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PENNONI ASSOCIATES INC.

CORPORATE HEALTH AND SAFETY PLAN

Pennoni Associates Inc.

3001 Market St.

Philadelphia, PA 19104

November 2013

PREFACE

Information contained in this document is the property of, and proprietary to, Pennoni Associates Inc. (Pennoni). No part of this document may be reproduced, disclosed, or used except for evaluation purposes without the prior written permission of Pennoni.

The policies and procedures included in this Corporate Health and Safety Plan are intended to promote a safe working environment for Pennoni employees. Compliance with established safety practices is essential to minimize exposures to health and safety hazards. This plan will be periodically reviewed and updated by the Corporate Health and Safety Officer to reflect changes in applicable regulations and advances in safety technology.

Each Pennoni employee is responsible for reading and complying with the components of this plan in relation to their specific duties within the company. Failure to comply with Health and Safety plan, policies, and procedures will result in disciplinary action up to and including termination. Each Division Manager is responsible for oversight and enforcement of requirements of this plan as it pertains to their employees.

Written copies of this plan will be available in each Regional Office. An electronic copy will be available on Pennoni Online for internet access by all employees.

Requests for additional copies should be made to Corporate Human Resources.

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TABLE OF CONTENTS

Section Page No. 1.0 INTRODUCTION 1

1.1 List of Acronyms 1 1.2 Purpose 1

1.3 Program Description 2

1.4 Pennoni Health and Safety Standards 2

2.0 ORGANIZATION AND RESPONSIBILITIES 3

2.1 Organization Structure 3

2.1.1 Management 3 2.1.2 Safety Committee 3

2.1.3 Human Resources 3

2.1.4 Corporate Health and Safety Officer 4

2.1.5 Division Managers 4

2.1.6 Site Under Control of Others 4

2.1.7 Employees 4

3.0 OFFICE ENVIRONMENT AND GENERAL SAFETY TRAINING 5

3.1 General Training 5 4.0 FIELD ENVIRONMENT 5

4.1 Roles and Responsibilities 6

4.2 Various Exposure Identification in Field Environments 6

4.2.1 Construction/Excavation Environment 6

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4.2.2 Manufacturing Environment 6

4.2.3 Traffic/Railroad Environment 7

4.2.4 Utility Environment 7

4.2.5 Outdoor Environment 7

4.3 Special Assignments 7

4.3.1 Confined Space Entry 7

4.3.2 Diving 7

4.3.3 Aerial/Elevated Environment 7

4.3.4 Laboratory Environment 7

5.0 GUIDANCE TO PREPARING A SHASP 7

5.1 Situations Requiring a SHASP 7 5.2 Roles and Responsibilities 8

5.3 Role in Project 8

5.4 Requirements of the SHASP 9

5.5 Preparing the SHASP 10

6.0 HEALTH AND SAFETY TRAINING DELIVERY 10 6.1 Basic Health and Safety Training Course 10

6.2 Specific Health and Safety Training Courses 10

6.3 Selecting the Appropriate Training Courses 11

6.4 Employees in Remote Locations 11

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1.0 INTRODUCTION

1.1 List of Acronyms

CHASP - Corporate Health and Safety Plan

CHSO - Corporate Health and Safety Officer

CPR - Cardio Pulmonary Resuscitation

CSO - Contractor Safety Officer

EPA - Environmental Protection Agency

HWS - Hazardous Waste Site

LOTO - Lockout Tagout

OSHA - Occupational Health and Safety Administration

PL/PM - Project Leader/Project Manager

PPE - Personal Protective Equipment

SHASP - Site Specific Health and Safety Plan

SHSO - Site Health and Safety Officer

OCO- OSHA Compliance Officer or Employee Representative

1.2 Purpose

1.2.1 The Pennoni Associates (Pennoni) Corporate Health and Safety Plan (CHASP) has been developed to provide management and employees with the guidance to properly perform their work duties and promote worker health and safety within the boundaries of local, state, and federal requirements. Although every contingency cannot be anticipated, this plan includes the following information:

1.2.1.1 Rules, regulations, and enforcement.

1.2.1.2 Assignment of Responsibility.

1.2.1.3 Training requirements.

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All employees must utilize safe practices when performing their assigned duties and be constantly aware and alert to their surroundings. Employees should perform only those duties which they feel safe doing, and remove themselves from a situation in which they feel unsafe and immediately report such conditions to their supervisor.

1.2.2 Employees are expected to adhere to the requirements contained in the CHASP. If

required, a SHASP (see Section 5.0) should be developed to address the circumstances unique to the site at which work is to be performed and to maintain an appropriate level of safety consciousness at all times, using the CHASP as guidance.

1.2.3 Employees are expected to maintain continuous surveillance for unsafe practices, potentially hazardous conditions, and deviation from established policies and regulations. Employees are expected to initiate measures to alleviate these conditions promptly or remove themselves from the hazard.

1.2.4 The development of a SHASP is necessary for field operations when the site at which the work is to be performed is known or strongly suspected to