors prior to ordering new hazardous materials and when new revisions are available. MSDS are filed in the MSDS binders in the main production area and on the local area network.

All employees speak and understand English. 2.0 Procedures

Any container used to store chemicals must be labeled using the Hazardous Materials Information System (HMIS) labeling system. The labels include the material name, address of the manufacturer, hazard rating including- Health rating (0-4), Flammability rating (0-4), Reactivity rating (0-4) and the manufacturer’s personal protective equipment recommendation.

Labels must remain legible and may not be defaced or removed. Any labels that are illegible must be replaced immediately.

Non-routine tasks must be evaluated prior to beginning the task to determine special hazards and precautions to conduct the task safely.

While at multi-employee facilities, personnel must inform the project coordinator of the hazardous materials being brought on site. A copy of the MSDS must be available for each hazardous material. Personnel must also discuss hazardous materials already on site with the project coordinator. 3.0 Training

All employees are trained to be aware of the hazards of chemicals and how to safely work with chemicals. Training is conducted at the time of hire and annually thereafter.

Training content includes:

1. Requirements of the program.

2. Any operations in their work area where hazardous chemicals are present.

3. Location of written hazard communication program, listing of hazardous chemicals present & MSDS.

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4. Methods & observations that may be used to detect the presence or release of hazardous by use of monitoring, visual appearance or odor.

5. The physical & health hazards of chemicals in the work area.

6. Protection measures to be utilized to prevent exposure, appropriate work practices, emergency procedures & proper PPE to be used.

7. Details of the hazard communication program, explanation of the labeling system and the MSDS and how employees can obtain & use appropriate hazard information.

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Ladder Safety

1.0 Background

Safe ladder use is vital to avoid serious injury.

All ladders must meet OSHA/ANSI standards. 2.0 Procedures

Prior to use, each ladder must be visually inspected to look for defects and dirt that may impede use. Dirty ladders must be cleaned prior to use. Any ladder with a defect must be taken out of service and tagged until it is repaired or replaced.

The following key safety practices must be followed while using portable ladders:

Must be placed on a stable, level surface

The top two rungs may not be used - or the top step on step ladders

Tools and parts must be placed in a tool bag or bucket

Always face the ladder while ascending, descending and working on a ladder

Extension ladders must extend 3’ beyond the landing surface

Extension ladders must be placed at a 4:1 ratio

Ladders may not be loaded beyond the manufacturer’s rated capacity

Ladders may only be used for their intended purpose 3.0 Training

All employees are trained in safe ladder use. Training is conducted at the time of hire and annually thereafter.

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Lockout Tagout / Control of Hazardous Energy

1.0 Purpose

This procedure establishes the minimum requirements for the lockout or tagout of energy isolating devices. It shall be used to ensure that the machine or equipment are isolated from all potentially hazardous energy, and locked out or tagged out before employees perform any servicing or maintenance activities where the unexpected energizing, start-up or release of stored energy could cause injury. These energy sources could be electric or compressed air and will be identified in this procedure.

Equipment specific procedures are located in the GAI-Tronics Maintenance system and a hard copy of the specific procedures is affixed to each machine. 2.0 Responsibility

Field Service authorized employees shall be instructed in the safety significance of the lockout-tagout procedure including:

Each new or transferred affected employee and other employees whose work operations are or may be in the area shall be instructed in the purpose and use of the lockout-tagout procedure.

All employees are required to comply with the restrictions and limitations imposed upon them during the use of lockout tagout. Authorized employees are required to lockout tagout appropriate equipment in accordance with this policy. All employees, after observing a piece of equipment which is locked out or tagged out, shall not attempt to start, energize or use that piece of equipment.

Each lockout and tagout device must include the name of the individual placing the device. 3.0 Preparation for Lockout or Tagout

Make a survey to locate and identify all isolating devises to be certain which switch(s), valve(s) or other energy isolating devices apply to the equipment to be locked or tagged out. More than one energy sources may be involved. See the attachment for a list of equipment within the facility and energy source(s). Equipment not included in lists is sent out for repair rather than being serviced by in-house personnel. 4.0 Sequence of Lockout or Tagout System Procedures

The following procedures provide the general sequence to follow to effectively isolate & control energy on equipment. Specific machine procedures are available in the maintenance management system.

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1. Notify all affected employees that a lockout and tagout system is going to be utilized and the reason therefore. The authorized employee shall know the type and magnitude of energy that the machine or equipment utilizes and shall understand the hazards thereof.

2. If the machine or equipment is operating, shut it down by the normal stopping procedure (depress the stop button, open toggle switch, etc.)

3. Operate the switch, valve, or other energy isolating device(s) so that the equipment is isolated from its energy source(s). Stored energy (such as that in springs, elevated machine members, rotating flywheels, hydraulic system, air, gas, steam, or water pressure etc., must be dissipated or restrained by methods such as repositioning, blocking, bleeding down, etc.

4. Lockout tagout the energy isolating devices with assigned individual lock(s) and tag(s). Whenever possible, both lockout and tagout should be utilized. Tagout alone will only be used when no method of lockout is available. Method(s) selected will include: locks, tags, additional safety devices, etc.

5. After ensuring that no personnel are exposed, and checking that all energy sources are disconnected, operate the push button or other normal operating controls to make certain the equipment will not operate. Caution: Return operating control(s) to “Neutral” or “Off” position after the test.

6. Return operating control(s) to "Neutral" or "Off" position after the test. The equipment is now locked out or tagged out.

5.0 Restoring Machines or Equipment to Normal Production

1. After the servicing and/or maintenance is complete and equipment is ready of normal production operations, check the area around the machines or equipment to ensure that no one is exposed.

2. After all tools have been removed from the machine equipment, guards have been reinstalled and employees are in the clear, remove all lockout or tagout devices, Operate the energy isolating devices to restore energy to the machine or equipment.

6.0 Procedure Involving More Than One Person

In the preceding steps, if more than one individual is required to lockout and tagout the equipment, each individual shall place his/her own personal lockout device and tagout tag on the energy isolating device(s). When an energy isolating device cannot accept multiple locks or tags, a multiple lockout or tagout device can be used. The employees at GAI-Tronics authorized for group lockout and tagout are John Giffin - Maintenance Foreman and Carl Neatock - Maintenance Mechanic II.

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7.0 Procedures Involving Contractors

In the event a contractor is utilized to perform work on company equipment, the contractor shall provide their own lockout and tagout devices. Company maintenance personnel will coordinate the procedure with the contractor to ensure that all appropriate safety precautions are taken. 8.0 Removal of Devices by Employer

Lockout tagout devices are normally removed by the installing authorized employee. In the event the authorized employee is not available, the company may remove the device after the following conditions have been met. Confirm that all required work is completed on the equipment. The company must verify that the authorized employee is not in the facility and must make reasonable efforts to notify the employee that the device is being removed. The company must notify the authorized employee upon his return to the facility. 9.0 Training

All new affected employees will be provided lockout tagout training during the Safety Orientation. Authorized employees will receive initial training prior to their use of the lockout tagout procedure. Retraining will be conducted annually and when there is a change in job assignments, in machines, a change in the energy control procedures or a new hazard is introduced.

All training and/or retraining is documented, signed and certified. 10.0 Inspection of Procedure

At least annually, the lockout tagout devices, procedures and the program will be inspected. Appropriate updates will be made as necessary. Program revisions will be approved by the Safety & Environmental Committee.

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Personal Protective Equipment / Assessments (PPE)

1.0 Background

Personal Protective Equipment includes safety glasses, safety shoes, hard hats, gloves, hearing protection and other items designed to protect the wearer from hazards that may be encountered in the workplace.

Whenever possible, engineering controls and administrative controls must be used to control or eliminate workplace hazards. A written and signed Job Safety Analysis (JSA) should be conducted prior to the start of any new work activity. The JSA will detail the hazard assessment and list what hazard controls must be put into place and what, if any, PPE is required. Field Service personnel are responsible for determining what equipment must be taken with them when visiting work sites and must comply with said safety regulations. 2.0 Procedures

PPE, including safety eye wear that comply with ANSI Z87.1+, gloves, hard hat, hearing protection, safety harness, respirator (if necessary), and fire retardant clothing are provided to each affected employee when hired and replaced as needed to no cost to the employee. Where appropriate, a variety of sizes of PPE are available to properly fit the employee. Safety shoes that comply with ANSI Z41-1991 as required by OSHA (29 CFR 1910.132) are purchased by the employee and the employee is reimbursed up to the annual maximum amount.

All PPE will be tested by the employee prior to being used on a job site.

If, while on a job site, an employee detects breakthrough or resistance on their PPE, they must leave the area to further examine and correct the issue. Correcting the issue may involve, but is not limited to, washing the unit, changing the cartridge, or replacing the defective PPE.

All PPE will be properly stored and inspected. It is the employee’s responsibility to use and maintain the PPE in sanitary and reliable condition. Any PPE that is damaged, defective or can’t be cleaned must be replaced prior to return to the job site.

The department manager will inspect respirators monthly. 2.1 Respirators Respiratory equipment will be provided to all employees that may be exposed to harmful vapors and oxygen deficient atmospheres. All respirators will be NIOSH certified. If a respirator is necessary, it will be selected based on the hazards that the employee might be exposed to, and will be tested by the employee prior to being used on the job site. Testing will include checking that the face piece fits

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securely to the employee's face without any breaks in the seal. Employees will not be permitted to wear any tight-fitting face piece if the seal is broken due to facial hair, glasses, etc. All medical evaluations prior to fit-testing will be kept confidential, will be performed during normal working hours, will be convenient and understandable, and the employee will be given the chance to discuss the results with a physician or other licensed health care professional. Working in IDLH atmospheres is not permissible. 3.0 Training

All employees are trained in the correct use, care, maintenance and disposal of PPE. Training is conducted at the time of hire and annually thereafter. Retraining will also occur if there is any indication that the employee is not using the PPE properly or is not following the PPE procedures.

Training records are documented and maintained by the Human Resources Manager. The Safety and Facilities Manager will be responsible for administration of this program.

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Process Safety Management (PSM)

1.0 Background

The purpose of process safety management is to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable or explosive chemicals. 2.0 Procedures

All known hazards must be discussed with the site project coordinator. This includes any hazards that may be introduced by the GAI-Tronics personnel and hazards that already exist at the job site. GAI-Tronics personnel shall advise the site employer of any unique hazards presented by the contractor employer’s work, or of any hazards found by the contract employer’s work.

Hazards introduced during work activity may include:

Blocking of aisles and walk ways to work on communications equipment.

Shock hazards if high voltages must be exposed.

Disruption of communications equipment.

These hazards will be minimized or eliminated by following all site safe work practices and by placing warning barriers/cones in the work area, following the Lock Out Tag Out procedures, and by utilizing back up communications procedures.

Employees may not and will not enter confined spaces, conduct hot work, or conduct work on process equipment, piping or controls. Hot work may not be conducted unless a hot work permit is obtained which meets the provisions of OSHA 29 CFR 1910.252(a) from the site employer.

All accidents, injuries, and near misses must be reported immediately to the site coordinator and the GAI-Tronics manager. Site personnel will conduct an incident investigation within 48 hours and the employee’s manager will complete an accident report within two hours of notification.

All trade secret process, product and any other work site details must be considered confidential and may not be discussed with anyone outside of the plant. 3.0 Training

All employees are trained in the work practices to safely perform their jobs.

Training comprehension is verified by various means including where appropriate:

Quizzes and tests

Employee participation during training

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Job monitoring by the department manager

Training records, including the date of the training, employee name, and any quizzes and signed employee training documents are maintained by the Human Resources Manager.

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Waste Management Plan

1.0 Field Locations/Job Sites

Potential project wastes, trash, and/or scrap materials will be taken into consideration before work begins; however, all materials that are brought to a job site return with the service technician as the quantities and volume are always negligible. There are no hazardous materials brought to any job sites.

2.0 Field Service Facility

Hazardous Wastes including aerosol cans and obsolete or outdated chemicals are shipped and treated by a hazardous waste vendor in accordance with all applicable laws and regulations.

Universal wastes including fluorescent lamps are recycled by a universal waste processing company in accordance with all applicable laws and regulations.

E-Waste including computers, printed circuit boards, and used electronics equipment is recycled.

General trash is collected and picked up on a regular schedule by a municipal trash hauler.

All wastes are segregated by waste type in designated labeled containers to ensure proper handling, storage, and disposal.

3.0 Sustainability

GAI-Tronics Corporation actively seeks opportunities to reduce, reuse, and recycle materials. Examples include reuse of packaging materials and recycling of metals, lamps, and other materials in our efforts to minimize potential impact to the environment.

4.0 Training

All field personnel are trained in the waste management program, including but not limited to the proper method to dispose of wastes, during the new employee safety orientation, whenever there is a change in the program, and annually.

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Emergency Action Plan

Business Continuation Plan

GAI-Tronics Corporation

New Orleans Service Center

125 Mallard St. Suite F St. Rose, LA 70087

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Contents Page

Contents Listing

Section 1: Purpose

Additional Actions

2

3

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Section 2: Fire

Evacuation Plan/Floor Plan & Fire Extinguisher Layout

Section 3: Building Evacuation

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Section 4: Weather Related Facility Closing

Section 5: Workplace Violence

Section 6: Power Outage

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Section 7: Telephone Service Disruption

Section 8: Water/Sewer Service Disruption

Section 9: Gas Service Disruption

GTC Personnel Contact Information

Business Continuation Resource Listing

Note page

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July 2012 - 2 –

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Section 1: Purpose

These procedures outline a planned method of evacuation and actions in the event of an emergency situation at the St. Rose facility.

The overriding rule when considering any action in the case of an emergency is to protect the health and welfare of all personnel. Any other considerations are secondary to this objective.

It is not GAI-Tronics’ policy to ask employees to remain and attempt to control the situation, rather our policy is to immediately evacuate the building.

The following outlined actions are to be taken by the facility manager, Robert Lizarraga, or the person in charge if Robert is off site or unavailable.

This procedure applies to:

GAI-Tronics Corp.

New Orleans Service Center

125 Mallard St. Suite F

St. Rose, LA 70087

800-452-7666

504-466-1666

The following personnel are required to be familiar with this procedure

_____________________________________ Date: ____________

Robert Lizarraga, Technical Service / Facility Manager

_____________________________________ Date: ____________

John Chauvin, Regional Sales Manager

____________________________________ Date: ____________

Michael D. Wolfe, National Service Team Manager

_____________________________________ Date: ____________

Charles M. Zechman III, Safety and Facilities Manager July 2012 - 3 -

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Additional Actions to be taken:

Each July the Facility Manager will insure:

There is a formal review of the Emergency Evacuation and Business Continuation Plans.

o Update as needed.

An evacuation drill is conducted at least once during each calendar year.

o A record is to be kept of the dates these are done

o The record (this page) is forwarded to Chuck Zechman after every drill.

Year Evacuation Drill Date Conducted by Issues/concerns

2012 _______________________________________________________

2013_________________________________________________________

2014_________________________________________________________

2015_________________________________________________________

2016_________________________________________________________

2017_________________________________________________________

2018_________________________________________________________

2019_________________________________________________________

2020_________________________________________________________

2021_________________________________________________________

2022_________________________________________________________

Immediately following the use of any of the following emergency plans a review of the plan should be done and improvement revisions made as needed.

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Section 2: Fire In the event of a fire, the employee who first notices the fire will immediately notify the

Facility Manager, Robert Lizarraga, or the person in charge if Robert is unavailable.

Additionally, the following steps are to be taken:

- Evacuate the building.

- Call 911 to report the emergency and location.

- After exiting the building, all employees will assemble at the predetermined meeting location in the front parking lot to allow verification of a total evacuation.

- The person in charge will account for all employees (and visitors if any) to make sure no one is still in the building.

- Notify Robert Lizarraga of the emergency if he is not on site – xxx-xxx-xxxx

- Notify the Sealy Sr. Property Manager of the emergency:

Jolie Bunol – xxx-xxx-xxxx

- Notify both of the following Mohnton management members:

Chuck Zechman - xxx-xxx-xxxx

Mike Wolfe – xxx-xxx-xxxx

- In no case should any employee re-enter the building to search for missing personnel.

- The person in charge will provide emergency response personnel the following information:

Details of any missing personnel and their probable location.

Status & location of the fire or source.

The existence and location of the propane storage rack.

A diagram of the facility.

The location of the MSDS sheets for the facility.

- Await further instructions from the emergency response personnel.

NOTE 1: See “Section 3: Building Evacuation” for additional information

Immediately following the use of this emergency plan a review of the plan should be done and improvement revisions made as needed.

NOTE: The Evacuation Plan below is posted throughout the facility and should be annually reviewed and updated as needed.

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Section 3: Building Evacuation

The Facility Manager, Robert Lizarraga, or the person in charge if Robert is unavailable,

will follow and strictly adhere to the following in the event of a building evacuation:

- The Facility Manager will instruct all personnel to evacuate the building.

- Proceed to the nearest safe exit. Exit the building in a quiet, orderly fashion.

- If possible on the way out of the building close all private office doors.

- Exterior doors are to remain unlocked to ease entrance of the first responding emergency personnel.

- Leave lights on so people can see to safely exit the building.

- After exiting the building, all employees will assemble at the predetermined meeting location in the front parking lot to allow verification of a total evacuation.

- The person in charge will account for all employees (and visitors if any) to make sure no one is still in the building.

- Employees must remain away from the building and any responding emergency equipment and personnel.

- They may not enter or move their automobiles unless instructed to do so.

- The Evacuation Coordinator will provide emergency response personnel the following information:

Details of any missing personnel and their probable location.

Status & location of the emergency.

The existence and location of the propane storage rack.

A diagram of the facility with potentially dangerous areas noted.

The location of the MSDS sheets for the facility.

- Await further instructions from the emergency response personnel.

- Notify both of the following Mohnton management members to report status:

Mike Wolfe – xxx-xxx-xxxx Chuck Zechman - xxx-xxx-xxxx


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Section 4: Weather Related Facility Closing: The Facility Manager, Robert Lizarraga, or the person in charge if Robert is unavailable, will determine if and when a facility closing is necessary during normal working hours and in the best interest for the safety of the employees.

If the facility will be closing/closed due to weather conditions the following steps are to be taken:

- Notify both of the following Mohnton management members:

Mike Wolfe – xxx-xxx-xxxx Chuck Zechman - xxx-xxx-xxxx

- Insure that all St. Rose facility employees (working on or off site) are notified of the facility closing.

- Insure the facility has been properly prepared for the closing (if possible) by:

1. Setting the thermostats to the “off” setting.

2. Insure all lighting has been turned off.

3. Facility water supply in rest rooms and kitchen should be turned off at the tank valves to reduce the risk of flood damage and/or from frozen pipes.

4. Place all service vehicles in the warehouse to prevent damage.

5. Move all items of value from windows.

- If it has been determined that a delayed facility opening is necessary Robert Lizarraga or the person in charge if Robert is off site or unavailable will insure that all employees have been advised of the delay.

- All employees are to be kept updated appropriately if the closure becomes a long term situation.


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Section 5: Workplace Violence Workplace Violence Risks includes:

Threats from employees, former employees, spouses, etc…

Verbal or written threats

Layoffs/terminations

Disciplinary action Potential steps to take:

Contact 911 if there is a potential for immediate violence.

Review details of violence potential.

Communicate with all of the following Mohnton management members:


Chuck Zechman – xxx-xxx-xxxx

Michele Hart – xxx-xxx-xxxx

Obtain copies of any court orders when applicable.

Review information with local Police.

Determine if additional security measures are required. If violence has already occurred:

Call 911 for Police and EMS as appropriate.

Contact First Aid team personnel if appropriate.

Evacuate employees from potential harm.

Keep bystanders away from the area.

Do not touch anything without Police approval.

Communicate with all of the following Mohnton management members:


Chuck Zechman – xxx-xxx-xxxx

Michele Hart – xxx-xxx-xxxx

Schedule Employee Assistance Plan for counseling (HR support).

Contact Michele Hart at xxx-xxx-xxxx Resources:

Police & EMS

First Aid Team

GTC Mohnton facility staff members

Employee Assistance Program xxx-xxx-xxxx (Magellan Health Services)


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Section 6: Power Outage

Background: Power outages constitute a significant risk due to the wide range of potential causes. Power outages can occur due to natural disasters such as the high winds associated with hurricanes and tornadoes, thunder storms, ice storms, earthquakes and floods, and outages can also occur from manmade disasters such as fires, car accidents, plant equipment failure and utility failure. Therefore, preparations must be made to limit the impact of a power outage. The following procedures will be used as a guide. However; specific circumstances may dictate additional actions.

Resources: Battery powered emergency lighting, emergency exit lighting, flash lights and cell phones.

During Service Disruption:

The facility manager, Robert Lizarraga, or the person in charge if Robert is off site or unavailable will:

Switch off high electrical demand equipment or equipment that could be damaged by a power surge including HVAC equipment, PC and printer equipment. Appropriate breaker panels are marked to indicate which breakers must be shut down during an outage.

Contact GTC Mohnton Service (Mike Wolfe @ xxx-xxx-xxxx) to notify him of the outage.

Contact the utility company, Entergy xxx-xxx-xxxx during the outage. The utility company should be questioned as to the cause of the outage, the geographic area of the outage and the expected duration. Maintain additional contact for further updates if needed.

Make the decision to close the facility on a case by case basis.

After service is restored:

The facility manager, Robert Lizarraga, or the person in charge if Robert is off site or unavailable will:

Power up equipment systematically.

Verify equipment is functioning properly.

Contact GTC Mohnton Service (Mike Wolfe @ xxx-xxx-xxxx) to report power restoration.

Contact employees as necessary.


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Section 7: Telephone Service Disruption

The facility manager, Robert Lizarraga, or the person in charge if Robert is off site or unavailable, will take the following steps as needed:

Methods to Determine Telephone Service Disruption:

Notification by plant personnel.

Call into a direct dial number and the toll free number to determine if they are operational.

Visit facility and check telephone service (dial tone) functionality.


Contact GTC Mohnton Service (Mike Wolfe @ xxx-xxx-xxxx) to notify him of the outage.

For PBX support contact Guywire xxx-xxx-xxxx the local tech service, to report the trouble and perform the repairs.

For line, hardware and internet issues contact the Hubbell Service Desk (xxx-xxx-xxxx) to report the trouble. Follow instruction if the Service desk advises to contact the local provider.

Contact Terry Olsen xxx-xxx-xxxx at Hubbell Power System in Centralia, MO if AT&T cannot resolve the service disruption.

Use cell phones to maintain contact with employees, GTC Mohnton, customers and any other pertinent contacts as deemed necessary.

Maintain contact with service providers if possible to determine schedule to restore service.


Contact GTC Mohnton Service (Mike Wolfe @ xxx-xxx-xxxx) to report service restoration.



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Section 8: Water/Sewer Service Disruption

The facility manager, Robert Lizarraga, or the person in charge if Robert

is off site or unavailable will take the following steps as needed:

Methods to Determine Water/Sewer Service Disruption:

Notification by plant personnel. (during business hours)

Notification by local radio station broadcast.

Visit facility and check functionality of restrooms and other facilities.


Contact Sealy & Company to report the outage.

Water – Sealy & Company Sr. Property Manager xxx-xxx-xxxx

Sewer – Sealy & Company Sr. Property Manager xxx-xxx-xxxx

The utility provider should be questioned as to the cause of the outage, the geographic area of the outage and the expected duration.

Maintain contact with service provider if possible to determine schedule to restore service.

Monitor local radio stations for additional information such as a “boil water” notice, etc.

Block off restrooms and sinks to prevent use.

If the outage is going to be long term strive to make alternate facility arrangements.

Purchase disposable hand cleaner/sanitizer and hand wipes as needed.


Verify restrooms and other equipment is functioning properly.



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Section 9: Natural Gas Service Disruption Background: Natural gas is used to fuel the facility’s warehouse heating system. The facility manager, Robert Lizarraga, or the person in charge if Robert is off site or unavailable will take the following steps as needed:


Contact Sealy & Company Sr. Property Manager xxx-xxx-xxxx to report the problem and to determine when restoration of service is expected. The utility provider should be questioned as to the cause of the outage, the geographic area of the outage and the expected duration. Maintain additional contact for further updates if needed.

Monitor facility temperature to determine if regular operations can continue.

Make the decision to close the facility on a case by case basis.


Verify all heating equipment is functioning properly.

Contact management and employees as necessary.


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Personnel Contact Information

Name Phone Cellular Ext Business Email

Robert Lizarraga 504-466-1666 xxx-xxx-xxxx 134 [email protected]

Wolfe, Mike 610-796-5859 xxx-xxx-xxxx [email protected]

Zechman, Chuck 610-796-5955 xxx-xxx-xxxx [email protected]

John Chauvin 504-466-1666 xxx-xxx-xxxx 125 [email protected]

Troy Falcon 504-466-1666 xxx-xxx-xxxx 137 [email protected]

Toby Falcon 504-466-1666 xxx-xxx-xxxx 135 [email protected]

Jeff Tranchant 504-466-1666 xxx-xxx-xxxx 133 [email protected]

Nicole Lizarraga 504-466-1666 N/A 136 [email protected]

Business Continuation Resource Listing

Name Category Phone Web Site

Home Depot Lumber/Hardware 504-464-9200 www.homedepot.com

Metro Lift Propane Propane 985-479-3015 www.metroliftpropane.com

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NOTES:

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

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Fire Extinguisher Information Inspect each unit for:

Extinguisher # 1 Not been dischaged

Brand Badger Hanging in proper location

Type ABC Pressure in acceptable range

Size 8 Not blocked or obstructed

Location Office: Main Entrance No visible damage to unit





Location Break Room No visible damage to unit


Brand Buckeye Hanging in proper location



Location Shop: Shop entrance No visible damage to unit


Brand Buckeye Hanging in proper location



Location Warehouse: Entry door No visible damage to unit





Location Warehouse: Rear exit door No visible damage to unit


Brand Amerex Hanging in proper location



Location Warehouse: Forklift No visible damage to unit

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Emergency Lighting Information Inspect each unit for:

Lighting # 1 Hanging in proper location

Type Exit & Dual Light "ON" when button depressed

Emergency Sign Fixture No visible damage to unit

Location Office: Front Main Door Exit not blocked or obstructed


Type Dual Light Left bulb "ON" when lights off

Emergency Light Fixture Right bulb "ON" when lights

off

Location Office: Main Hall No visible damage to unit




Location Office: Side Exit Door Exit not blocked or obstructed




Location Warehouse: Rear Exit Door Exit not blocked or obstructed


Type Dual Light "ON" when button depressed

Emergency Light Fixture No visible damage to unit

Location Warehouse: Side wall Left bulb "ON" when lights off

Right bulb "ON" when lights

off

Exit not blocked or obstructed

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Electrical Safety

1.0 Electrical Safety

Nearly all workers in the country directly or indirectly work with electricity in their daily work routine. Many overlook possible electrical hazards and fail to understand the potential consequences. Working with or near electrical circuits may expose employees to electric shock, burns, fires, and even explosions. According to Bureau of Labor Statistics preliminary data, over 300 workplace fatalities resulted from contact with electrical current in 2009.

2.0 Electrical Injuries

The four main types of electrical injuries are: • Fatal electrocution • Electric shock • Burns • Falls caused as a result of contact with electrical energy

3.0 Electrical Accidents

Most electrical accidents result from one of the following three factors: • Unsafe equipment or installation • Unsafe environment • Unsafe work practices

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If a person is “frozen” to a live electrical contact, shut off the current immediately. If this is not possible, use boards, poles or sticks made of wood or any other non-conducting materials to safely push or pull the person away from the contact. It’s important to act quickly! And, remember to protect yourself as well from electrocution or shock.

Power Outage at Work

When a power outage occurs…

• Shut off equipment, particularly electronic equipment such as computers, copiers and fax machines, etc.

• Shut off any electronic equipment that was operating when the power went off. Shut off major electric equipment as well. This will help stabilize the electric system when power is restored.

• Turn off any heat-producing electric equipment such as ovens, irons or dryers. This will minimize fire hazards when power is restored.

• Stay out of elevators – use the stairs instead. If possible, post signs warning people not

to use the elevators.

• Remain at your work station till your supervisor gives you further instructions.

• IF the power outage lasts more than 5-10 minutes your supervisor will instruct you to go to the lunchroom.

- Do not go to your lockers - Do not leave the building - Await further information

• If it is determined to close the facility use extreme caution when leaving the parking lot.

Traffic signals may not be working.

After an outage….

• Follow the instructions given by your supervisor that are specific to your department or job.

• Electrical equipment will be brought back on-line in stages. This will help eliminate

problems that could occur if there’s a surge in demand before the electric system stabilizes.

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Electrical Safety – Qualified Person Training

1.0 Energized Exposed Electrical Parts

1. Exposed parts 2. Live or energized parts 3. De-energized parts 4. Exposed parts that are de-energized, but not locked/tagged are

considered energized, exposed parts 2.0 Working Near Exposed Parts

1. Only qualified workers can work on or near exposed electrical parts 2. Live parts operating at less than 50 volts to ground do not need to be

de-energized when the worker experiences no increased exposure to electrical burns or explosions due to electrical arcs

3. Lockout/tagout must be performed by a qualified person 4. Types of excluded electrical work:

a. general, transmission, distribution, installation b. communications installations c. vehicle installations d. railway installations

3.0 Distinguishing Exposed Live Parts From Other Parts

1. Qualified persons use voltage testing equipment to identify live and de-energized parts

2. Testing equipment must be rated for the anticipated voltages to be tested

4.0 Nominal Voltage of Exposed Live Parts

1. Nominal voltages are values assigned to circuits to designate its voltage class

a. 120/240 b. 480Y/277 c. 600

2. The actual voltage at which a circuit operates can vary from the nominal within a range that permits satisfactory operation

3. Multi-meters/volt-ohm meters identify voltage 5.0 Clearance Distances – Unguarded/Energized Overhead Lines

1. The required distance between the workers and a conductive object that they could contact

2. Used when working below unguarded, energized lines 3. Exceptions to required distances

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a. The worker is wearing insulated equipment b. The energized part is insulated from the worker, and all

conductive parts at a different potential c. The worker is insulated from all conductive objects at a different

potential than the energized part 4. Voltages 50kv or less, the clearance distance is 10 feet 5. Voltages greater than 50kv, the clearance is 10 feet plus 4 inches for

every 10kv over 50kv 6. When the vehicle is in transit, and the structure is lowered:

a. The clearance distance is 4 feet for 50kv or less; or b. 4 feet plus 4 inches for every 10kv over 50kv for voltage greater

than 50kv 7. Insulating barriers

a. When installed but not attached to the vehicle, the clearance distance is the designed working dimensions of the barrier

8. Employees must not come into contact with vehicles/equipment under an energized line unless

a. The employee is wearing proper PPE b. The equipment/vehicle is located so that no insulated part can

provide a conductive path to employees 9. Do not stand near grounding locations for intentionally grounded

equipment/vehicles when contact with overhead wires is possible 6.0 Illumination

1. Do not enter an area containing exposed energized parts unless the area is illuminated

2. Do not work near exposed energized parts unless the area is properly illuminated

3. Do not reach into blind areas 7.0 Confined Spaces

1. Barriers, shields, and insulation provide protection from energized parts

2. Secure doors, hinged panels to prevent exposure to energized parts 8.0 Handling Conductive Materials/Equipment

1. Carefully handle conductive materials or equipment that come in contact with your body

2. Prevent contact with exposed energized parts 3. Carefully handle long, conductive objects in areas containing exposed

energized parts a. Insulation b. Guarding c. Materials handling

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9.0 Nonconductive Ladders

1. Portable ladders must have nonconductive siderails if they could contact exposed energized parts

2. Metal ladders can conduct electricity and cause arcing and shocks 10.0 Hazards of Conductive Apparel

1. Conductive jewelry and clothing can cause arcing when exposed to energized parts

2. Remove or cover conductive jewelry and clothing to eliminate risk of conductivity

11.0 Procedures for Using Portable Electrical Equipment

1. Proper handling of cords a. Don’t raise or lower equipment by its cord b. Don’t unplug the equipment by pulling on its cord c. Don’t staple or fasten the cord so as to damage outer jacket

2. Equipment inspection a. Visually check for:

i. Loose parts ii. Deformed or missing parts iii. Damaged jackets or insulation

b. Inspect for internal defectives, such as pinched or crushed outer jackets

c. Perform inspections prior to beginning each shift d. Remove defective equipment from service e. Check the plug and receptacle mating configuration before

connecting 3. Flexible cords

a. Flexible cords with grounding-type of equipment must have an equipment grounding conductor

b. Never remove or alter the cord’s grounding pin c. Never use an adapter with a missing grounding pin

4. Types of electrical equipment and cords to be used near water a. Equipment must be approved for use in these types of locations

5. Proper methods for plugging/unplugging a. Ensure hands are dry b. Never pull the plug out by the cord c. Handle cords and equipment with insulating protective

equipment when the cord connector is wet d. Secure locking-type connectors after making connection

12.0 Circuit Breakers and Circuits

1. Never use the following to open and close electrical circuits

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a. Fuses b. Terminal lugs c. Cable connectors d. Cable splice connections

2. Don’t manually re-energize a circuit without first determining if the equipment and circuit can be safely energized

3. Don’t modify overcurrent protective devices 4. Testing of electrical equipment should be performed by qualified

persons only 5. Keep flammables and combustibles away from electrical equipment

13.0 Protective Equipment

1. Personal protective equipment includes: a. Headgear b. Eye and face protection c. Rubber insulating gloves d. Rubber insulating sleeves e. Protective footwear

2. Inspect protective equipment to ensure its reliability and stability 3. Use insulated tools/equipment around exposed energized parts 4. Protective shields, barriers, insulating materials protect employees

from: a. Accidental contact b. Dangerous electrical heating c. Arcing

5. Normally enclosed live parts must be guarded during maintenance 14.0 Alerting Techniques

1. Signs and markings 2. Barricades 3. Attendants

15.0 Summary of Key Points

1. De-energized means locked/tagged out 2. Safe distances for clearances between workers and energized lines 3. Nonconductive ladders 4. Nonconductive clothing 5. Proper use of cords, plugs, receptacles 6. Proper use of electrical equipment around flammables/combustibles 7. Protective equipment 8. Alerting techniques

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Incident Reporting and Investigation Procedure

1.0 Incident Reporting and Investigation Procedure

GAI-Tronics takes significant precautions to avoid safety & environmental mishaps. However; in the event an incident does occur, appropriate steps must be taken including accurate reporting and investigation of the incident. This allows us to verify that the right measures have been taken to avoid re-occurrence of the incident. An incident is defined to include a work related injury or illness, any damage to company property, a motor vehicle accident involving a company vehicle or a personal vehicle during work related activities, a chemical spill, or a close call that could have resulted in any of these examples. 2.0 Emergency Response

Emergency response to an incident should be handled before any reporting needs are considered. Examples include:

First Aid and Emergency Medical Services for injured or ill personnel.

Fire Department response for fire, chemical spills and other emergencies.

Police response for suspected crimes. 3.0 Reporting

All accidents, injuries, and near misses must be reported immediately to the client/site coordinator and the GAI-Tronics manager. Incidents involving fatality or three (3) or more hospitalized employees will be reported to OSHA within eight (8) hours. The employee’s supervisor will complete an accident report within two (2) hours of notification. Site personnel and the involved employee’s supervisor will conduct an appropriate incident investigation based on the severity of the incident within forty-eight (48) hours. Incident reports should normally be completed by the supervisor responsible for the employee or work area involved in the incident. All appropriate information blanks should be completed on the incident form. In addition to providing accurate, factual information about the incident, special care and time should be committed to recommending preventative precautions to avoid re-occurrence of the incident. Instructions such as “be more careful” are not sufficient. Examples of appropriate prevention steps include specific engineering changes, tool or equipment changes, part changes, additional training requirements, policy or procedural changes, etc. Specific precautions can be discussed with the Safety Officer. Any questions relating to the incident report should be communicated to the Safety Officer or the Human Resources department. After completion by the supervisor, the report should be forwarded to the next level manager for review, comments, and additional recommendations. The

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completed form should then be forwarded to the Safety Officer for incident number assignment, review and follow up. If the incident involves employee injury or illness, the supervisor should also complete an Injury/Illness Report and provide the employee with an Employee Notification and Acknowledgment form. These forms should be forwarded to Human Resources after completion. All evidence collection, photography, witness statements, follow up interviews, etc. are the responsibility of the owner client.

Corrective actions will be determined during the accident investigation and completion of the recommendations will be coordinated by the owner client and GAI-Tronics personnel. Lessons learned will be communicated to personnel as appropriate. 4.0 Investigation Resources

The incident investigation kit includes the following items; writing equipment such as pens/paper, measurement equipment such as tape measures and rulers, cameras, small tools, audio recorder, PPE, marking devices such as flags, equipment manuals, etc. 5.0 Safety Follow Up

After receipt of an incident report, the Safety Officer will review the incident details and the preventative precautions with another member of the Safety & Environmental Committee and the supervisor. When appropriate, additional recommendations will be discussed. The best prevention solution, based on effectiveness, cost, and availability will then be implemented. A summary of the incident details and the preventative measures taken will be reported at the monthly Safety & Environmental Committee meeting. The Safety Manager and the supervisor will monitor the effectiveness of the preventative measures. 6.0 Training

Supervisors & Managers are trained in their roles and responsibilities for incident response and incident investigation techniques. Training requirements are appropriate to incident investigation and include:

Direct cause

Indirect cause

Root cause

Interview process

Report writing

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Heat-Related Illness Prevention

1.0 Policy

The objective of this program is employee awareness regarding heat illness symptoms, ways to prevent illness, and what to do if symptoms occur. Employees working in outdoor places or in other areas at times when the environmental risk factors for heat illness are present are at risk for developing heat illnesses if they do not protect themselves appropriately. It is the policy of GAI-Tronics Corporation that any employee who works outdoors in the heat and all individuals who supervise these employees must comply with the procedures in this program and in the Injury and Illness Prevention Program.

2.0 Scope

This program applies to employees and supervisors working in outdoor places of employment during those times when the environmental risk factors for heat illness are present.

3.0 Definitions

Acclimatization - The temporary adaptation of the body to work in the heat that occurs gradually when a person is exposed to it. Acclimatization peaks in most people within four to fourteen days of regular work for about two hours per day in the heat. Environmental risk factors for heat illness - The working conditions that create the possibility that heat illness could occur, including air temperature, relative humidity, radiant heat from the sun and other sources, conductive heat sources such as the ground, air movement, workload severity and duration, protective clothing and personnel protective equipment worn by employees. Heat illness - A serious medical condition resulting from the body’s inability to cope with a particular heat load, and includes heat cramps, heat exhaustion, heat syncope, and heat stroke. See the appendix for specific information on the forms of heat illness. Personal risk factors for heat illness - Factors such as an individual’s age, degree of acclimatization, health, water consumption, alcohol consumption, caffeine consumption, and use of prescription medications that affects the body’s water retention or other physiological responses to heat. Preventative recovery period - A period of time required to recover from the heat in order to prevent heat illness.

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Shade - The blockage of direct sunlight. Canopies, umbrellas, and other temporary structures or devices may be used to provide shade. One indicator that blockage is sufficient is when objects do not cast a shadow in the area of blocked sunlight. Shade is not adequate when heat in the area of shade defeats the purpose of shade, which is to allow the body to cool. For example, a car sitting in the sun does not provide acceptable shade to a person inside it, unless the car is running with air conditioning.

4.0 Accountability

Provide training to all potentially impacted employees and their supervisors on the risks and prevention of heat illness, including how to recognize symptoms and respond when they appear. Training should be provided annually as a refresher prior to the start of the summer season. Managers and Supervisors

A. Identify all employees who are required to work outdoors where potential

heat illness could occur and identify the supervisor of the employees.

B. Assure that adequate water and shade are available at a job site when the

environmental risk factors for heat illness are present.

C. Ensure that all affected employees have received proper training on heat

illness prevention.

D. Ensure that the requirements in this program are followed.

E. Contact the appropriate emergency medical services in the event medical

assistance is required. Police will direct emergency medical services to

the work site.

Affected Employees

A. Comply with the provisions of the Heat Illness Prevention Program, as

described in this document and in the training sessions they attend.

B. Ensure they have drinking water available at all times when the

environmental risk factors for heat illness are present.

C. Ensure they have access to a shaded area to prevent or recover from heat

related symptoms.

D. Report heat related illness symptoms to the supervisor.

E. Look for the signs and symptoms of heat stress on your co-workers.

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5.0 Program

Access to Water Employees must have access to potable drinking water and encouraged to frequently consume small amounts of water throughout the day – up to 4 cups per hour depending heat conditions. If plumbed potable water is not readily accessible, provide portable water containers or bottled water. Shade Employees suffering from heat related illnesses or in need of a recovery period from the heat must be provided with access to an area with shade that is either open to the air or provided with ventilation or cooling for a period of no less than five minutes. Access to shade must be permitted at all times. Other methods of cooling, other than shade, can be used if it can be demonstrated that these methods are at least as effective as shade.

6.0 Training

Training must be provided for employees working on job tasks where environmental risk factors for heat illness are present, as well as training for their respective supervisors. Refresher training must be provided annually. Employees - All employees working on job tasks where environmental risk

factors for heat illness are present shall receive instruction before being assigned

to work tasks. Training topics shall include the following:

1. Environmental and personal risk factors for heat illness.

2. Procedures for identifying, evaluating, and controlling exposures to the

environmental and personal risk factors for heat illness.

3. Employees who experience excessive sweating require frequent

consumption of small quantities of water, up to 4 cups per hour when

working in extreme conditions of heat.

4. Importance of acclimatization.

5. Different types, signs, and symptoms of heat illness.

6. Importance of immediately reporting symptoms or signs of heat illness in

themselves or in coworkers to their supervisor.

7. Procedures for responding to symptoms of possible heat illness, including

how emergency medical services will be contacted and provided, should

they become necessary.

8. Campus procedures for contacting emergency medical services.

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Supervisors and Affected Employees - Supervisors and/or their designees

shall receive training on the following topics prior to being assigned to supervise

outdoor employees:

1. Information as detailed above in employee training requirements.

2. Procedures the supervisor must follow to implement the provisions of

this program.

3. Procedures the supervisor must follow when an employee exhibits

symptoms consistent with possible heat illness, including emergency

response.

Training Records All training records prepared in association with the Heat Illness Prevention Program will be maintained by Human Resources and the Safety officer. REFERENCES

http://www.cdc.gov/niosh/topics/heatstress/

http://www.dir.ca.gov/dosh/heatillnessinfo.html

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Field Service Department Fatigue Management Program

1.0 Purpose and Objective

GAI-Tronics Corporation has an obligation to minimize risk due to fatigue of Field Service Employees. Where the effects of fatigue and/or the nature of the work being performed induces fatigue, causing impairment to a person’s health and safety, GAI-Tronics Corporation will ensure that appropriate and reasonable management action, consistent with this procedure, is taken. The objective of this procedure is to provide appropriate knowledge, skills and tools for the safe management of fatigue to:

maintain a safe and healthy work environment;

minimize the risk to Employees, Contractors, Visitors and the public;

act as a minimum standard;

encourage persons affected by work and non-work related fatigue to seek assistance;

enable the appropriate people to perform their role and responsibilities whilst maintaining the privacy and confidentiality of people participating in fatigue management; and

educate and provide a greater understanding of the effects of fatigue to

Field Service Employees.

2.0 Definitions

The definitions in this document pertain only to the matters dealt with in this document. They shall not be used to infer rights and/or obligations in any other industrial mechanism.

24-hour Period A rolling period of 24 consecutive hours.

Call Out A period when a person is required to work outside their normal work hours due to an unplanned event.

Circadian Rhythm A bodily rhythm that is cyclic and recurs every 24 hours. It increases alertness and performance during the day and drives us to sleep at night.

Compulsory Break Break periods as defined in Section 10.

Consultation The timely exchange of relevant information and ideas in such a manner that the parties have the actual and genuine opportunity to influence the outcome.

Contingency A future event which is possible but cannot be predicted with any certainty.

Drug Use Use of over-the-counter or prescription drugs for the

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purpose of fatigue control is forbidden. (Refer to “Fitness for Duty Policy”.)

Emergency A serious, unexpected and potentially dangerous situation requiring immediate action.

Employee A person directly employed with the Field Service Department of GAI-Tronics Corporation.

Employee Assistance Program

The EAP is provided by trained professionals operating externally to GAI-Tronics Corporation. They provide counseling, information and assistance on a wide range of problems including work stress, relationship and family problems, conflict and managing change, and other issues that may lead to fatigue problem.

Essential Personnel Personnel vital to the resolution of the crisis.

Extraordinary Hours Successive days of greater than 12.5 hours.

Fatigue A state of impaired physical and/or mental performance and lowered alertness. Influences on fatigue include, but are not limited to, restorative sleep, physical or mental activity, refreshment, time of day and length of time awake.

Fatigue Assessment A process to assist in determining fatigue risk level and suitable control measures for Personnel. It may be used for situations such as call outs, extension of work time, random, due cause etc.

Fit for Duty Means that a person is in a state (physical, mental and emotional) which enables them to perform assigned tasks competently and in a manner which does not threaten or compromise the safety or health of themselves or others. (Refer to “Fitness for Duty Policy”.)

Health & Safety Specialist An employee of GAI-Tronics Corporation who is engaged in a Health and Safety role as a Manager, Coordinator, or Advisor.

Night/Shift Work Requirement to work during the time when a person would normally be asleep which requires a change to the normal sleeping pattern; typically, work outside daylight hours.

Normal Work Hours Attendance at work according to an agreed schedule.

On Call Persons designated to be available to respond to customer contingencies outside their normal work hours.

Personnel / Persons Employees of GAI-Tronics Corporation Field Service Department.

Prior Sleep Wake Model A means for determining a person’s fatigue risk

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levels based on the amount of sleep obtained in the prior 24 and 48 hour period.

Random A selection process where each variable in the sample has the same probability of being selected.

Reasonable Suspicion An opinion that is formed as a result of an observation that is conducted by a suitable trained person with reference to Appendix 1.

Rest Period A period allocated for recovery and/or restorative sleep.

Risk Assessment A documented process of identifying hazards, assessing risks and determining control measures.

Safety Critical Work Work or activities that are critical to the safe planning and/or performance of tasks, involve the safety of people or others at the workplace and the safe use of equipment.

Shift Work A pattern of work rosters including day and/or night periods.

Sleep Debt Occurs when a person does not achieve adequate restorative sleep. It can accumulate over a period of days of inadequate sleep or a night without sleep. Sleep debt may result in impaired performance, reduced alertness and higher levels of sleepiness and fatigue. A sleep debt can only be repaired with recovery sleep.

Sleep Inertia Impairment of alertness and performance immediately upon waking e.g. may last for a period of up to 30 minutes.

Scheduling The allocation of tasks and resources.

Suitable Place for Sleep A facility where a person can obtain good quality restorative sleep.

Suitable Trained Person A person who is authorized by GAI-Tronics Corporation to perform fatigue assessments following successful completion of training and education.

Transparent & Auditable Information must be readily available and accessible to all personnel within 7 days of occurrence e.g. distributed to the working party, intranet, etc.

Unplanned Contingency An event that has the ability to imminently cause (a) safety risks, (b) environmental impacts and (c) loss of production.

Working Time The period of time spent conducting company business.

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3.0 Obligations

All Personnel shall comply with this common policy for fatigue management. GAI-Tronics Corporation has an obligation to ensure that this policy is in place to promote, support, monitor and review the workplace practices and outcomes. All Personnel have an obligation to ensure they report for work in a state that enables them to conduct their business activities in a safe manner. GAI-Tronics Corporation has an obligation to ensure that, as far as reasonably practical, those workers unfit to drive due to the effects of fatigue are transported to their home or alternative suitable place for sleep. Where a fatigue risk is identified the situation must be managed to remove or minimize the risk.

4.0 Responsibility

Everyone at the workplace has a responsibility to ensure that fatigue does not affect their own or others’ health and safety in the workplace. 4.1 Shared Responsibility

The management of fatigue is considered a shared responsibility between an organization and its Personnel as illustrated in Figure 1. GAI-Tronics Corporation is responsible for providing a safe system of work which includes the development, implementation and management of working time schedules, work schedules and the establishment of a safe work environment and work practices. Personnel are responsible for ensuring they are fit for duty by taking into account their lifestyle and medical factors that could influence fatigue, and managing these appropriately.

FIGURE 1

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4.2 GAI-Tronics Corporation

GAI-Tronics Corporation will:

provide training and educate its Employees about the impacts of fatigue;

offer rehabilitation and assistance to any Employee, taking into account the person’s right to privacy and confidentiality;

provide leadership and commitment through the allocation of resources and Personnel for the establishment, implementation, evaluation and review of the fatigue management program;

review, monitor and track all aspects of the fatigue management program to ensure compliance as well as identifying areas for improvement;

ensure that the fatigue assessment process is utilized and documented;

provide continuing appropriate fatigue management training;

develop and implement agreed working rosters to ensure adequate opportunity for restorative sleep is provided;

provide support processes, policies and services for Personnel;

ensure that if a person’s capacity to work safely is reduced by fatigue they can notify their supervisor without fear of adverse repercussions;

ensure that privacy and confidentiality are maintained;

provide suitable accommodation for Employees when required to travel for work;

provide an Employee Assistance Program (EAP) that places emphasis on the recognition and management of fatigue.

4.3 Field Service Managers

Field Service Managers are responsible for:

implementing this procedure at the workplace;

investigating apparent breaches of the provisions of this procedure;

taking appropriate actions where breaches of the procedure have occurred;

ensuring that during recruitment processes, prospective Employees are advised that a fatigue procedure is in place;

ensuring that the Employee and workplace induction processes includes education on the standards, obligations and responsibilities of this procedure;

assisting Supervisors and Managers in applying this procedure. This includes facilitating access to counseling, rehabilitation and other assistance services when required;

monitoring the application of this procedure and regularly assessing the suitability and adequacy of this procedure and identifying any aspects that can be improved and report accordingly about those matters;

providing advice to management, particularly on the privacy and confidentiality rights of Employees;

ensuring that privacy and confidentiality is maintained.

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assisting in and implementing this procedure to minimize the causes of work related fatigue;

ensuring that, to the extent possible, controlling fatigue through work schedules and promoting positive personal habits

employee fatigue is considered in planning work rosters, work allocation and scheduling, taking into account the range of matters set out in Appendix 2;

identifying and advising the relevant Site/General Manager about issues with the practical application and operation of this procedure and any areas for improvement;

consulting with appropriate Personnel, arranging suitable alternate duties (where possible) and/or a safe location for a person impaired by fatigue;

ensuring that fatigue is considered in the investigation of any incident;

maintaining privacy and confidentiality, including acting on reports of concern about privacy and confidentiality;

recognizing and assessing the signs, symptoms and management of fatigue (refer to Appendix 1).

4.4 Human Resources

Human Resources is responsible for:

ensuring that information and education regarding this procedure are provided in Employee and workplace inductions;

offering to arrange support, counseling and medical advice for Employees;

maintaining records and reporting fatigue matters and statistical data;

maintaining privacy and confidentiality;

Fitness For Duty Policy

4.5 Employees

Employees must:

Not willfully place their own or others health and safety at risk;

make every reasonable effort to be fit for work while: - at work; - on call; - driving a company vehicle; or - operating company equipment.

notify their Supervisor if: - their work performance is likely to be affected by fatigue; or - there is any risk to themselves or others due to the effects of fatigue;

notify their Supervisor or other responsible person immediately (if a person will not self manage their potential impairment) where there is a potential risk to health and safety if they suspect others in the workplace are behaving in a manner that suggests fatigue-related impairment exists (refer to signs and symptoms in Appendix 1);

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encourage other Personnel to comply with this procedure;

participate in fatigue assessments, if requested;

report any actual or potential fatigue risks;

fulfill their obligation to arrive at work fit for duty.

All Personnel are encouraged to use time away from work to obtain sufficient restorative sleep to ensure fatigue-related risks are managed to an acceptable level.

5.0 Counseling and Support

5.1 Employee Assistance Program (EAP)

GAI-Tronics Corporation provides a confidential EAP through an external service provider. This program is available to all Employees and their families free of charge. Contact details of the EAP are posted throughout each workplace. GAI-Tronics Corporation can provide information regarding the service and will arrange an appointment on request. An Employee may directly contact the external service provider if they so choose. 5.2 Employee Treatment and Support

GAI-Tronics Corporation recognizes that some Employees may require treatment and/or support for fatigue-related issues. If an Employee believes he or she requires assistance, or where GAI-Tronics Corporation management considers a person may require assistance, that Employee will be encouraged to obtain treatment and/or support through:

EAP Counselors;

Community Health Services;

Support groups or other specialist services;

Human Resources;

Medical Practitioners.

GAI-Tronics Corporation will, in all cases, offer an appropriate, fully-funded treatment and/or support program in accordance with the organization’s procedure for Workplace Rehabilitation and Workers Compensation Claims. Any Employee who participates in a treatment and/or support program to manage a fatigue-related issue will be granted leave (which may include special leave) in accordance with the relevant workplace FMLA, Policy HR 3.1.

6.0 Privacy and Confidentiality

The use of information gained as a result of a fatigue assessment will be strictly limited to purposes consistent with this procedure. GAI-Tronics Corporation will ensure that Employee information is kept confidential and secure. All documentation and requests for disclosure will be handled according to relevant

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Legislation. Information will only be used for the purpose of determining fitness for duty, assignment of appropriate duties, treatment and/or support purposes. GAI-Tronics Corporation will only release information to a third party as required by law, and with the written permission of the Site Manager, after the person concerned has been advised. The person concerned will be advised and this advice shall be documented. Records of fatigue assessments are not to be passed on by the company to any future Employer (except in the case of a transmission of business where the Employees transfer their employment to the new owner). GAI-Tronics Corporation will take all reasonable steps to respect the privacy and confidentiality of persons participating in fatigue management. The behavior and actions of all parties involved will be under close scrutiny with regards to maintaining the privacy and confidentiality of persons being assessed. Concerns about privacy and confidentiality should be reported to their Supervisor or Human Resources Representative. Breaches of confidentiality are considered a serious matter and will be treated in accordance with the performance management process outlined in the procedure Counseling, Discipline and Dismissal (Work Rules Procedure HR- 2.1). Where relevant to an incident investigation records will only be referenced in the investigation and flagged with the appropriate cross-referencing. These records will be kept in accordance with regulatory requirements.

7.0 Education and Training

GAI-Tronics Corporation will provide all Employees with an education program on fatigue management including their responsibilities under this procedure. This education will give Employees the knowledge and ability to manage their own fitness for work. The education program will be on-going and flexible. It will respond to fatigue-related trends identified through policy and procedure reviews and audits. All Employees will participate in training, both initially and annually thereafter, to recognize symptoms and behaviors associated with the affects of fatigue including support mechanisms and the application of the procedure. Supervisors, Managers, and Health and Safety Personnel will participate in more detailed training. The EAP is available to provide Employees and their families with assistance and/or support. EAP consultants will provide further education and information as required.

8.0 Fatigue Management System and Procedures

8.1 Fatigue Risk Management Framework

Fatigue risk management is about managing sleep, the duration of sustained wakefulness and the type of work performed. The level of control will reflect the level of fatigue risk. It is a shared responsibility between GAI-Tronics Corporation and its personnel. Work-related risk factors shall be addressed because they reduce physical performance and impact on psychological factors such as

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judgment, concentration, vision and decision-making processes. The process for undertaking risk assessments and fatigue assessments to identify control measures is outlined in this section. 8.2 Risk Assessment

The GAI-Tronics Hazard Identification and Risk Assessment Procedure shall be utilized to assist in the evaluation and management of fatigue risks. Work-related risk factors shall be addressed as they can reduce physical performance, impact on psychological factors such as judgment, concentration, vision and decision-making processes. When performing a risk assessment, use the GAI-Tronics Job Safety Analysis (JSA) Form to document the activity, tasks, risk analysis and controls measures to be applied. When undertaking risk assessments and identifying control measures, refer to the risk factors that contribute to fatigue and typical control measures outlined in Appendix 2. To support the risk assessment, the assessment tool Form FS2012 ‘Observation and Fatigue Assessment’ may be applied. Refer to Section 8.4. Risk assessments will provide a graded/graduated process for the determination of fatigue cut off levels such as low, moderate and high risk categories with subsequent actions such as breaks, task rotation, refreshments and others outlined in Appendix 2. 8.3 Identification of Fatigue

Identification of persons who may be affected by fatigue can occur as a result of:

self-assessment and voluntary disclosure by the person affected;

direct observation of the affected person’s behavior, consistent with: Appendix 1:

a workplace incident investigation;

monitoring compliance with this procedure;

completing a fatigue risk assessment;

conducting the relevant site risk assessment process. 8.4 Assessing Fatigue Impairment

A fatigue assessment tool assists in understanding a person’s level of fatigue. The fatigue assessment will be conducted by a suitably trained person who is authorized by GAI-Tronics Corporation. The assessment shall be documented on the approved form, FS2012, ‘Observation and Fatigue Assessment’. Any person who is requested to undergo a fatigue assessment and refuses such a request will not be allowed entry to, nor allowed to remain in the workplace.

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8.4.1 Assessment Methods, Tools and Criteria:

Provided are several fatigue assessment methods. These include:

sleep opportunity;

signs and symptoms – use the fatigue table detailed in Appendix 1;

prior sleep wake model (sleep duration) – Appendix 3;

hazard control methods – refer to Appendices 2 and 4, and Risk Assessment Section 8.2;

sleepiness scales;

hours of wakefulness;

incident reporting; and

self reporting.

This criteria is used in the assessment tool Form FS2012 ‘Observation and Fatigue Assessment’ to document, assess and provide appropriate action/s to safely manage fatigue. This form is detailed in Appendix 5. This form is the tool to be used for the following assessments:

Self

Random

Overhaul

With cause (post- incident)

Reasonable suspicion The assessment will indicate the person’s level of fatigue giving a score and corresponding risk category with pre-determined responses and actions. This is detailed in Appendix 4. 8.4.2 Self-Assessment

Personnel are encouraged to self-assess where they believe they may be impaired due to the effects of fatigue. Self-assessment is generally performed using the Prior Sleep Wake Model (Appendix 3) and/or by identifying signs and symptoms (Appendix 1). This is a voluntary assessment process. An Employee who identifies they are impaired by fatigue (to the extent that it has the potential to create a health and safety risk) as the result of a voluntary self-assessment must cease work immediately and contact their Supervisor. A formal risk assessment will be conducted to identify appropriate controls. An Employee who is unfit for work as a result of fatigue impairment due to personal circumstances shall apply for appropriate leave. Leave will be in accordance with the relevant procedure. An Employee’s voluntary self-assessment that results in non-attendance will not be recorded. Excessive non-attendance may be managed as per the performance management process outlined in the procedure, (Work Rules Procedure HR- 2.1.)

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8.4.3 Random Assessment

The National Service Manager will set the assessment frequency and number of Personnel to be assessed. Those people selected will be advised to report and undergo assessment. Random assessments may also be initiated where there is concern that a high level of risk may exist due to, for example:

Large numbers of Contractors on-site for a forced outage or other repair work.

Construction projects occurring on-site.

Community social events where it is likely persons may be fatigued. Where random assessments have been initiated a suitably trained person shall conduct the assessment using Form FS2012 ‘Observation and Fatigue Assessment’. 8.4.4 With Cause (Post-Incident) Assessment

If an incident occurs in the workplace that a Supervisor believes caused or could have caused serious injury to people and/or serious damage to plant and/or equipment (with cause), the person/s involved will be assessed for fatigue, using Form FS2012 ‘Observation and Fatigue Assessment’, as soon as practicable by a suitably trained person. This assessment will form part of the incident investigation process. 8.4.5 Reasonable Suspicion Assessment

Reasonable Suspicion is identified from observation of signs and symptoms that may be displayed by a person impaired by fatigue. These are listed in Appendix 1. If a Supervisor has a Reasonable Suspicion that a person at work is impaired by fatigue, the supervisor must, as soon as possible, direct the person to stop performing any duties that, if the person is fatigued, may present a risk of injury. The supervisor should initiate an assessment, using Form FS2012 ‘Observation and Fatigue Assessment’, by a suitably trained person. If other Employees or a Customer Representative suspect a person at work is affected by fatigue, they should advise a GAI-Tronics Corporation Supervisor. In the event that it is not possible or practical for the person in question to undertake an assessment, a Supervisor will direct them not to perform any further work. That person will remain in an area where he or she presents no safety risk to themselves or others until they can be assessed. Alternatively, GAI-Tronics Corporation will make arrangements for their safe transport home, including relocation of vehicle and/or return to site later.

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8.4.6 Assessment Results

An Employee who is impaired by fatigue due to work-related factors or other reasons will be required to undertake a formal fatigue assessment (Form FS2012 ‘Observation and Fatigue Assessment’) to indicate the level of fatigue to determine appropriate control measures. When a person has been identified as having fatigue risk, control measures shall be put in place consistent with the actions and responses detailed in Table 1 and Appendix 4. Also, the fatigue assessment utilizes the Risk Score Chart in Section 6 of the Form FS2012 ‘Observation and Fatigue Assessment’ to determine the appropriate fatigue management actions to allow that person to return to the task or appropriate tasks at a later time. If a person is removed from duties or given alternate duties as a result of a fatigue assessment, the person will not be disadvantaged. Fatigue assessment records shall be held in accordance with Section 6, Privacy and Confidentiality, and filed with the Human Resources Representative (this does not include voluntary self-assessments for fatigue).

9.0 Management of a Person Impaired by Fatigue

Where a person has been identified with a level of fatigue that will present a risk to the health and safety of Personnel or the safe operation of plant, the person’s supervisor will discuss with that person the appropriate control measures based upon the Risk Score Chart detailed in Appendix 4. Where practicable, suitable alternative duties and control measures are to be selected (e.g. less physical work activities, monitoring of work, rescheduling of tasks, rest periods, longer breaks). Refer to Appendix 2 for possible control measures. However, it may be determined that the person leave the site and return to work on their next scheduled work period. Where the level of impairment is considered a health risk, that person should be referred to a medical practitioner or EAP counselor. A medical clearance is to be obtained by that person prior to returning to work if that person has received medical treatment. When it is not possible to provide suitable alternative duties and the person is required to leave the site, the Supervisor or Manager shall arrange transport for that person. 9.1 Employees Affected by Fatigue

Where an Employee is affected by fatigue, the supervisor shall:

record the fatigue assessment using Form FS2012 ‘Observation and Fatigue Assessment’;

Apply the appropriate controls as per the Risk Score Chart;

Where suitable alternate duties are required, conduct a risk assessment (using the JSA) and develop suitable controls to minimize the effects of fatigue;

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Where a person is not fit for duty and required to leave the site, provide transport for that person to their home or suitable place for rest; and

Forward the Fatigue Assessment Form to the Human Resources Representative for sign off and filing.

Offer the services of EAP and/or medical practitioners.

10.0 Rules for Managing Fatigue

10.1 Staff and Appropriate Work Balance

Table 1 prescribes the rules for managing fatigue for planned or pre-agreed work schedules.

Table 1 – Rules for planned or pre-agreed work schedules

Situations Basis Value Limit number of actual work hours in any 7 day period.

6 attendances consisting of a maximum of 12 hours each

72 Hours

Planned maximum hours of work 12 Hours 12 Hours

Long Break frequency Minimum 24 hours with no financial disadvantage

1 break in every 7 days

If personnel are required to work continuously for 4 or more nights the person will have a rest period after change from night work/shift before returning to the normal work schedule

4 or more nights shifts consecutively.

48 hours (to support 2 nights sleeps) *see Note 1.

Rest period after change from night work before changing to a different work schedule - were night work has been worked continuously for 3 or more weeks.

Minimum 48 hours *See Note 1

48 hours (to support 2 nights sleeps) *see Note 1.

*Note 1: The 48 hour rest period may occur at anytime during a Work Schedule period. Breaks which fall on normal projected roster working shifts will be paid as if at work.

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10.2 Contingency and Call Outs

Table 2 prescribes the rules for managing fatigue for contingency and call outs.

Table 2 – Rules for contingency and call outs

Situations Basis Value Limit number of actual work hours in any 7 day period.

Inclusive of call outs

Normal schedule plus 24 hours after which a 24 hour break must be taken without financial disadvantage

Maximum continuous hours worked in a 24 hour period inclusive of time worked as a result of unplanned contingency.

16 Hours 16 Hours

Unplanned contingency - after a work period of greater than 12 hours, additional work periods of greater than 12 hours cannot be worked unless there has been a 24 hour break.

16 Hours Up to 16 Hours

Minimum short break duration (hours) following a call out or contingency

10 Hours 10 Hours

Call Outs - Maximum hours worked in a 24 hour period, starting from commencement of previous attendance

16 Hours 16 Hours

11.0 Accommodation

GAI-Tronics Corporation is responsible to ensure that suitable accommodation is available for their Employees when required to travel for work purposes to enable them to fulfill their obligation to arrive at work in a fit state.

12.0 Travel

Where work duration reaches 14 hours, the Employee is to be provided with transport for the return journey to their home or a suitable place for sleep. The person driving the vehicle is to be fit to safely undertake the journey. Personnel shall avoid driving more than 12 hours in a 24 hour day. Personnel driving vehicles to and from work should:

Avoid driving after being awake for a continuous period of 17 hours;

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Avoid driving if they have not accumulated more than 5 hours sleep in the previous 24 hours or 12 hours sleep in the previous 48 hours;

Ensure adequate sleep the night before a long journey;

Share driving where possible;

Take a rest break from driving of at least 10 minutes every 2 hours or more frequently if feeling tired.

In the case of work purposes when driving company provided vehicles, all of the above requirements shall apply. All travel time, when in control of a vehicle, prior to the commencement of and after the completion of work shall be incorporated into the calculation of fatigue levels.

13.0 Call Outs

For a call out the following conditions will apply:

A formal fatigue assessment which includes prior sleep wake data shall be conducted where the person is required to work between the hours of 7:00pm to 7:00am. A review of the fatigue assessment will be done if the work is to continue past 4 hours.

A person may choose to drive provided they take into account the following fatigue issues: - Sleep inertia (which may require them to allow 30 minutes after being woken prior to driving); - Maximum hours of work in the prior 24 hours as defined in Section 10; and - Other relevant factors which may impact on their ability to drive.

Conditions relating to travel shall comply with Section 12. There is a shared responsibility between the person requesting the call out and the person being called out to consider the effects of fatigue and comply with the requirements of this procedure.

14.0 Telephone Call Disturbances

When sleep is disturbed by work-related telephone calls, the loss of sleep should be considered in the person’s assessment of fatigue risk level. This may result in the person being unavailable for duties until sufficient restorative sleep has been achieved.

15.0 Prior Sleep and Wakefulness

The Prior Sleep Wake Model, detailed in Appendix 3, shall be used as part of the fatigue assessment tool. It is based upon a person’s level of risk from fatigue when that person had: (i) less than 5 hours sleep in the previous 24 hours; and

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(ii) less than 12 hours sleep in the previous 48 hours. The duration of their wake period is not to exceed the amount of prior sleep they have had in the previous 48 hours. This is illustrated in Appendix 3 and supporting examples. Control measures shall be initiated consistent with Appendix 4 where a person reports they have had inadequate time for sleep or poor sleep. Control measures may include, but are not limited to, shift start toolbox talks to assess prior sleep, regular onsite peer review, job allocation to less critical tasks, increased break periods, close supervision of their work-related fatigue, opportunity for a rest period and being transported home.

16.0 Breaks Within Shifts

The duration of breaks within shifts shall be a minimum of 15 minutes for every two hours worked unless the work conditions dictate addition break time/duration. Employees should be encouraged to take breaks away from their work area in locations without the need for any PPE (hearing/eye/head protection) and with access to sustenance and seating. Further breaks may be needed based on the physical need for sustenance or due to environmental factors in accordance with “Heat Related Illness Prevention Procedures”, metabolism, work load, nature of work, etc. Changing work tasks shall not be considered as a break.

17.0 Scheduling

Planning of work tasks shall comply with this fatigue management procedure. In all scheduling the following matters shall be considered, but are not limited to:

time of day;

nature of work and the level of risk inherent in the work;

number of people;

circadian rhythm;

sleep inertia;

sleep debt;

start and finish times;

duration of work;

frequency of breaks;

opportunity to recover from fatigue;

redesign work practices or rescheduling high risk/complex tasks;

the need to conduct a formal risk assessment.

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Job rescheduling may be necessary when there is a risk to a person’s health and safety, plant or equipment if performing hazardous/critical work during the high fatigue periods, e.g. between 2:00am to 6:00am Any scheduling involved with unplanned contingency must be managed to comply with this procedure.

18.0 Ergonomic Considerations

Where possible, GAI-Tronics Corporation shall ensure that if an employee is required to perform their duties in a stationary location, the location is equipped with proper lighting and temperature control. The workstation shall also be equipped with seating and a portable desk for use when writing software on their laptop.

19.0 Records

Fatigue Assessments shall be recorded on the Form FS2012 ‘Observation and Fatigue Assessment’ and forwarded to the Human Resources Representative for filing.

20.0 Incidents

GAI-Tronics Corporation shall ensure that fatigue-related issues are considered in the investigation and reporting of incidents.

21. Further Information

Further information or assistance with this procedure can be obtained from your Supervisor or the Safety & Environmental Manager.

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Appendix 1 – Signs and Symptoms of Fatigue

Physical Mental Emotional

Yawning Difficulty concentrating on a task More quiet than usual

Heavy Eyelids Lapses in attention Lacking energy

Eye-Rubbing Difficulty remembering what you

are doing Mood changes, decreased

tolerance

Head Drooping Failure to communicate important

information Emotional outburst(s),

aggression, rage

Micro Sleeps Failure to anticipate events or

actions

Accidentally doing the wrong thing

(error)

Accidentally not doing the right

thing (omission)

Use these signs and symptoms for Fatigue when completing a Fatigue Assessment.

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Appendix 2 – Risk Factors and Control Measures

Supervisors (e.g. when preparing JSAs in consultation with workers) should address the following issues. Risk factors that contribute to fatigue:

Prior sleep and wakefulness – the amount of sleep they have had prior to work and the duration of their work period.

Working without a rest break to meet critical deadlines/milestones.

Sleep patterns affected by frequent call outs over a limited period and extended hours of work.

Work tasks/activities requiring concentration or high levels of muscular exertion for extended periods of time.

Tedious and monotonous work.

Heavy or exhausting physical activity.

Working in high risk situations.

Inadequate recovery from interrupted or poor quality sleep.

Working successive shifts, frequently on call out, and regular emergency work outside standard work hours.

Working in high heat or cold temperatures or humid conditions.

Driving vehicles while tired.

Accepting work which results in exceeding working hour limits.

External factors that affect a person’s fatigue risk level while at work. - Excess hours/Overtime. - Extended Shiftwork over successive days. - Rest Breaks and Rotation of Tasks. - Contractors and Outages.

Emergency Work/Time of day – incidents are more likely to happen in circadian low points (such as night time, especially between the hours of 2am to 6am).

Length of shifts worked – the effects of fatigue are cumulative, workers are more likely to feel fatigued in the final hours of a shift, than in the first few hours of a shift.

Lack of opportunity to recover from fatigue – incidents are more likely to occur if workers are not given a sufficient opportunity to recover from fatigue.

How often the situation occurs – generally, the more often a worker is fatigued, the greater the likelihood that an incident will occur.

How many people are fatigued – generally, the greater the number of people who are fatigued, the more likely an incident is to occur.

The skills and experience of persons fatigued – consider training and competency both to perform work-related tasks and manage fatigue.

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Any special characteristics of the people involved – for example if a worker is on medication for a medical condition that is affected by circadian rhythms and night shift work (such as asthma, depression or diabetes).

The duration of exposure to fatigue - generally, the longer a person is fatigued, the more likely an incident will occur.

The level of risk inherent in the work – incidents are more likely to occur in work that is generally hazardous, such as when operating heavy machinery.

Number of consecutive night shifts worked. Commuting – time spent travelling reduces time available for recovery.

Shift rotation – relevant shift changes and start/finish times.

Sleep inertia – drowsiness after being woken.

Rest breaks – the number and duration of breaks taken.

Occupational exposure levels – extended exposure on longer shifts to noise, dusts, chemicals. Manual tasks – forces used to push, pull, lift, carry, reach or dexterity required for work and ergonomics – body position and location.

Proximity of workers residence or accommodation – method of travel to and from work and the risk of commuting incidents.

Ability to access food and refreshments for a balanced diet.

Control Measures

Redesigning work practices so that routine administrative tasks are minimized for night shift workers, allowing them to focus on core duties during night work.

Scheduling later start times so that maximum night sleep can be obtained before starting work (however this can affect those on night shift).

Scheduling low risk work during periods of high fatigue, such as night time, especially during the hours of 2am to 6am) and/or in the latter half of shifts.

Scheduling complex tasks to be performed only during the day.

Sufficient supervision, particularly during periods of high fatigue (such as night time, or in the latter half of shifts) and especially for hazardous work.

Contingency plans if workers become fatigued – this would involve removing fatigued workers from work activities where there is a considerable risk to health and/or safety.

Effective emergency responses.

Strict controls and procedures if performing hazardous work during high fatigue periods (especially during 2am to 6am).

Job rotation for repetitive or monotonous work, or work that

involves heavy physical demands.

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Appendix 3 – Prior Sleep Wake Model

This tool is used for qualifying a person’s fatigue risk level/s based on the amount of sleep obtained in the prior 24 and 48 hour period. The basis of the model is minimum sleep of:

5 hours in the previous 24 hour period and 12 hours in the previous 48 hour period.

Start of shift End of shift

Wake-up

SLEEP SLEEP WORK

X

Y

Z

X = Sleep in prior 24 hrs

Y = Sleep in prior 48 hrs

Z = Time Awake

As prior sleep decreases and prior wake increases, the likelihood of fatigue also increases. In general; X should be greater than threshold of 5 hours Y should be greater than threshold of 12 hours Z should be less than Y A point system is used to determine what course of action a person and/or the organization may take, as follows:

Step 1

X: Sleep in previous 24 hours: _______ hrs

[5 or more hrs = 0; add 2 pts for every hour below 5] _______ pts

Step 2

Y: Sleep in previous 48 hours: _______ hrs


Step 3

Z: Time awake: Time from waking to present:

_______ hrs

[Y or less hrs = 0; add 1 point for every hour of wake beyond Y hrs] _______ pts

Total Score (Prior Sleep Wake Score): _______ pts

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Example – Low Fatigue If a person has slept 6 hours in the prior 24 hours and 10 hours in the prior 48 hours and has been awake for 2 hours, that person’s score would be - X=6 (sleep in prior 24 hours) Y=10 (sleep in prior 48 hours) Z=2 (hours awake) Points System Step 1 + Step 2 + Step 3 = Fatigue Risk Score 0 + 4 + 0 = 4 Refer to appendix 4 - Risk control measures for a score of 4 may include: Self monitoring, task rotation and team monitoring of colleague but this range will be determined by internal organizational decisions regarding responses designed to reduce the identified fatigue risk. Example – Higher Fatigue If a person has slept 3 hours in the last 24 hours and 6 hours in the prior 48 hours and has been awake for 10 hours, that person’s score would be – X=3 (sleep in prior 24 hours) Y=6 (sleep in prior 48 hours) Z=10 (hours awake) Points System Step 1 + Step 2 + Step 3 = Fatigue Risk Score 4 + 12 + 4 = 20 Refer to appendix 4 - Risk control measures for a score of 20 may include: Document externally, do not engage in any hazardous activities, do not commence work.

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Appendix 4 – Risk Score Chart

Score Risk Response/Actions

0 n/a Remain with existing working arrangements unless

higher level hazards are present.

1 - 4 Low

Report to the supervisor and document. Undertake approved individual control measures. Self-monitor for

symptoms, team monitoring by colleagues and task rotation.

5 - 8 Moderate Report to the supervisor and document. Organize

supervisory checks. Complete symptom checklist and task re-assignment.

9 or more High Document externally, do not engage in any safety critical

work and do not recommence until fit for work.

Score: The higher number from the fatigue assessment determined

from either: (i) the prior sleep wake model; or (ii) signs and symptoms chart (Appendix 1)

Risk: The level designated for the risk to identify severity to priority

to address. Response/Action: The appropriate course of action to address the level of risk.

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Appendix 5 - Form FS2012 Observation Record and Fatigue Assessment

This form is a record of the fatigue assessment for a person under GAI-Tronics Corporation's Fatigue Management policy. The privacy and confidentiality of that person will be maintained with respect to the information gained as a result of the fatigue assessment.

Section 1 - Assessment Type Check √ appropriate boxes

Assesment Type: □ Self □ Random □ With Cause □ Reasonable Suspicion

Work Type:

□ Ops/Maint/Adm □ Projects □ Forced Outage

Section 2 - Particulars of Person (being assessed) and Work Schedule Check √ appropriate boxes

Engagement Type:

□ Employee

Last name:

First name:

Job Title: Site: Department:

Nature of Duties:

Date: Time:

Attendance Start Time:

Work Schedule: □ Planned Roster □ Call Out □ Extended Hours This assessment was undertaken hrs into the attendance.

Section 3 - Questions Check √ appropriate boxes

Have you completed your designated compulsory break from previous work period? □ Yes □ No

Will this work keep you within 72 hours worked within 7 days?

□ Yes □ No

Have you had a continuous 24 hr break since you last worked greater than 12 hrs? □ Yes □ No

Have you had a 10 hour break since your last call out ended?

□ Yes □ No

Do you think you are fit for duty?

□ Yes □ No

Where 'no', the risks from fatigue are increased. Refer to 'Rules for Managing Fatigue' and record in Section 6.

Other Comments:

Section 4 - Observation, Signs and Symptoms Check √ appropriate boxes

Physical: □ Heavy eyelids □ Yawning □ Head drooping □ Eye rubbing □ Micro sleeps

Emotional: □ More quiet than usual □ Mood changes, decrease in tolerance

□ Lacking energy

□ Emotional outburst, aggression, rage

Mental: □ Difficulty concentrating on the task

□ Difficulty remembering what you are doing

□ Lapses in attention

□ Failure to anticipate events/actions

□ Failure to communicate important information

□ Accidentally doing the wrong thing (error)

□ Accidentally not doing the right thing (omission)

Total number of marked boxes: Transfer total score to Section 6 (Signs & Symptoms Score)

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Appendix 5 - Form FS2012 Observation Record and Fatigue Assessment – Page 2

Section 5 - Prior Sleep History Check √ appropriate boxes

X: Sleep in previous 24 hours: _______ hrs


Y: Sleep in previous 48 hours: _______ hrs


Z: Time awake: Time from waking to present: _______ hrs

[Y or less hrs = 0; add 1 point for every hour of wake beyond Y hrs] _______ pts

Transfer total score to Section 6.

Total Score (Prior Sleep Wake Score): _______ pts

Section 6 - Assessment and Decision Response Check √ appropriate boxes

Signs & Symptoms Score: _______ Prior Sleep Wake Score: _______ Choose the higher score to determine the Fatigue Assessment Score. Fatigue Assessment Score: _______

from table below Risk: ______________

Score Risk

Response/Action

0 N/A Remain with working arrangements unless higher hazards are present

1 - 4 Low

Report to the supervisor and document. Undertake approved individual control measures. Self monitor for symptoms, team monitoring by colleagues and task rotation.

5 - 8 Moderate

Report to the supervisor and document. Organize supervisory checks. Complete symptom checklist and task re-assignment.

9 or More High

Document externally, do not engage in any safety critical work and do not recommence until fit for work.

Relating the Fatigue Assessment Score to the table plus responses from Section 3 has identified the person is:

□ Fit for current duties □ Not fit for current duties

Action Taken:

□ Employee Assistance Program recommended □ Alternate transport offered

□ Alternate transport accepted

Section 7 - Completion Details

Observation Sheet completed by: Name: Position: Signature: Date: ____/_____/_____

Acknowledgment of person assessed: Signature: Date: _____/_____/____

→ Forward to the Supevisor/Manager

Supervisor/Manager: Name:

Position: Signature: Date: _____/_____/____

→ Forward completed form to the Human Resource Representative

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Stop Work Authority

1.0 Work Practice

All employees have the authority and obligation to stop any task or operation where concerns or questions regarding the control of Health, Safety & Environmental risk exist. Employees are encouraged to assess the site working conditions at all times, and work should not continue until the stop work issues have been resolved. At no time will retribution or intimidation be directed at any individual for exercising their right to issue a stop work authority. Employees shall contact their supervisor, Human Resources department or call the Hubbell “Listen Up” hot line at 1-888-789-6627 to report any retribution or intimidation concerns. 2.0 Stop Work Intervention

Each employee is responsible for working in a safe manner during their work assignment. Additionally, each employee is encouraged to constantly review their working conditions. GAI-Tronics management supports an employee’s right to initiate a Stop Work Intervention when warranted. Each Stop Work Intervention will be documented and coordinated through a supervisor. This documentation will include, but is not limited to: The root cause of the intervention in addition to corrective action and any recommendations for training. All affected personnel and supervision will be notified of the Stop Work Intervention. The end result of any Stop Work Intervention is to have identified safety concern(s) and verify it has been addressed to the satisfaction of the initiator as well as others involved prior to the continuation of work. All Stop Work reports shall be reviewed by management. The purpose of the review will be to verify the quality of Stop Work Interventions and to follow-up and document common issues. The reports will also be reviewed to capture any opportunities for improvement and shared training. 3.0 Training

Employees receive Stop Work Authority training as part of each project briefing prior to assignment. The training is documented with the employee name, the dates of training and the subjects covered.

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STOP WORK REPORT

All employees have the authority and obligation to stop any task or operation where concerns or questions regarding the control of Health, Safety & Environmental risk exist. At no time will retribution or intimidation be directed at any individual for exercising their right to issue a stop work authority. Employees shall contact their supervisor, Human Resources department or call the Hubbell “Listen Up” hot line at xxx-xxx-xxxx to report any retribution or intimidation concerns.

Please describe the reason for the intervention:

Date: _________ Time: _________ Reported To: ________________________

Observation: _____________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

Resolution Action

Findings: ________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

Resolution: _______________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

Lessons Learned: _________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

Date: ________ Employee: _________________ Signature: ________________

Date: ________ Supervisor: ________________ Signature: ________________

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Alcohol & Drug Policy

Policy of GAI-Tronics Corporation Effective Date

Alcohol and Drug Policy Revised 11/22/2013

1.0 General

The illegal use, possession, distribution or sale of alcohol or drugs anywhere at work is prohibited and considered a willful violation of Company policy, and shall result in employment suspension or discharge (see page 30 1.a.). All employees have the responsibility to report to work in a fit condition and to perform their jobs without unnecessary risk to themselves or other individuals. This policy is primarily driven by a concern for employee safety and is in addition to and consistent with the basic requirement that all employees must report to work and remain at work in a fit condition.

2.0 Guidelines

1. All employees will be subject to alcohol and drug screening as a result of: 2. Involvement in a serious workplace accident, or serious workplace incident as

determined by the Company. 3. Being identified as unfit for work as determined by the Company

Management. 4. Any Company-required physical examination or evaluation. 5. Any employee, such as a Field Service Technician, working at a customer

site will be required to take and pass a drug-screening equivalent to Department of Transportation (DOT) screenings. Field Service employees are required to submit and pass a hair sample for drug testing (when first accepting a Field Service position), and then submit to random urinalysis screenings thereafter.

6. By taking this step, we hope to satisfy all customer requirements, however, employees may still be required to take a drug screen prior to a specific customer visit. If this is needed, GAI-Tronics is notified prior to an employee’s arrival as to whether a drug screen is required. After such notification, the employee is required to have a drug screen before entering the customer’s facility. Employees must have a negative test result to enter the facility.

7. Any employee testing positive during alcohol and drug screening will be removed from work and referred to the Employee Assistance Program, subject to appropriate disciplinary action up to termination. If the employee returns to work, the employee shall be required to undergo further alcohol and drug screening. Subsequent violations of this policy may result in discipline or discharge. Refusal to undergo alcohol and drug screening, or refusal to

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accept referral to the Employee Assistance Program as required by the Company, will subject the employee to immediate discharge.

8. Each job applicant, regardless of intended payroll status, must undergo a drug screening, as part of pre-employment processing and as a condition of employment.

3.0 Definitions

Serious Workplace Incident - An accident or incident to an employee which involves serious or potentially serious harm to an individual on the property of GAI-Tronics. Examples of incidents that may be deemed a workplace incident are accidents resulting in a lost-time injury or property damage greater than $500. In the event of a serious accident, Field Service employees will need a physician's release (without restrictions) to travel to a customer’s facility.

Unfit for Work - Any employee identified by designated Company Management as not safely or completely performing his/her job and presenting unnecessary risk to themselves or others. Field Service employees will need a physician's release (without restrictions) to travel to a customer’s facility. That determination will be done in conjunction with the requirements identified in the job description for their particular position.

Fit for Work – The employee is physically capable of performing the duties identified in the position requirements identified in their job description. It is the employee’s responsibility to identify to their supervisor any medical conditions that may prevent them from performing their assigned duties.

4.0 Procedures

1. If an employee's performance or behavior indicates possible alcohol or drug abuse or impairment, or if there is a reasonable concern that an alcohol or drug problem may exist, the employee will be counseled by the supervisor and the Human Resources Department and may be required to submit to alcohol and drug screening.

2. Supervisors/Managers must notify the Human Resources Department to make arrangements with the lab/hospital for screening.

3. Employees who are required to submit to alcohol and drug screening will be asked to sign a consent/release form authorizing the physician to perform the screening and the lab/hospital to release the results of the screening to the Company. Any employee who refuses to sign a consent/release form will be subject to immediate discharge.

4. In other than pre-employment screening, Supervisors/Managers, or an authorized Company representative will escort the employee to the lab/hospital for screening and then to his/her home or will arrange for transportation and escort (if necessary) from the location of their current duty assignment.

5. Until the Company receives the results of the alcohol and drug screening,

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the employee will be placed on an unpaid leave of absence and will not be eligible to work. If the test results are negative, the employee will be reinstated and compensated for any work time lost. Any employee who tests positive will not be permitted to return to work or to any Client/Host site or facility, and will be referred to the Employee Assistance Program and subject to disciplinary action. Any such employee may only return to work upon the satisfactory completion of the rehabilitation program recommended by the Employee Assistance Program. The employee, upon returning to work, may be required to undergo periodic alcohol and drug screening up to a maximum of three (3) times over the next twelve (12) month period. Any employee who is unable to undergo alcohol and drug screening within twenty-four (24) hours after a serious workplace incident will also be subject to periodic alcohol and drug screening up to a maximum of three (3) times over the next twelve (12) month period. Subsequent violations of this policy shall result in discipline and discharge.

6. Every reasonable effort will be made by the Human Resources Department and the involved Supervisor/Manager to preserve the confidentiality of the alcohol and drug screening process. Information concerning this process will be limited to those Company personnel with a "need to know".

THIS POLICY AND PROCEDURE GUIDE DOES NOT CREATE A CONTRACT EITHER EXPRESSED OR IMPLIED

This policy is subject to change at any time without notice

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GAI-TRONICS CORPORATION

MEMORANDUM

To: All Employees Date: August 1, 2000

From: Gary Amato cc:

Subject: GAI-Tronics Corporation

DRUG-FREE WORKPLACE PROGRAM

PROGRAM STATEMENT:

As a supplement to the GAI-Tronics Corporation Drug and Alcohol Policy and as

required by the Drug-Free Workplace Act of 1988, the Company has formulated a Drug-

Free Workplace Program. This program is intended to inform employees about the

Company’s policy against the use, possession, sale or transfer of controlled substances in

the workplace and to establish a list of responsibilities for the administration and

implementation of this program.

SCOPE:

This policy applies to all GAI-Tronics employees wherever Company services are being

performed.

RESPONSIBILITIES:

The Human Resources Department is responsible for the formulation, implementation,

and administration of the Drug-Free Workplace Program. These responsibilities shall

include:

Publishing a statement notifying employees that the unlawful manufacture,

distribution, dispensation, possession, or use of a controlled substance is

prohibited in the workplace, and specifying the actions that will be taken against

employees for violations of such prohibition;

Distribution the Company’s Drug-Free Workplace Policy Statement to all

employees working on the Government contract;

Including within the Company’s Drug-Free Workplace Policy Statement a notice

to all employees working on a Government Contact that as a condition of

employment, the employee will abide by the terms of the Policy Statement and

will notify the Company within 5 days of a conviction of a criminal drug statue

occurring in the workplace;

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Notifying the Government Contracting Agency within 10 days after receiving

notice form an employee or after otherwise receiving actual notice of a criminal

drug statue conviction occurring in the workplace;

Coordination with the employee’s Manager to impose an appropriate sanction on,

or requiring the satisfactory participation in drug abuse assistance or rehabilitation

program by, any employee who is convicted of a criminal drug statue violation

occurring in the workplace.

Establishing a Drug-Free awareness program to educate and inform employees

about:

I. The dangers of drug abuse in the workplace;

II. Company policy of maintaining a drug free;

III. Any available drug counseling, rehabilitation, and employees assistance

programs;

IV. The penalties that may be imposed upon employees for drug abuse

violations;

Certifying to the Government Contracting Agencies that the Company will

provide a drug-free workplace by compliance with the requirements of the Drug-

Free Workplace Act of 1988 and by which and administration of the Drug-Free

Workplace Program.

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Policy Effective Date

Fitness for Duty Policy

Issued: 05/24/2012

Updated:

Purpose

GAI-Tronics Corporation is committed to providing a safe workplace environment. The Company will implement selection criteria to provide reasonable assurance that those working in an offshore work environment are physically/mentally capable of safely performing their assignments/duties without excessive risk or harm to themselves, others or property. Selection criteria will be based on an evaluation of an applicant’s qualifications for the position, which includes the applicant’s fitness to work in an offshore work environment.

Scope

All employees who are assigned to positions which require they work in an offshore work environment.

General

Prior to hire, employees will be subject to background checks and screenings to ensure the employee’s physical and mental fitness for the offshore work environment. In addition, while employees are assigned to the offshore work environment, employees are expected to report to work in a fit condition to perform their duties at the utmost levels of safety and efficiency.

Pre-employment Background Checks

GAI-Tronics Corporation conducts background checks to confirm educational qualifications, prior employment experience and conviction records consistent with state and federal law.

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Pre-employment Medical Exam

Following an offer of employment, the Company conducts a physical examination to confirm, among other things, that an applicant can perform the essential functions of the position, with or without reasonable accommodation. In addition, following an offer of employment, the Company requires applicants to undergo a drug screening.

Fitness for Duty Evaluations

The Company will require Fitness for Duty evaluations whenever there is a reasonable belief, based on objective evidence, that: (1) an employee's ability to perform essential job functions is or will be impaired by a medical condition; or (2) employment of an individual poses a direct threat due to a medical condition. Fit for Duty evaluations are generally accomplished through medical examinations conducted by an employee’s own treating physician and/or a physician or other medical professional chosen by the Company. Objective evidence sufficient to warrant a Fitness for Duty evaluation will be deemed to exist if company representatives: (1) know about a particular employee's medical condition, are aware of performance problems, and reasonably can attribute the performance problems to the medical condition; (2) know about a particular employee's medical condition and reasonably believe the employee’s performance of essential job functions may pose a direct threat; (3) receive reliable information from a credible third party that the employee has a medical condition that may impair the employee’s ability to perform essential job functions or may pose a direct threat; or (4) the company observes symptoms indicating that the employee may have a medical condition that will impair the employee’s ability to perform essential job functions or may pose a direct threat. “Direct threat” means a significant risk of substantial harm that cannot be eliminated or reduced through reasonable accommodations. Depending on the circumstances, it might be appropriate and necessary for employees to submit to more than one Fitness for Duty evaluation. For example, if there were a dispute regarding an employee’s functional status, it might be necessary for the employee to participate in one or more independent medical evaluations to clarify his or her functional status. If employees, without justification, refuse to submit medical information and/or participate in Fitness for Duty evaluations or examinations, their work injury or disability benefits may be discontinued and they may be subject to disciplinary action including possible termination of employment.

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Drug/Alcohol Free Workplace Policy

The unlawful manufacture, distribution, dispensation, possession, use, or sale of a Controlled Substance or Alcohol is prohibited at any time. If an employee seeks medical treatment for substance abuse, the Company will reasonably accommodate the employee’s efforts and his/her return to work once he/she has received the appropriate treatment. However, no provisions of this program will prevent the Company from terminating an employee if the employee engages in any of the offenses above. In addition, employees are prohibited from being at work under the influence of any substance which may impair an employee’s fitness to perform in an off-shore work environment, including prescription or over-the counter medication. If an employee is using prescription or over-the counter medication which may impair his/her fitness or safe and effective performance of his/her job responsibilities, the employee should inform his/her supervisor immediately. The supervisor, with the assistance of the health care resources, will determine whether the employee can continue to work and/or whether the Company should temporarily change the employee’s job assignment while employee is using the prescription or over-the counter medication.

Random Drug/Alcohol Screening

A. To the extent permitted by state law, a percentage of employees will be tested for drugs monthly on a random basis. The annual percentage will be established and will include all employees. B. When a random drug test is performed, the method used will be urinalysis. C. If, pursuant to a random drug test, a regular, full-time employee tests positive for illegal drugs, or for legal drugs or substances which are used illegally (including drugs or substances for which the employee does not have a valid prescription), the employee will be removed from work and referred to the Employee Assistance Program, subject to

appropriate disciplinary action up to termination.

Reasonable Cause Drug/Alcohol Screenings

A. Where a drug/alcohol test is based upon reasonable suspicion, approval to give the test will be made by two members of management, where feasible.

B. Factors which may indicate that a reasonable suspicion drug/alcohol test may be warranted include, but are not limited to:

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• Contributing to a workplace accident

• Possession of drug paraphernalia by the employee

• Unexplained abnormal or erratic behavior

• Arrest or conviction for an illegal drug related offense; or the identification of an employee as the focus of a criminal investigation involving illegal drugs

• The odor of drugs or alcoholic beverages

• Employee appearance and speech

• Other behavior that gives rise to reasonable suspicion that the employee has used alcohol or illegal drugs in a manner inconsistent with this policy.

If suspicion under this policy is raised, employee will be removed from duty and subject to drug testing. The MRO will request an explanation from the employee and, in the event of a confirmed positive result, will determine whether the explanation is reasonable.

C. When a drug test is based upon reasonable suspicion, urinalysis will be the method used. If, for medical reasons, an employee is unable to provide a urine sample, alternative methods (such as hair or blood samples) will be utilized as allowed by law.

D. When an alcohol test is based upon reasonable suspicion, the method(s) used will be a screening saliva test, Evidential Breath Test (EBT) or a blood test. If the screening saliva test is positive, either a follow-up confirmatory EBT or a blood test must be immediately obtained.

E. If, pursuant to a reasonable suspicion drug/alcohol test, an employee tests positive for illegal drugs or alcohol, or for legal drugs or substances which are used illegally (including use of a drug or substance for which the employee does not have a valid prescription), the employee will be subject to immediate discharge.

F. An employee may also be subject to discharge if he/she refuses to submit to a reasonable cause screening or if he/she tampers with the urine sample.

G. To the extent permitted by state law, a drug and alcohol test is mandatory for all work-related accidents requiring a physician’s visit. Urinalysis will be the method used. If a drug or alcohol test is verified positive, the employee(s) will be subject to immediate discharge.

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References

Employee Assistance Program - Offering solution-focused help and resources for all types of life issues and is available 24 hours a day, seven days a week online at MagellanHealth.com/member or by telephone: xxx-xxx-xxxx. 4851-1127-9119, v. 1

Additional Policies Incorporated Herein

A. All Field Service Technicians must obtain and maintain the certifications outlined in the Technician Off-Shore Certification Requirements contained in the Field Service Safety & Environmental Policy manual in order to accept Off-Shore Assignments.

B. All Field Service Technicians are subject to the Service Organization Skill Compensation Plan and Short Service Employee Mentoring Program outlined within the Field Service Safety & Environmental Policy manual.

C. All Field Service Technicians must follow the safe work practices and procedures outlined within the Field Service Safety & Environmental Policy manual, including but not limited to the Fatigue Management Plan.

http://www.magellanhealth.com/member

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Short Service Employee Mentoring Program

1.0 Definition

A short service employee is generally a new hire or other transfer from another department within GAI-Tronics with little or no field experience. All new employees are considered Short Service Employees (SSE) regardless of past experience with another company. 2.0 Crew Makeup and Restrictions

A typical work crew will consist of 2-3 individuals, and at no time will there be more than one SSE in the crew makeup. At no time will a SSE be the sole representative to any work site. 3.0 SSE Monitoring and Feedback

The SSE will be accompanied by an experienced service technician at all times during the training period and is not permitted to perform work outside of a controlled environment (Control Room or Maintenance Shop) without direct supervision at all times. At no time will more than one SSE be paired with an experienced technician.

The experienced technician will report any corrective action notations of behavior or unsafe work habits to the owner as well as the GAI-Tronics Service Manager. The SSE will receive verbal counseling/correction immediately following any observed unsafe act, either directly or through the owner representative.

4.0 SSE Identification and Site Specific Training

Prior to mobilization the Service Manager will notify the owner that two individuals will be performing the onsite service so that arrangements can be made for site specific training. The SSE will receive the same site orientation training as the experienced service technician and will be required to pass any verbal or written test to confirm the training. The owner will also be notified that the SSE will be identified with a yellow hard hat and coveralls.

5.0 Certification and Promotion

A SSE will receive certification for independent service visits after he/she has: 1. Met all training requirements of the systems they are responsible to support. 2. Demonstrated the ability to provide hardware and software support

independently. 3. Accompanied a mentor technician on a minimum of 5 service trips over a

span of 6 months. 4. Performed at least two system startups independently with a certified

technician who was observer only. 5. Had no reports of misconduct or safety violations.

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6. Had no reports of non-negative test results from the randomized substance abuse screening program.

Any SSE who does not meet any of the six requirements for certification will remain in the mentoring program until they have met the requirements. Failure to attain certifications due to repeat offenses of safety, drug screening, etc. will result in the employee being referred to the GAI-Tronics progressive discipline program.

6.0 Owner Feedback or Safety Violations

An employee may be returned to the mentoring program if an employee receives a safety violation or notation from a customer, contractor or owner’s agent. The decision to return to the mentoring program will be made by the service manager responsible for the employee after consulting with the party who issued the violation.

7.0 Sub Contractors

GAI-Tronics never has and never will use a subcontractor to perform any work on our behalf.

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Technician Off-Shore Certification Requirements

All Field Service Technicians must obtain and maintain the following certifications prior to any offshore assignments:

1. BOSIET (Basic Offshore Safety Induction and Emergency Training) Certification to include HUET (utilizing the Modular Egress Training Simulator) and EBS training

2. SafeGulf Training at an Accredited Facility 3. Transportation Worker Identification Credential (TWIC®) Card 4. Gulf Coast Safety Council – Basic Orientation Plus Safety Training

Basic Offshore Safety Induction and Emergency Training

(BOSIET) LEARNING OUTCOMES During the BOSIET program Participants will gain a basic level of understanding and an awareness of safety and emergency response on the offshore installations. They will be required to demonstrate their skills and the level of knowledge and understanding of the following key areas. SAFETY INDUCTION Participants will explain/identify: (testing knowledge)

Offshore hazards Waste disposal/environment awareness Role of the HSE/offshore safety regulations Permit to Work Procedures for prescribed medicines offshore Alcohol and substance abuse policy PPE requirements Procedure for reporting incidents, accidents and near misses Role of the Medic

HELICOPTER SAFETY & ESCAPE Participants will demonstrate practically: (testing skills and knowledge)

Donning a transit type survival suit, aviation lifejacket and Emergency Breathing System

Equipment (EBS). Operation and use of Emergency Breathing System Equipment (EBS) during pool

exercises. Actions in preparation for a helicopter ditching and an emergency landing Actions following:

1. a controlled emergency descent to a dry landing (without deploying EBS) 2. a controlled ditching on water (including deployment of EBS equipment) 3. a partial submersion of an aircraft (without deploying EBS equipment) 4. a partial submersion of an aircraft (deploy & operate EBS equipment)

Actions following an aircraft capsize in water (including deployment of EBS equipment on surface prior to capsize).

SEA SURVIVAL Participants will demonstrate practically: (testing skills and knowledge)

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Donning of a permanent buoyancy lifejacket prior to use in an emergency Actions when mustering and boarding a survival craft (TEMPSC) as a passenger during

launching operations Fitting of a helicopter strop and correct body posture during winching Survival First Aid, to include Resuscitation, Bleeding, Hypothermia, and First Aid Kit.

FIREFIGHTING AND SELF RESCUE Participants will demonstrate practically: (testing skills and knowledge)

Use of appropriate hand held portable fire extinguisher Use of a small bore fire hose reel or a fire blanket Appropriate self rescue techniques using a smoke hood and an escape type breathing

apparatus

The following are further examples of items to be covered in the BOSIET training:

1. A member of the flight crew, the HLO or a qualified platform escort must escort passengers at all times while on the helideck.

2. Passengers shall ensure that all personal gear in the vicinity of helicopter operations is properly stowed inside a bag or container.

3. If PPE is required to be worn in or around helicopter operations, the PPE must be secured to the individual by an approved strap or method.

4. Smoking is not permitted on a helideck or in the vicinity of helicopter operations.

5. Passenger use of cell phones is not permitted and cell phones must be turned off and stowed during flight.

6. Requirements for work clothes as well as PPE may vary for specific job and location. Employee shall verify requirements prior to traveling offshore.

7. Firearms, illegal drugs, and alcoholic beverages are prohibited on helicopters, vessels, shorebases, and offshore jobsites.

8. Pilot authority, manifest and weighing procedures, safe embarking and disembarking procedures, use of approved life jackets, seating arrangements, seat belts, luggage and cargo, pollution prevention, rules of safe conduct in flight, and emergency in flight and landing procedures for helicopter transportation.

9. Boat Captain authority, passenger manifest procedures, safe loading procedures, use of Coast Guard approved PFD, seating arrangements, luggage, cargo, pollution control, smoking rules, safe conduct during transit, safe disembarking procedures (including swing ropes and/or personal baskets and handling of materials) and outline of emergency procedures for boat transportation.

10. Marine Trash and Debris Awareness, including viewing the OOC video.

11. Procedures for water safety, to include various types of personal flotation devices; do not jump into the water unless it is the only

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means of evacuation; when in the water, stay calm, stay in a group, conserve energy, conserve body heat and await assistance.

Copies of all technician BOSIET Certifications (training records) are to be kept in the GAI-Tronics Field Service Department.

SafeGulf

Orientation / Minimum Training Requirements

Total 10 Hours of Awareness Level / Orientation Training to include, but

not limited to:

1. Incident Reporting and Investigation (Awareness) 2. Accident Prevention Signs & Tags (Awareness) 3. Hand Safety (Awareness) 4. Back Injury Prevention (Awareness) 5. Behavioral Safety (Awareness) 6. Bloodborne Pathogens (Awareness)

7. Confined Space (Awareness) 8. Lockout/Tagout (Awareness) 9. Drug & Alcohol (Awareness) 10. HazCom (Awareness) & HAZWOPER (First Responder – Awareness) 11. Electrical Safety (Non-Qualified) (Awareness) 12. Intervention (Awareness) 13. Fire Prevention and Portable Fire Extinguishers (Awareness)

14. Walking Working Surfaces (Awareness)

15. Job Safety and Environmental Analysis (Awareness) 16. Offshore Orientation and Emergency Evacuation (Awareness) 17. Personal Protective Equipment (Awareness) & Respiratory Protection (Awareness) 18. Prevention of Workplace Violence (Awareness) 19. Marine Debris (Awareness)

20. Fall Protection:Introduction (Awareness) 21. Permitting (Awareness) 22. SafeGulf Maritime Security (Awareness)

TWIC Card

A Transportation Worker Identification Credential (TWIC®) is a biometric credential that ensures

only vetted workers are eligible to gain unescorted access to secure areas of a Maritime Transportation Security Act (MTSA)-regulated port or vessel.

Gulf Coast Safety Council – Basic Orientation Plus Safety

Training

1. Hazard Communication a. Describe the right to know law Under OSHA Regulations

b. Define Hazardous Material c. Describe Methods of Recognizing Hazards

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d. Explain Material Safety Data Sheets (MSDS) e. Discuss Marking and Labeling for Hazardous Materials

f. Describe NFPA and HMIS Methods of Labeling g. Listing of Hazardous Materials

i. H2S ii. Asbestos iii. Lead iv. Radiation

h. Written Program

i. Train Before Handling Chemicals j. Warning Signs and Signals k. Don't Cross Barricade l. Barricades Should Be Visible

2. Personal Protective Equipment a. Controlling Hazards

b. Assessment and Selection

c. Selection Guidelines d. Fitting the Devices e. Devices with Adjustable Features f. Cleaning and Maintenance g. Hard Hat h. Safety Glasses

i. Foot Protection j. Fall Protection

3. Respiratory Protection a. Written Program b. Respirator Selection c. Medical Evaluations d. Fit Testing

e. Respirator Hazards f. Limitations and capabilities

4. Hearing Conservation a. Effects of Noise b. The Way We Hear c. Symptoms of Exposure d. OSHA Hearing Conservation Standard

e. Monitoring f. Audiometric Testing - Consider deleting? g. Administrative & Engineering Controls h. Selection Criteria

5. Electrical Safe-Work Practices a. Causes of Electrical Accidents

b. Unsafe Work Practices c. Energized and De-Energized Equipment d. Lockout/Tagout e. Working on Energized Circuits Safely f. Overhead Line Safety

g. Energized Parts General Safety Consideration h. Hand/Portable Electrical Equipment

6. Elevated Work a. Fall Hazards b. Fall Protection Systems c. Scaffold Requirements d. Scaffold Types e. Ladder Requirements f. Ladder Types

7. Process Safety Management

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a. Introduction to Process Safety Management b. Employee Involvement

c. Process Safety Information d. Process Hazard Analysis (PHA) e. Operating Procedures and Practices f. Employee Training g. Contractors h. Pre-Startup Safety i. Mechanical Integrity

j. Hot Work Permit k. Managing Change l. Investigation of Incidents m. Emergency Preparedness n. Compliance Audits o. Trade Secrets

8. General Safety Topics

a. Accident Reporting b. Emergency Alarms and Communications c. Reasons for Evacuation d. Evacuation Plan e. Evacuation Route f. Substance Abuse

g. Permits and Work Authorizations h. Job Site Maintenance and Housekeeping i. Vehicle and Equipment Safety j. Respiratory Protection k. Hand Safety l. Back Safety m. Fire Prevention

i. Types of Fire Extinguishers ii. Classes of Fires

n. Eye Wash and Safety Shower o. Cranes

9. Maritime Security a. Marsec Levels b. Incident Control

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Service Organization Skill Compensation Plan

1.0 Intent

Implement a program by which each Service Technician can be fairly and equally evaluated, can achieve personal and professional growth, and will be provided with salary compensation equal to their achievements. The program should additionally provide the department manager the ability to map each technician’s growth path and allow planned development. 2.0 Plan

Develop specific technical qualifications required for the growth and promotion of Service Technicians, addressing entry level and additional growth levels. This will include the development of “proficiency” requirements, training, and minimum field/bench requirements associated with specific product “elements”. Technical performance will directly affect performance appraisal scoring but will not be the sole determining factor in a decision to promote. Compensation will also be provided for professional licenses and certificates that directly relate to job responsibilities. 3.0 Technical & Time-In-Grade Requirements

Associate Service Tech, Band NE3 (entry level) Each Associate Service Technician must meet the minimum technical requirements of the elements listed in Modules 1, 2 and 3 before being considered for promotion. Promotion to Senior Service Technician will generally not occur until a minimum of three (3) years time in grade as an Associate Service Tech has been completed. Senior Service Technician, Band NE4 (Minimum requirements = 11 Elements Complete) Senior Service Technician may select new elements to complete provided they’re approved by the office manager prior to beginning. Upon completion of an element, the office manager will submit the required Personnel Action form from HR for the percentage of the completed element.

4.0 General

1. Upon employment, the department manager will assign two Core Modules that consist of three elements each. These two modules consist of skills universal to all service centers and focus on support of the company’s core business. A third Regional Module will consist of five elements that may be unique to the market focus of the service center. The office manager will assign three elements that make up the Regional Module.

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2. Each of the elements within the modules must be completed before

compensation is given for the entire module. 3. In addition to the published time in grade requirements, each technician must

have achieved an overall rating of “On Target” in all non-technical sections of their most recent performance appraisal before being considered for promotion.

4. Travel time cannot be considered when calculating field service hours. 5. An element “checklist” will be maintained by the technician throughout the

course of their progress toward completing the Module. The checklist will include all the technical requirements of the associated element and must be completed before the technician is credited with completion of the element. The department manager’s signature will indicate the minimum technical requirements met and the date the requirements were recognized.

6. All technical positions listed will require travel and are considered non-

exempt. 7. Elements may be waived or credited with the approval of the National Service

Manager. Examples of justification of waiver would include hiring or transferring a technician within the company with a strong background in one or more of the listed elements.

8. Elements may be added or deleted at any time as required to support the

business plan and departmental objectives. 9. GAI-Tronics reserves the right to modify or delete portions of this plan at any

time without prior notice. 5.0 Certification Pay Compensation

Certification pay compensation will be provided for licenses and certificates that directly relate to the technicians’ responsibilities and/or the products GAI-Tronics sells and supports. This compensation will be considered an “adder” to the technician’s hourly base pay and will be noted on the associated Personnel Action Form. It will be the department manager’s responsibility to monitor the technicians’ qualifications for any associated certificate/license compensation and submit the appropriate forms to Human Resources for salary adjustment (with a certificate/license copy). Technicians certified in NICET Fire Alarm, Levels 1 and 2 must present proof of maintained certification on an annual basis. Failure to maintain any compensated certification or license that requires yearly renewal or re-certification will result in deducting the associated per hour “adder” from the technician’s rate until the certification/license is regained. Certification

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may be considered a “requirement” under certain job descriptions, without consideration for additional compensation. Accepted licenses/certificates are as follows: NICET Low Voltage Audio Certificate, Level 1 NICET Low Voltage Audio Level 2 NICET Fire Alarm, Level 1 NICET Fire Alarm. Level 2

6.0 Element Minimum Requirements

Basic Elements (Entry Level) Minimum Requirements

Page/Party (Including Interfaces) Two hundred (200) bench repair hours, including a minimum of ten (10) hours total on the repair of previous tone generators and telephone interfaces. Six (6) field service visits (minimum 3 start-up visits and 3 troubleshooting visits)

Electro-Sound II Fifteen (15) bench repair hours, including a minimum of eight (8) hours combined power source/interface hours (station repair hours can count towards Centra P/P II element requirements)

Industrial Telephone Eighty (80) bench repair hours on GTC or DAC

Central Amplifier Three (3) field service visits

Call-Talk Forty (40) bench repair hours

Intermediate Elements Minimum Requirements

Centra Page/Party II One hundred and twenty (120) bench repair hours and four (4) field service visits (minimum 2 start-up visits)

Emergency Telephones One hundred (100) bench repair hours

SmartSeries / ADVANCE Support Sixteen (16) hours training and (6) field service visits

Rigcom / E-Z Page Thirty (30) bench repair hours

Low Complexity Customized Products Forty (40) bench repair hours and three (3) service visits supporting systems that include low complexity customized products (can be counted with standard product visits)

Intrinsically Safe / Clean Room Telephones

Thirty (30) bench repair hours combined

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Customer Training Seminar Two classroom training classes that cover operation and maintenance of GAI-Tronics related products and systems.

LE100/LE200/LE300 Two start-ups involving any LE part listed with 4 hours training

Advanced Elements Minimum Requirements

GTC/GTL Smart Phone Eight (8) training hours, forty (40) bench repair hours

Telephone Management Application (TMA)

Sixteen (16) training hours and three (3) system configurations

Elemec Plus Formal training and two (2) start-up service visits

VoIP Telephones General VoIP training class plus two (2) customer start-ups

Six Channel Radio/Couplers Eighty (80) bench repair hours and two (2) field service visits

Telephone PBX Formal or informal training and (2) start-ups that require termination and programming

High Complexity Customized Products Forty (40) bench repair hours and three (3) field service visits supporting systems that include high complexity customized products (can be counted with standard product visits)

GTC RF Systems / DataCom / Sircom Formal training and two (2) field service visits

Fiber Optic Cable Terminations / Troubleshooting

Certified training program and two (2) field service visits where fiber optic cable terminations are performed

RF Speakers / Broadcast Module Two (2) start-up / programming visits

Audio Messenger Interface Three (3) customer configurations requiring customized tones or speech and two (2) start-ups

AMI Redundant Controller Module Two (2) start-up visits with Direct responsibility

Note: 1. All field service must be performed as a solo visit or a joint visit not considered as training.

2. Formal training can be provided by an experienced GAI-Tronics technician.

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SERVICE TECHNICIAN STATUS REPORT

NAME:

DATE:

TITLE:

ELEMENTS COMPLETED TO DATE:

Basic Elements Advanced Elements

Page/Party GTC/DAC Smart Telephone

Industrial Telephone Telephone Management Sftwr

Central Amplifier Elemec +

Call-Talk VoIP

ElectroSound II Six-Channel Radio

PBX Programming

Intermediate Elements High Compl. Custom Prod.

Centra Page/Party II GTC RF/ DataCom/Sircom

LE100/LE200 Line Ext. AMI / ACC2500

Emergency Telephone F.O. Cable Term./Trblshtg.

Intrin. Safe/Clean Room Tel Service Sales

SmartSeries/ADV. Support AMI Redundant Control Module

Customer Training Seminar

Rigcom/EZ Page

Low Compl. Custom Prod.

Microprocessor Elements

Smart Series Repair ADVANCE Sys. S/U, Lvl 1

ADVANCE Sys. S/U, Lvl. 2 Card Rack Setup

Card Rack Configuration MCU Configuration

MCU Formatting System S/U Tool (SST)

System Configuration (SST) System Trblshtg., Lvl. 1

System Trblshtg., Lvl. 2 UL Fire Approved Systems

Networked Sys. & Config. Network System Start-up

Smart Status

CERTIFICATION CREDITS: RENEWAL DATE

FCC GENERAL LICENSE N/A

N.I.C.E.T. LOW VOLTAGE AUDIO, LVL. 1 N/A

N.I.C.E.T. LOW VOLTAGE AUDIO, LVL. 2 N/A

N.I.C.E.T. FIRE ALARM SUB-FIELD. LVL. 1

N.I.C.E.T. FIRE ALARM SUB-FIELD. LVL. 2

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Disciplinary Program

Enforcement of the company rules is the responsibility of all supervisors, managers, and group leaders. Violation of the Company rules is adequate cause for discipline. The standard progression of discipline is as follows:

Counseling (If deemed applicable) In most cases of misconduct or poor performance, an employee's supervisor will meet with the employee to discuss the inappropriate behavior or performance problem. The supervisor will review the workplace rules and standards. If appropriate, the supervisor will arrange for additional training. A plan or objectives to improve the employee's conduct or performance will be put in place where appropriate.

The supervisor may refer the employee to the Employee Assistance Program.

Verbal (Oral) Warning The exact problem will be stated to the employee accompanied by a written memorandum documenting the discussion, which is added to the employee's personnel file.

Written Warning A written warning will be placed in the employee's personnel file.

Suspension The employee will be suspended for a specified number of days without pay. Documentation of the suspension will be placed in the employee's personnel file.

Discharge Human Resources ordinarily will be involved prior to the approval of a termination.

Violation of the following rules will be cause for the disciplinary action described above:

a. Violation of written or verbal safety rules or common safety practices (including failure to wear PPE, operating equipment in an unsafe manor, or bypassing safety features).

b. Running, scuffling, throwing of articles, horseplay or disorderly conduct of any kind.

c. Failure to report occupational injury promptly to supervisor.

d. Contributing to unsanitary conditions or poor housekeeping, or eating at workstations.

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e. Smoking in unauthorized or restricted areas.

f. Other actions not warranting immediate dismissal.

All supervisors, managers, and group leaders share in the commitment to a safe workplace. Any failure by a member of management to this responsibility will result in disciplinary actions as described above.

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Access to Medical Records

1.0 Definitions

"Employee exposure record" means a record containing any of the following kinds of information:

Environmental (workplace) monitoring or measuring of a toxic substance or harmful physical agent, including personal, area, grab, wipe, or other form of sampling, as well as related collection and analytical methodologies, calculations, and other background data relevant to interpretation of the results obtained;

Biological monitoring results which directly assess the absorption of a toxic substance or harmful physical agent by body systems (e.g., the level of a chemical in the blood, urine, breath, hair, fingernails, etc.) but not including results which assess the biological effect of a substance or agent or which assess an employee's use of alcohol or drugs;

Material safety data sheets indicating that the material may pose a hazard to human health; or in the absence, a chemical inventory or any other record which reveals where and when used and the identity (e.g., chemical, common, or trade name) of a toxic substance or harmful physical agent..

"Employee medical record" means a record concerning the health status of an employee which is made or maintained by a physician, nurse, or other health care personnel, or technician, including: medical questionnaires, results of medical examinations, medical opinions, first aid records, description of treatments, employee medical complaints, etc. 2.0 Retention & Access

Employee medical records are maintained by Human Resources for the duration of employment plus 30 years. Employee exposure records are maintained by Human Resources for 30 years.

Whenever an employee or designated representative requests access to a record, access is provided in a reasonable time, place, and manner. If access cannot be provided to the record within fifteen (15) working days, Human Resources will within fifteen (15) working days apprise the employee or designated representative requesting the record of the reason for the delay and the earliest date when the record can be made available.

Copies of records are provided at no cost to the employee.

Whenever access is requested to an analysis which reports the contents of employee medical records by either direct identifier (name, address, social security number, payroll number, etc.) or by information which could reasonably be used under the circumstances indirectly to identify specific employees (exact

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age, height, weight, race, sex, date of initial employment, job title, etc.), Human Resources will remove personal identifiers before access is provided. If removal of personal identifiers from an analysis is not feasible, access to the personally identifiable portions of the analysis will not be provided.

Upon request, Human Resources will provide representatives of the Assistant Secretary of Labor for Occupational Safety and Health (OSHA) prompt access to employee exposure and medical records and to analyses using exposure or medical records. 3.0 Trade Secrets

Trade secret disclosure follows the requirements of OSHA 29 CFR 1910.1020 (f). 4.0 Employee Rights of Access & Transfer of Records

Upon an employee's first entering into employment, and annually thereafter, current employees are informed of the existence, location, and availability of any records covered by this section; the person responsible for maintaining and providing access to records; and each employee's rights of access to these records.

If GAI-Tronics ceases to do business, all records subject to this section will be transferred to the successor employer. If there is no successor employer to receive and maintain the records, or intends to dispose of any records required to be preserved for at least thirty (30) years, the records will be transferred to the Director of the National Institute for Occupational Safety and Health (NIOSH) if so required by a specific occupational safety and health standard.

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Injury/Illness Recordkeeping

Program-GAI-Tronics Corporation Effective Date

Injury/Illness Recordkeeping 08/22/2012

General

GAI-Tronics Corporation acknowledges the importance of an effective record-keeping of injuries, illnesses and fatalities. Our Company recognizes the importance of tracking, implementing and maintaining active, up-to-date information. Upon request by an authorized representative, GAI-Tronics Corporation has to produce accurate records of injury/illnesses, fatalities.

All data pertaining to injuries or illnesses that does not require medical treatment or was otherwise not recordable on the above-mentioned documents will be maintained in written form. This includes first aid treatment, of any kind. All injury and illness documentation and records will be reviewed on a regular basis by Management, to analyze occurrences, identify developing trends, and plan courses of corrective actions.

Guidelines

1. Our Company must record injuries and illness that are:

a. Work-related, b. New, and c. Meet the following criteria:

1. Death 2. Days away from work 3. Job transfer or restricted work 4. Medical treatment beyond first aid 5. Significant injury, as diagnosed by a physician or other

licensed health care professional

2. Each recordable injury/illness is entered on an OSHA 300 Log and 301 Incident Report or other equivalent form within seven (7) calendar days of receiving information that a recordable injury or illness has occurred.

3. At the end of each calendar year, our Company reviews the OSHA 300 Log, verify entries as complete and accurate, and creates an annual summary of injuries and illnesses (OSHA 300-A). A Company Executive must certify that he or she has examined the OSHA 300 log, and that he

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or she reasonably believes, based on his or her knowledge of the process by which the information was recorded, that the annual summary is correct and complete.

4. After the Company Executive certifies the Summary by signature, a copy

of the annual summary is posted in each establishment in a noticeable place where information to employees are customarily posted and not altered, defaced or covered by other material.

5. The annual summary must be posted no later than February 1 of the year

following the year covered by the records and the posting is kept in the designated place until April 30th. This posting is currently located on the Human Resources Bulletin Board in the employee lunchroom, is easily visible to all employees, and cannot be altered, defaced or covered by other material.

6. OSHA 300 Log, other equivalent form, the Annual Summary, and the OSHA 301 Incident Report forms must be retained by the Human Resources Department for five (5) years following the end of the calendar year that these records cover.

7. Safety goals and OSHA updates are posted regularly throughout the year on the GAI-Tronics Intranet under GAI-Tronics’ News, which is also played at scheduled times throughout the day in the lunchroom, as well as posted inside the employee entrance.

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Hazard Identification and Risk Assessment

1.0 Purpose

To provide guidelines for identifying, assessing and controlling workplace hazards;

To ensure the potential hazards of new processes and materials are identified before they are introduced into the workplace;

To identify the jobs/tasks which require risk assessment.

2.0 Key Responsibilities

As specified within this program, GAI-Tronics Corp. must assess a work site and identify existing or potential hazards upon arrival at the work site. 3.0 Hazard and Risk Identification

The hazard identification process is used for routine and non-routine activities as well as new processes, changes in operation, products or services as applicable. The Service Manager and/or Service Technician shall conduct a baseline worksite hazard assessment which is a formal process in place to identify the various tasks that are to be performed. The results are included in a report of the results of the hazard assessment and the methods used to control or eliminate the hazards identified. The hazard assessment report must be signed and dated. Inputs into the baseline hazard identification include, but are not limited to:

Scope of work Legal and other requirements Previous incidents and non-conformances Sources of energy, contaminants and other environmental conditions that

can cause injury Walk through of work environment

Hazards identifications (as examples) are to include:

Working Alone Thermal Exposure Isolation of Energy Noise Exposure Musculoskeletal Disorders Blood Borne Pathogens General Safety Precautions And any other established policy or procedure by GAI-Tronics Corp. Any other site specific work scope

GAI-Tronics Corp. has a formal process for identifying potential hazards. Processes are in place to identify potential hazards by the use of JSA's and/or facility wide or area specific analysis/inspections.

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All identified hazards are assessed for risk and risk controls are assigned within the worksite hazard assessment for that specific hazard. The GAI-Tronics Corp. program provides processes to ensure employees are actively involved in the hazard identification process and hazards are reviewed with all employees concerned. Employees are trained in the hazard identification process including the use and care of proper PPE. 4.0 Review of Hazard Assessment

Existing worksite hazard identifications are formally reviewed at reasonably practicable intervals to prevent the development of unsafe and unhealthy working conditions and specifically updated when new tasks are to be performed that have not been risk assessed, when a work process or operation changes or when significant additions or alterations to a job site are made. 5.0 Risk Assessment

Hazards are classified and ranked based on severity. The program identifies that hazards are classified/prioritized and addressed based on the risk associated with the task. (See the risk assessment matrix outlining frequency, likelihood and severity).

GAI-TRONICS CORP. RISK ASSESSMENT MATRIX

1 2 3 4 5

Frequency

Less Than Once per

Month

Less Than Once per

Week

Less Than Once per

Shift

More Than Once per

Shift

At All Times

Likelihood

Highly

Unlikely

Unlikely

Possible

Probable

Highly

Probable

Severity

First Aid

Medical

Treatment

Lost Time,

Full Recovery

Some

Permanent Impairment

Major

Permanent Impairment

or Death

6.0 Risk Controls/Methods to Ensure Identified Hazards Are Addressed and Mitigated

If an existing or potential hazard to workers is identified during a hazard assessment GAI-Tronics Corp. will take measures to eliminate the hazard, or if

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elimination is not reasonably practicable, to control the hazard. If reasonably practicable, GAI-Tronics Corp. will eliminate or control a hazard through the use of engineering controls. If a hazard cannot be adequately controlled using engineering controls, GAI-Tronics Corp. will use administrative controls that control the hazard to a level as low as reasonably achievable. If the hazard cannot be adequately controlled using engineering and/or administrative controls, GAI-Tronics Corp. will ensure that the appropriate personal protective equipment (PPE) is used by workers affected by the hazard. GAI-Tronics Corp. may use a combination of engineering controls, administrative controls, and personal protective equipment if there is a greater level of worker safety because a combination is used.

7.0 Emergency Control of Hazards

Only those employees competent in correcting emergency controls of hazards may be exposed to the hazard and only the minimum number of competent employees may be exposed during hazard emergency control. GAI-Tronics Corp. will make every possible effort to control the hazard while the condition is being corrected or under the supervision of client emergency response personnel in every emergency. 8.0 Job Safety Analysis (JSA)

For those jobs with the highest injury or illness rates, jobs that are new to our operation, jobs that have undergone major changes in processes and procedures or jobs complex enough to require written instructions will have a Job Safety Analysis performed. Completed JSAs are available from the Safety Manager. A. Training

All Field Service technicians will be trained on Job Safety Analysis, as follows:

Define components of a JSA

Understand the benefits of conducting JSAs

Select and prioritize jobs to analyze based on given factors

Discuss how JSAs are conducted through the breakdown, hazard identification, and controls

Complete a JSA

B. Definitions

Job A job is a sequence of steps or separate activities that together accomplishes a work goal

Safety Condition of being protected from injury, illness, or loss

Encompasses all that we do from an engineering, training, and performance standpoint to lessen risk

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Awareness Mindfulness Reduction Control

Analysis A separation of a thing into parts or elements of which it is composed

An examination of a thing to determine its parts or elements C. Job Safety Anaylsis

Can be defined as a procedure used to review job methods and uncover hazards

Overlooked in plant or building layout In the design of machinery, equipment, tools, processes Developed after production started Resulted from changes in work procedures or personnel

JSA is one of the first steps in hazard and accident analysis and in safety training

D. How Can JSAs Help our Safety Program?

Identification of hazards and control methods

Better understanding and knowledge of each job

Guide in new employee training

Periodic contacts and for retraining of senior employees

Refresher on jobs which run infrequently

An accident investigation tool

Higher quality and productivity

Discovery of possible improvements in the job methods

Employee involvement and improved safety attitude by providing input on their jobs

Preparation for planned job safety observations E. Four Steps of JSAs

1. Selecting the Job 2. Breaking Down the Job 3. Identifying Hazards and Potential Accidents 4. Developing Controls

Selecting the Job a. Risk Assessment b. Past Losses c. Concerns/Complaints d. An accident waiting to happen?

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Breaking Down the Job a. Select the right person to observe b. Brief the person on the purpose c. Observe the person performing the job and try to break it into basic

steps d. Record each step in the breakdown e. Check the breakdown with the person observed

Identifying Hazards - What can go wrong in the system? a. Struck by, struck against, or come in contact with an object b. Caught in, by, or between objects c. Slip or trip and/or fall d. Strain, sprain, or overexertion from lifting, lower, pushing, or pulling e. Exposure to environmental or health hazards – noise, dust, vapors,

fumes, etc.

Developing Controls – Hierarchy a. Complete redesign of the job b. Partial revision – engineering change c. Improve the individual job element d. Procedural review and administration

Change the work procedure – define what the employee should do and how it should be done

e. Other Administrative Controls f. Training g. Limit exposure time (e.g. – by rotation) h. Gradual break-in periods (for new hires) i. Provide extra breaks

9.0 Site Specific HSE Plan

Each work location may have a site specific HSE plan. Each employee reporting to a location shall receive a documented orientation from the job site safety representative that includes the SSSP for that site. The SSSP may contain the job site Health and Safety Policy, site specific safety requirements as well as a PPE matrix for that location, which GAI-Tronics Corp. has a responsibility to follow. 10.0 Review Process

The hazard assessment program will be reviewed to ensure no new hazards are derived from the corrective measures. The review shall include a management of change consideration as well.

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Company GAI-Tronics Corp. Original or Revision:

Plant Original Completion Date:

Department Field Service Revision Completion Date:

Operation

Description of Operation [Positions, Job Titles, Types of Specific Activities]: Field Service Technician Required PPE: Hard Hat, Safety Glasses, Safety Shoes

Analysis By:

Reviewed By:

Approved By:

STEP # STEPS Sequence of Basic Job Steps

HAZARDS Potential or Actual Job Hazards

CONTROLS Recommended Safe Work Procedures, Required PPE

1 Arrive at the job site Eye Injury from flying particulates

Head Injury from falling material

Foot/Toe Injury from falling objects

Safety Glasses

Hard Hat

Safety Shoes

2 Enter into high noise area Hearing Loss from noise exposure above 85dba

Hearing Protection

3 Work at elevated height Serious Injury from falling more than 4 ft

Fall Protection Harness

4 Enter into areas where flammable gasses or hot work may be present, and/or when required for site access

Burn Injury from fire Flame Retardant Clothing

5

6

7

Recommendations [include person(s) assigned and target dates]:

- JSAs are to be reviewed and approved by a supervisor or Person in Charge (PIC) prior to work commencing. Upon arrival to job site should any scope change, revise JSA and adapt changes including any new PPE requirement. - Stop Work Authority applies to all jobs

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Behavioral Based Safety (BBS) Program

1.0 Overview

Behavioral Based Safety is an approach to safety that focuses on a workers' behavior as a potential cause of work-related injuries and illnesses. Incident metrics are reviewed to determine the program objectives. BBS programs are a positive, employee-driven system of observation, feedback and problem solving that focus on improving safe practices and reducing the potential for work related injuries. Employees are expected to perform a given process in the safe manner in which they were trained to do so - EVERY time. Employees are expected to institute and maintain all safeguards required for the area, such as machine guarding or proper tool usage. If an observed action is categorized as “at-risk” the employee could be injured if they continue to perform the action in that fashion. A department manager or supervisor provides training to an employee for every job they are assigned to complete, before being assigned to the process. Specific requirements and conditions are identified as being necessary each time they are assigned in order to safely perform the task. Personal protection equipment (PPE) is issued to the employee, if required, for that work area or process. The employee is also made aware that their actions may be observed by a department manager or supervisor at any time to insure they are properly following the procedure as trained. Observations are performed by a trained department manager or supervisor. Observations are done per prescribed frequency in each department. For example, a department may have 15 processes that are observed; one process is observed randomly on a rotating basis. Observations are done on each shift to insure all employees are observed performing the process. Generally the observation is done unannounced but it is acceptable and possible that the employee knows they are being observed. 2.0 Creating a BBS Observation Form Check Sheet

The manager of a department creates a check sheet by selecting a process to be observed and listing the steps necessary to complete that process. The check list clearly defines what the safe expectations are for a process or work station. Typically at least 5 expectations are identified as the safe elements to be observed. A standardized form is created and used during each observation. (Refer to Behavior Based Safety Program Attachment A for guidance in writing your BBS expectations.)

3.0 Performing a BBS Observation

A manager or supervisor randomly selects a process to be observed in their department. He goes to the area where the process is being performed and randomly

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selects an employee to focus his observation on while they are performing the process. The observer is familiar with the required behaviors of the process and can determine the difference between a safe and at-risk action. Using the check list he observes the employee performing each step of the process listed and scores their action as either “safe” or “at risk” by placing a checkmark in the appropriate box per step.

Each step of a process is a potential opportunity for an employee to be injured if performed incorrectly. Job training and provided personal protection equipment are prerequisites to the employee performing the process. Based on a process’ written procedure, the observer is looking to proactively identify the safe and at-risk behaviors through the observation. The results are discussed with the employee as follows: First, the observer engages in a discussion with the employee that contains positive comments and reinforcement of safe behaviors. Next, at-risk behaviors are identified and discussed. Using open-ended questions, the observer is able to obtain feedback from the employee to explain their at-risk behaviors. The employee is reassured that no consequences will come to them for their comments. The employee feedback determines what additional training, mentoring, etc. is needed to assure the employee understands what an at-risk behavior is and knows how to apply the proper behaviors safely in the future. The steps to performing an observation are:

1. Select the process and employee to be observed and the respective Observation Check Sheet.

2. Record the date and employee name at the top of the Observation Check Sheet. 3. Use the check sheet to identify the expectations of the process and/or area to be

reviewed. 4. Observe the employee’s actions as they perform the process. 5. Indicate each action as “safe” or “at risk” on the check sheet by placing an “X” in

the appropriate box next to the observed expectation. 6. Repeat steps 3 - 5 for each listed expectation. 7. List all safety concerns and comments in the space provided at the bottom of the

form. 8. Review the results and determine if corrective actions are needed. 9. Discuss the results with the employee. Ask for feedback on their actions. 10. Compliment and reinforce identified “safe” observations. 11. Retrain, mentor and coach as needed to eliminate the “at risk” observations /

actions. 12. Follow up / repeat observation to insure implementation of corrective actions.

4.0 BBS Observation Data and Trend Analysis

The completed Behavioral Based Safety Observation forms are reviewed by the department manager. The department manager compiles a report based upon the

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number of observations completed and the percentage of safe observations. The department reports are then submitted to the Human Resources coordinator. The Human Resources coordinator combines the reports from each department. The combined report is distributed to upper management and to each department. Each department posts the monthly combined report as well as their individual department’s report. Month-to-month trends are compared by department on a line graph. 5.0 BBS Observation Action Planning

Observations and action planning are reviewed monthly by the department managers and the safety coordinator. At-risk behaviors are recognized and appropriate action plans are developed by them and prioritized based upon frequency and severity. Each action plan will include the individual(s) responsible for follow up as well as a timeframe for completion. Action plans are submitted to upper management for review and approval. 5.0 Training

All employees, managers and supervisors have received the appropriate training necessary to implement this program as outlined above. The program is to be reviewed as needed and updated (including additional training) based upon feedback received from observations and action plans.

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Observation Checklist Mark Safe or At-Risk for Each Item

Process / Work Station: Product Repair / Service Technician

Department / Operator’s Name: Service /

Date:

Expectation Safe At-Risk Employee wearing safety glasses when soldering

Employee wearing protective clothing for soldering

Employee using correct test fixture/test procedure for product.

Employee plugging test fixture into GFI.

Employee testing product within reach at table height or above.

Employee positioning test equipment within reach at table height or

above.

Employee setting up test leads and cables to prevent damage, twisting,

fraying, and not using damaged items.

Employee disengaging power following test of product.

MSDS identification on all chemicals at workstation.

Absence of food or drink at workstation.

Safety Concerns or Comments:

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Behavioral Based Safety Action Plan

Date Assigned Action Due Date Responsible

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ATTACHMENT A

Behavioral Based Safety Program

Writing SMART (Specific Measurable Actionable Reliable Tangible)

Expectations

The Rules: 1. What can be directly observed can be objectively defined.

2. What can be objectively defined can be accurately measured.

3. What can be accurately measured can be effectively managed.

Specific: Describes what will happen, who will do it, and when it will be done.

Assumes nothing.

Written as if it is intended for someone completely unfamiliar with the activity.

Usually is context dependent.

Not Specific: “Look both ways at intersections.”

Does not say who is expected to do it.

Does not say when it will be done.

Does not say how it will be accomplished.

Specific: “The driver looks to the right, then left, then back to the right before the vehicle leaves a

stopped position at intersections.”

Says who should do it.

Says when it should be done.

Describes how it will be done.

Measurable:

Is directly observable.

The behavior or condition occurs under normal operating circumstances.

Special circumstances are not required to observe the behavior or condition.

Not Measurable: “The driver activates flashers when stopped in the emergency lane.”

Observer must be present when an emergency is in progress.

By definition, an emergency does not occur under normal operating circumstances.

Measurable: “The driver can describe two procedures that should be followed in emergencies; (move the

vehicle into the emergency lane and activate the flashers).”

Active:

Will not exist without action taken by someone.

Cannot be accomplished by a dead body or a rock.

The behavior or condition is under the control of the person responsible for seeing that it exists.

Stated as a positive act, the expectation describes what is to be done vs. what is not to be done.

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Not Active: “The driver does not dangle his/her hand out of the window of the vehicle.”

Describes an unwanted behavior/condition.

Does not describe what is expected to be done.

Active: “The driver keeps his/her hands positioned at 10 o’clock and 2 o’clock on the steering wheel

when not shifting gears or operating other vehicle controls.”

Requires someone to DO something.

Will not occur without someone doing something.

It is stated objectively as a positive act.

Reliable:

Is objectively defined.

Two or more observers will draw the same conclusion about what is being observed.

Does not require a value judgment by the observer.

The Expectation will not contain ambiguous adverbs or adjectives. (e.g. quickly, slowly,

properly, adequately, safe, unsafe, etc.)

Making reliable observations does not preclude the use of instruments where necessary.

Not Reliable: “The driver maintains an adequate following distance for the vehicle speed of travel and

roadway conditions.”

Requires the observer to make a judgement.

As stated, it describes a hope but not an Expectation.

Reliable: “The driver follows the vehicle ahead by:

8 seconds on dry pavement

16 seconds on wet pavement

24 seconds on snow or ice.”

The observer can time the following distance using stationary objects beside the roadway.

The expected behavior is clear, objective, and repeatable.

Tangible:

Capable of being appraised.

Anything other than a “yes” is a “no”.

A “yes” always indicates that the desired or expected condition or behavior was observed.

The observation has a beginning and an end.

Not Tangible: “The driver always maintains engine speed at or below 5000 Rpm’s.”

In this example, of a constantly fluctuating indicator of performance, what constitutes an

observation may not be clear to the observer or the observee.

The word “always” infers more than is possible to observe.

Tangible: “The driver shifts gears when the engine speed is between 3000 and 5000 Rpm’s.”

The point at which the expected behavior or condition should occur is defined.

Multiple observations are possible without a continuous observation being necessary to answer

“yes” or “no”.

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SMART Language:

They may be…. Watch for…. Because they….

Adverbs

A word used to modify a verb, adjective,

or another adverb.

They indicate, usually, to an indeterminate

degree, amount, direction, place, time,

manner, belief, doubt, or rate to the term

they are used to modify

Words that end in “ly”

Words that seem to enhance

the statement but do not

change the meaning.

Words for which a number

could be substituted.

Seem to make the statement

more specific but in fact do

just the opposite.

Impart a need for judgment

on the part of the observer.

Compromise reliability.

Create opportunity for

emotional static.

Adjectives

A word used to modify or qualify a noun

or pronoun in one of three forms of

comparative degree: POSITIVE: e.g.

“strong” COMPARATIVE: e.g. “stronger”

SUPERLATIVE: e.g. “strongest”

Problematic adjectives are usually those

that are comparative or superlative.

Positive adjectives may be necessary to

make the statement explicit (e.g. “the

yellow line”)

Words that end in “er” or

“est”.

Words for which a number

could be substituted.

Words that require the

reader to make a judgment.

Seems to make the

statement more specific but

in fact do just the opposite.

Impart a need for judgment

on the part of the observer.


Create opportunity for

emotional static.

Absolutes

Words that indicate freedom from restraint

or limitation.

They have no restriction, exception, or

qualification.

They may be adverbs or adjectives.

“All”, “always”

“None”, “never”

Are not measurable.

Are not tangible.


Infer what cannot be stated

as fact.

Negatives

A proposition by which something is

denied or contradicted.

Something that is the opposite of

something else.

Note that “No” can be used as a function

word to introduce an explicit statement.

(e.g. “There are no objects on the stairway

landing?”)

“Does not”, “is not” Are not active

Can be accomplished or

achieved without any action.

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Management of Change

1.0 Commitment

GAI-Tronics Corporation is committed to the Health and Safety of its employees and the communities where it operates. We will operate under sound environmental practices and will conduct our operations in compliance with all applicable laws, regulations and standards. 2.0 Management Expectations

All employees are individually responsible / accountable for self, coworkers and community when it comes to safety. All personnel by actions and example will strive to ensure a safe work place. All personnel respect the communities and areas we work in, through compliance and environmental awareness. 3.0 General

The management of GAI-Tronics Corporation has established Management of Change (MOC) procedures to identify and control hazards associated with change and maintain the accuracy of safety information. Although some changes may be minor with little likelihood of compromising safety or environmental protection, all changes may have the potential for disruption, injury, or business loss. 4.0 Changes in Facilities or Equipment

While on-site, the GAI-Tronics Corporation field service technicians will only execute Replacement-in-Kind changes, which are close replications of existing components or functions that are highly unlikely to produce adverse effects. GAI-Tronics Corporation’s scope of work covers the Emergency Notification System only. For manufacturing changes, see Attachment A - Engineering Change Notice Procedure. For Health, Safety & Environmental Policy/Procedure Change Notice (HCN) System, see Attachment B. 5.0 Changes in Personnel

GAI-Tronics Corporation’s management fully recognizes their field personnel working offshore do so on an as-call basis for limited periods of time (generally

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one week or less). Thus there is no MOC process required for normal and routine changes in personnel due to rotation or shift. Uncontrollable changes in personnel will be addressed and a suitable qualified replacement will be agreed upon should the need arise. For Personnel changes within the Field Service Organization, see Attachment C – Personnel Change Notice Procedure. A PCN is required in addition to the Separation Process, described below. For general personnel changes within GAI-Tronics Corporation no PCN is required. When an assignment ends, whether voluntary or involuntary, responsibility is transferred to the next level up in Management and the Separation Process is completed, as follows:

Human Resources receives notice of separation

Letter to employee explaining items that require immediate attention

Separation information provided for benefits

Confidentiality Agreement

Supervisor Checklist

HR Checklist

HR schedules a time to meet with employee prior to exit date

HR goes over items listed

Supervisor meets with employee and receives returned items per list

Access card to building is turned off

File is removed and termination process begins with SAP All new hires at GAI-Tronics Corporation are subject to the following New Hire Process:

Candidate is selected after interview process

Offer letter is presented to candidate

Upon acceptance of offer and signed consent forms, HR coordinates background screening, pre-employment physical and drug testing

Pending successful completion of screenings, HR continues with hiring process. Which includes completion of new hire paperwork, policies, procedures and new hire orientation

Provide copy of handbook and policies and procedures

HR continues new hire process in SAP In addition to the GAI-Tronics Corporation New Hire Process, all new Field Service Technicians (whether new hire or internal transfer) are subject to the following programs outlined within the Field Service Safety and Environmental Policy, including but not limited to:

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1. Short Service Employee Mentoring Program

2. Skill Compensation Plan

3. Technician Off-Shore Certification Requirements, to include:

1. BOSIET

2. SafeGulf Training

3. TWIC® Card

4. Gulf Coast Safety Council – Basic Orientation Plus Safety Training

ATTACHMENT A Guide for Originating an ECN

127

The originator of ECN must provide the following minimum required information on the form:

Step by Step instructions follow:

Step 1: Date - Enter date ECN is written. Step 2: Page of : List the page and total number of pages, the ECN consists of by using the follow format: -i.e: Page 1 of 2, Page 2 of 2, etc. Step 3: Originator: Person or Persons who are writing the ECN. Use complete name, never initials. Step 4: Notice Type: Indicates urgency of ECN.

1 = Immediate Change. Changes needed to production already in process. Change is effective immediately. 2 = Changes to be incorporated into the next scheduled work order. 3 = The Effective date and/or drawing due dates will be determined by ECN Coordinator, with input from Scheduling & ECN Committee members 4 = Only used to correct “typo errors” only on drawings.

Step 5: Priority – When should we process the ECN, is always linked to Notice type.

Immediate - Must be Notice Type 1 or Notice Type 2. ECN is walked around for signatures immediately, instead of waiting for next meeting. Next Meeting - Will be presented at next scheduled ECN committee meeting, each Wednesday.

Step 6: Single or Multiple Effectivity: Select "Multiple Effectivity" only, if ECN has multiple BOMs that must go into effect on different dates; otherwise, select Single Effectivity..

GAI-TRONICS

ENGINEERING CHANGE NOTICE

ECN#: Date: / /

Step 1

Page of Step 2

Originator: Step 3

Notice Type:

1 2 3 4

Step 4

Priority: Immediate Next Mtg

Step 5

Single Effectivity: Multiple Effectivity

Step 6


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Step 7: BOM No./Dwg Changed: List all BOMs and/or Drawings to be changed. (If list is too long, see ECN coordinator). (Status 12, 15, 20, 25, 30, 32, 34, 35, 50, 51, 55, 60, 70, 80 are valid).

Notes: If this change is also required for any BOM at status 10 or 11, please list the BOM P/N in the Comments section,it will then be checked and/or changed when the ECN is processed. If not entered under comments, it is very likely the BOM will not be updated. Status 14 product must be changed using a PPECN. Codes do not require or use ECNs.

Step 8: Description of changed item: List SAP description of each item being changed. If a family series is being changed, a general description is permitted. If a drawing is being changed, enter the drawing’ title, (from the title block of the drawing) Example: Emerg. Tel., Flush-mount, Single Button Or if family series

i.e. Ephone Flushmount Series Drawing: Assembly drawing for 13314-003 Hazarous driver.

Step 9: Where Used: If a single-level where used list has three (3) valid items or less, please list the items in this area. If list of where used is longer than three (3) items, you must attach a where used list. Use SAP T-Code ZCS15 for a single-level where used list. Only obsolete (status 85) items do not need to be listed, but can appear on any attached lists. Step 10: Product Line Affected: List general description of product line affected by ECN.

i.e. Navigator Series, or Handset Emergency Phones

BOM No. / Dwg Changed: Step 7

SAP Description of Item Listed Above: Step 8

Where Used: Step 9

Product Line(s) Affected: Step 10

Is this part, bill of material or drawing used in or with any agency approved products? Yes No Step 11

Does change affect other Hubbell Div.? Yes No Step 12

Is changed item a configured product? Yes No

Step 13

Sales Literature Revision

Step 14

No

Yes

Manual Revision:

Step 15

No Yes

Related Notice(s):

Step 16


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Step 11: Is this part, bill of material or drawing used in or with any agency approved products? Yes / No – You must first do a multi-level where used in SAP to find all Products effected by the ECN. Then check to see if any of those products appear in the Agency Device Key spread sheet. If any effected products are found in the Agency Device Key spread sheet, then you must check Yes for agency approved products. Otherwise check No. See GTC Intranet / Engineering/ Agency Approval Listings/Agency Device Key for the spread sheet.. You may cut and paste the URL listed below in your browser to access the spread sheet. http://gtcintranet/eng/Agency%20Approval%20Listings/AgencyApprovalListingsTable.htm

This spreadsheet will allow you to search for any product that has an agency approval. Please be aware that you must be careful in your search. For example: a 701-204TR may not be listed BUT the 701-204* will be listed. The * indicates a series that has been approved.

Step 12: Does change affect other Hubbell Div? Yes / No. - Check yes only when this change will effect product we receive from other Hubbell Divisions. (i.e. Killark). Otherwise check No. Step 13: Is changed item a configured product?: Yes/ No. - Very few items are "Configured" products. See Basic Data 2 Screen, under Client specific configuration and checkbox for "Material is configurable", if this ECN affects any configured products, check Yes. Otherwise, check No. Please see ECN coordinator if there are any questions or doubt as to whether your request falls under this requirement. Step 14: Sales Literature Revision: Yes/ No - does any Sales literature need to be revised by marketing? Step 15: Manual Revision: Yes / No - do the manuals associated with affected products need revision due to your ECN? (That means you should not forget to review the manuals to determine if they should be revised along with the other changes on your ECN). Note: Assembly Drawings are commonly included in manuals. Step 16: Related Notice(s): List any other related action items (or forms) that may need to be coordinated with this ECN. Related action items can be other ECNs, PPECNs, TPDs, CCRNs, P/Os, etc. Step 17: Specific Reason for Notice: List only the “WHY” (real reason) of “why should we do this” and NEVER the “WHAT” of “what is being changed” All of the “WHAT” is always specified on Page 2 (or higher) of the ECN.

Specific Reason for Notice:

Step 17

Comments:

Step 18

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Step 18: Comments: For General comments. In this area, list Status 10 and 11 BOMs that also require change; so they will not be overlooked. Explain if anything special needs to be done, as the result of the ECN; this includes any coordination of other activities, forms processes, etc.

Compliance Engineer Initial Review section. Please Skip - (Not for use by anyone other than

Compliance Engineer).

Step 19: Material Disposition The originator must determine if anything should be scraped, and/or if anything needs to be re-worked, because of this ECN. If so, check the appropriate boxes and specify the appropriate P/Ns, (to be either scrapped and/or reworked).

MATERIAL DISPOSITION

Include Part Number and Qty Include Part Number and Qty

Rework Yes No

Part #:

Scrap Yes No

Part #:

Skip the rest of page 1 and go directly to page 2. Page 2 Step 20: Item being Changed - List BOM(s) and/or drawing numbers being changed. You should use the acronym BOM or DWG before any listed numbers. Only if the “exact same BOM changes” are being done to a list of BOMs, you may enter the list of BOMs in one cell of " Item being Changed" box, otherwise only enter one entry per box. Drawing numbers will only be one per box.

i.e. BOM 69447-001 or dwg 74247

Step 21: Dwg Rev – Enter the current revision level of drawing being changed. (Only applies to drawing, leave blank if BOM change). Step 22: Specific Description of Change – This is where you enter the details & description of what is being changed. The clearer you can be in this section, the lower probability of an error occurring.

Item Being Changed

Dwg Rev. Specific Description of Change

Step 20 Step 21 Step 22


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For BOMs: CHANGE, ADD or DELETE are the key operative words that should appear at the beginning of entries in this section, (as appropriate for the change). See examples below. CHANGE: 47552-002, “RES ME 0805 1/10W 1% 20.0K-OHMS 7"REEL-A”, From 20 pcs To 18 pcs and Delete Ref Des R1 and R2. CHANGE: 47551-004, “RES ME 0805 1/10W 1% 1.00M-OHMS 7"REEL-A”, From 7 pcs To 9 pcs and Add Ref Des R1 R2. Or DELETE: 4 pcs 18105-005, “CHOKE PWR 6.8mH”, Ref Des L1, L2, L3, L4 ADD: 4 pcs of 18105-002, “CHOKE PWR 150uH” Ref Des L1, L2, L3, L4 For Dwgs: Descriptions of changes tend to be more free form, depending on the nature of the drawing change. Be as clear and descriptive as you can. The “mark ups”, “text changes” or “other identified changes”, that are shown on the attached (marked up) drawings should always use the same wording written on the ECN form as you would like to see on the revised drawing. i.e. Revise note 1 to read as follows:

1. STANDARD "G-STYLE" INJECTION MOLDED ABS 20% CARBON FILLED (ELECTRABLEND CF20 BK) ONE PIECE HANDSET WITH RECEIVER AND TRANSMITTER CAPS. THE TRANSMITTER AND PRESSBAR ARE BLACK ABS (CYCOLAC MG47, COLOR CODE XS10208).

Don’t forget to attach marked up copies of all drawings being changed, showing exactly how you want them changed. You may call or email to request an ECN number from the ECN Coordinator. Once you have an ECN number, please enter it on the top right of page 1, next to the “ECN#:” before submitting it. If you have completed all of the originator’s responsible areas as outlined in this document and, if necessary, attached marked-up drawings, you are now done and may submit your ECN to the ECN Coordinator.

ATTACHMENT A ECN Procedure

GAI-TRONICS CORPORATION PROCEDURES MANUAL

Procedure 2.6, Engineering Change Notice (ECN).

Revision 3, Effective 02/10/12.

Approval: T. Moran – Engineering Project Manager

Printed copies are uncontrolled.

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1.0 PURPOSE / SCOPE

The procedure describes the process for the review and approval of changes to released bills of

material and released engineering drawings. (Reference Procedure 2.5, Engineering

Documentation)

2.0 RELATED DOCUMENTS

Procedure 2.5, Engineering Documentation

Procedure 2.13, Quality Records

Procedure 5.3, Part Status

Procedure 5.4, Agency Approval

Procedure 7.3, Production Rework.

Form 5, Engineering Change Notice

3.0 DEFINITIONS

4.0 PROCEDURE

4.1 General

4.1.1 Requested design changes are noted on an Engineering Change Notice (ECN) Form. An

ECN may contain more than one change per part number, or the same change on multiple part

numbers.

4.1.2 The ECN Coordinator has responsibility for tracking the status of all open ECNs.

Personnel involved with ECN review, approval and implementation activities are responsible for

providing timely status information to the ECN Coordinator.

4.2 Initiation

4.2.1 Anyone may initiate an ECN. The originator has responsibility to evaluate the proposed

change, its effects and to provide complete accurate information on the submitted ECN

form. The originator is required to determine and specify if the ECN affects or is

associated with any agency approved products. The originator shall make

recommendations about rework and material scrap, on the appropriate sections of the

ECN form. Any items requiring rework or scrap shall be listed on the form by P/N and

include recommended effected quantities. It is recommended that the originator follow







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the ECN through the approval process, in order to provide additional information as

needed and to ensure successful implementation. The Agency Device Key, described in

Procedure 5.4, is used to determine the approval status of products.

4.2.2 The ECN Coordinator reviews the form for completeness.

4.2.3 The ECN Coordinator assigns a number to the ECN.

4.2.4 The ECN Coordinator assists the originator in assigning a priority type to the ECN.

There are 4 types:

Type 1: the requested change is needed to complete production of work orders in progress.

Type 2: the requested change should go into effect upon approval.

Type 3: the requested change may go into effect as determined by the ECN Coordinator,

depending upon availability of new materials and/or the depletion of current

materials.

Type 4: the requested change does not change how materials are purchased or how

product is built. It is generally used to change typographical errors on drawings

or bills of material. Drawings will carry a new revision, but bills of material will

not have a visible effectivity in the BOM database.

4.2.5 All ECNs are provided to the Compliance Engineer for initial agency impact review. The

Compliance Engineer will specify if the ECN requires agency notification or approval

prior to completion of the ECN.

4.2.6 For ECNs where scrap has been identified, the ECN coordinator shall complete a Scrap

Form in accordance with the corporate Scrap Procedures. The Scrap form shall be affixed

to the ECN prior to Review. The scrap form(s) shall remain with the ECN until after the

effectivity date of the ECN. After the ECN has gone into effect, the scrap form(s) shall

be submitted to the Scrap Coordinator.

4.3 Review

4.3.1 ECNs are reviewed and approved by the ECN Committee members. The committee

consists of representatives from Engineering, Production, Quality Assurance, Scheduling,

and Purchasing. To review and approve ECNs in a timely manner, the ECN committee

will meet regularly. Engineering is responsible for scheduling and conducting the

meetings.







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4.3.2 The ECN Committee will obtain or request additional information, as necessary, to

provide a complete review of the effects of the requested change. Each representative

evaluates the effect of the change on their department’s activities and on operations as a

whole. The following items, in particular, must be addressed:

technical merit of the change;

costs associated with the change;

effect on agency approvals;

effect on sales and installation literature;

effect on upper and lower level parts;

effect on material on order and in stock and the effect on work in process;

parts added to bills must conform to valid part status relationships (Reference

Procedure 5.3, Part Status).

4.3.3 If the committee makes any changes to the ECN, the changes must be dated and initialed

on the ECN Form; the originator and Compliance Engineer must be informed.

4.4 Approval

4.4.1 ECN Committee representatives note their approval of an ECN by initialing and dating

the ECN. If subsequent changes are made to the ECN, approvals must be obtained again.

4.4.2 If an ECN requires agency notification or approval, the ECN will not be completed and

will be put on agency hold until such notification or approval has been received in

writing by the Compliance Engineer from the required agency. Copies of approval letters

will be attached to the corresponding ECN.

4.4.3 When ECN Committee representatives determine that they will not approve an ECN,

reasons for rejection must be documented and transmitted to the originator and the ECN

Coordinator. The originator may provide additional information or make changes to the

ECN and resubmit it for consideration.

4.4.4 If the ECN Committee and the originator cannot come to agreement over the ECN, then

the ECN may be elevated to appropriate department managers for resolution.







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4.5 Implementation

4.5.1 The ECN Coordinator sets an effectivity date for the ECN. For some ECNs the actual

effectivity date is not initially known. In these cases, a projected effectivity date is

determined. The ECN Coordinator monitors these dates and adjusts as necessary until

the ECN is closed. The ECN Coordinator informs Scheduling to re-explode work orders

and verifies that the ECN has been applied correctly.

4.5.2 ECNs that affect an agency approval may be implemented to the extent necessary to

provide revised documentation for submittal to the agency. These ECNs are not

implemented in production until the change has been approved by the agency. The

effectivity date must be set beyond the receipt of approval.

4.5.3 Necessary rework is implemented as described in Procedure 7.3, Production Rework.

4.5.4 BOM changes and associated effectivities are entered by the ECN Coordinator.

4.5.5 Documentation changes are forwarded to Engineering, with an effectivity date.

4.5.6 Representatives are responsible for implementing the change as it relates to the activities

of their departments.

4.6 Closure

4.6.1 ECNs can only be closed after meeting all of the applicable simultaneous conditions

specified below:

4.6.2 ECNs that affect material in any way or include a BOM change and have a known

effectivity date shall not be closed or completed until the effectivity date has passed.

4.6.3 ECNs for drawing changes are closed after the ECN Coordinator receives the issued,

revised drawing.

4.6.4 Any ECN requiring prior agency notification or approval can only be closed once written

agency approval has been received, all material issues are resolved and after its final

effectivity date has passed.







136

4.6.5 The ECN Coordinator shall closely monitor all ECNs whose effectivity dates have not

passed, re-adjusting effectivity dates as required to continue to meet the intent and

conditions that originally determined the selection of the effectivity date. Any change to

an ECNs effectivity date shall immediately be entered into the ERP/MRP system and the

appropriate people are informed.

4.6.6 Required Scrap Forms shall not be submitted into the Scrap process until after the ECNs

final effectivity date has passed.

4.7 Documentation

The ECN Coordinator retains completed ECNs (and all attachments) as Quality Records for a

minimum of 5 years (Reference Procedure 2.13, Quality Records).

5.0 REVISION HISTORY

Revision 3, renumbered from Procedure 4.6, with changes, 02/10/12.

Revision 2, 05/12/06, Revised Paragraphs 3.2.1, 3.2.4, 3.3.1, 3.6, 3.6.1, 3.6.2 ;; Added

paragraphs 3.2.6, 3.6.4, 3.6.5; Deleted Paragraph 3.6.3 and renumbered.

Revision 1, Para 3.2.1, added “The originator is required to determine and specify if the ECN

affects or is associated with any agency approved products.”, added “The Agency Device Key,

described in Procedure 7.7, is used to determine the approval status of products.”; Added para

3.2.5; para 3.3.3, added.”and Compliance Engineer”; para 3.4.2, complete rewrite; para 3.6.3,

removed “that are contingent upon agency approval”; added para 3.6.4 07/01/04

Revision 0, First Issued 08/01/03.

ATTACHMENT A ECN Form

137

GAI-TRONICS


ECN#: Date: / /

Page of

Originator:

Notice Type: 1 2 3 4 Priority: Immediate Next Mtg Single Effectivity: Multiple Effectivity

BOM No. / Dwg Changed:

SAP Description of Item Listed Above:

Where Used:

Product Line(s) Affected:

Is this part, bill of material or drawing used in or with any agency approved products? Yes No

Does change effect other Hubbell Div.? Yes No Is changed item a configured product? Yes No

Sales Literature Revision

No Yes Manual Revision: No Yes Related Notice(s):


Comments:

Compliance Engineer Initial Review:

Do any of these changes require prior agency notification or approval before we can completely execute this ECN? Yes No

Put this ECN on “Agency Hold” until approval has been received? Yes No

Agencies requiring notification or approval:

Comments:

Signature – Compliance Engineer: Date:

Review Team:

Quality Assurance:

Scheduling:

Purchasing:

Engineering:

Production Engineering:

MATERIAL DISPOSITION

Include Part Number and Qty Include Part Number and Qty

Rework Yes No

Part #:

Scrap Yes No

Part #:

Compliance Engineer - Approvals Received

Have all required agencies approved our use of this change? Yes No

May we complete this ECN now? Yes No

Signature – Compliance Engineer: Date:

Drawing Due Date : Effectivity Date : Completion Date:


138

GAI-TRONICS


ECN#:

Page of

E-Code Item Being Changed

Dwg Rev. Specific Description of Change

(use tab to add additional lines)

Hubbell Division Affected

Div Name: Date: Contact:



Approval Received: Yes No Date:

Hubbell Variant Configurator Specialist Notified? Yes No Who: Date:


139

E-Code Effective Date Comments Continued:

A

B

C

Note: E-code is only used if multiple effectivity dates are required. (A=First Date; B=Second Date, etc.)

ATTACHMENT B HCN Procedure

140

HES-1 Health Safety Environmental Change Notice Procedure Rev. -

Effective: May 29, 2012

1.0 Purpose/Scope

This procedure describes the process for the review and approval of new and/or changes to health, safety and environmental

policies and procedures.

2.0 Related Documents/Resources

HSE-2 Health Safety Environmental Change Notice form

Health Safety Environmental Change Notice database

Health Safety Environmental documentation database

3.0 Definitions

HSE Health Safety Environmental

HCN Health Safety Environmental change notice

HCN Coordinator The Safety & Environmental Committee Chairperson or their designee

4.0 Procedure

4.1 General

Requests for HSE changes are noted on an HCN Form. The HCN may be requested due to regulatory requirements from

OSHA, EPA, etc., employee suggestions, the safety & environmental committee, Hubbell Electrical Systems platform

directives, Hubbell Incorporated directives, Job Safety Analysis (JSA), Residual Risk Reduction R3 events, customer

requests, and other entities.

4.2 Initiation

The HCN Coordinator reviews the HCN form for completeness, assigns an HCN number, and has responsibility for

tracking the status of all open HCNs. Personnel involved with HCN review, approval and implementation activities are

responsible for providing timely status information to the HCN Coordinator.

4.3 Review

HCNs are reviewed and approved by the HCN Review Team. The team consists of representatives from HSE, Human

Resources, the Safety & Environmental Committee, Operations, Warehouse/Material, the field offices, and where

appropriate the customer.

Key elements of the review process include:

Affects the HCN will have on Field Service customer sites

Equipment procurement (Personal Protective Equipment for example)

Assurance the HCN won’t create new risks

ATTACHMENT B HCN Procedure

141

Determining other processes, procedures, postings that must be revised.

Selecting the most appropriate implementation process (specific training, tool box session, employee sign off,

etc…)

4.3 Approval

HCN Review Team members note their approval by initialing and dating the HCN form or by emailing approval to the

HCN coordinator. If a team member decides they will not approve an HCN, they must document the reason for rejection

and email the originator and the HCN coordinator.

4.4 Implementation

The HCN coordinator, with input from the originator, sets the effectivity date. Unless otherwise noted, HCNs are

permanent. Temporary HCNs with defined start and end dates may be implemented for specific projects.

4.5 Documentation

Completed HCNs and any supporting documents are scanned and saved to the network drive. The network drive is

backed up each day.

5.0 Revision History

Rev

.

Date Description Revised by Approved by

- 5/29/2012 Original Issue C. Zechman Jim Jurczyk

ATTACHMENT B HCN Form

142

GAI-TRONICS

Health Safety Environmental Change Notice

R

HCN#: Date:

Originator:

Policy/Procedure#:

Policy/Procedure Summary:

New Policy/Procedure: Revised Policy/Procedure:

Reason For Change Sites Affected Effective Date:

Regulatory: All: Temporary Start Date: Employee: Mohnton: Temporary End Date:

Platform: New Orleans: Other Documents

Hubbell: Pittsburgh:

JSA/R3: Customer:

Customer: Other (see below):

Incident Follow Up:

Other:

Reason Notes: Implementation Requirements Date

Training:

Tool Box:

Review Team Name Date Approved Sign Off:

HSE: Intranet:

Human Resources: Customer:

Safety Committee: Implementation Notes:

Operations:

Warehouse:

New Orleans:

Pittsburgh:

Customer:

Review Notes:

ATTACHMENT C PCN Procedure


Procedure - Personnel Change Notice (PCN) – Field Service Organization

Revision 1, Effective 05/24/12

Approval: M. Wolfe – National Service Team Manager

143

1.0 PURPOSE / SCOPE

The procedure describes the process for the review and approval of changes to personnel within the Field

Service Organization.

2.0 RELATED DOCUMENTS

Personnel Change Notice

3.0 ENDING YOUR CAREER AT GAI-TRONICS CORPORATION

Employment with GAI-Tronics Corporation is on an at-will basis, which means the employee or employer can

terminate the employment relationship at any time for any reason. In the event of either a voluntary or

involuntary termination the Human Resources Department will be notified. This is to ensure that all necessary

information regarding the separation is obtained.

3.1 Voluntary Termination

Employees electing to terminate the employment relationship are urged but not required to provide the

company with two (2) weeks written notice of the intent to terminate. The company expects the

employee to continue active employment, performing regular duties, during the two (2) week notice

period. However, the company retains the right to determine whether it wishes the employee to continue

active employment.

3.2 Involuntary Termination An employee may be involuntarily terminated for failure to perform his / her position as required by the

supervisor. Involuntary termination may also result when the employee’s conduct or behavior is not

conducive to the successful and satisfactory performance of either the employee’s or the department’s

job or for violation of any company rules or policies.

3.3 Personnel Change Notice

Upon termination, whether voluntary or involuntary, all Field Service employees and/or supervisors will

be required to complete the attached Personnel Change Notice (PCN) in order to facilitate the transfer of

knowledge. All current duties will transfer to the next level up in the GAI-Tronics Corporation

Organizational Hierarchy until PCN has been completed. Should the employee leave voluntarily, then

the PCN will be completed by the employee. Should the employee leave involuntarily, then the PCN

will be completed by the next level up within the GAI-Tronics Corporation Organizational Hierarchy.

4.0 PROCEDURE

4.1 All changes to personnel are noted on a Personnel Change Notice (PCN) Form.

4.2 Initiation will be completed by the Employee in the case of Voluntary Termination, or the immediate

Supervisor in the case of Involuntary Termination. The originator has the responsibility to provide

complete accurate information on the submitted PCN Form.

4.3 The Manager directly above the employee will review the form for completeness.

ATTACHMENT C PCN Procedure


Procedure - Personnel Change Notice (PCN) – Field Service Organization

Revision 1, Effective 05/24/12

Approval: M. Wolfe – National Service Team Manager

144

4.4 The National Service Team Manager will assign a number and completion due date to the PCN.

4.5 Once the immediate Manager has completed the Manager Review, upper Management levels will

review the PCN to verify all outstanding assignments have been appropriately reassigned.

4.6 PCN will then be reviewed by Human Resources.

4.7 The National Service Team Manager will determine when PCN can be closed.

4.8 Completed PCNs shall remain on file with the National Service Team Manager.

5.0 REPLACEMENT OF FIELD SERVICE TECHNICIANS

In addition to the GAI-Tronics Corporation New Hire Process, all new Field Service Technicians (whether new

hire or internal transfer) are subject to all programs outlined within the Field Service Safety and Environmental

Policy, including but not limited to:

12. Short Service Employee Mentoring Program

13. Skill Compensation Plan

14. Technician Off-Shore Certification Requirements, to include:

1. BOSIET

2. SafeGulf Training

3. TWIC® Card

4. Gulf Coast Safety Council – Basic Orientation Plus Safety Training

ATTACHMENT C PCN Form

145

GAI-TRONICS

PERSONNEL CHANGE NOTICE

PCN#: Date: / /

Page of

Originator:

Employee Name:

Title:

Effective Date:

Termination Status: Voluntary Involuntary


Current Assignments:

Job Number Customer End-User Status (attach punch list of open items)

Comments:

Manager Review:

Has contact been made with customers this employee was currently interacting with? Yes No

Have current assignments been appropriately reassigned? Yes No (mark above after reassignment)

Signature – Manager: Date:

Human Resources Review:

Has this employee completed an Exit interview? Yes No If yes, provide date:

Will a replacement be required for this employee? Yes No

Signature – Human Resources: Date:

Review Team:

Manager: National Service Team Manager: Director of Engineering:

May we complete this PCN now? Yes No

Signature – National Service Team Manager: Date:

Completion Due Date : Effective Date : Completion Date:

ATTACHMENT C GAI-Tronics Corporation Organizational Hierarchy

146

GAI-TRONICS


R

147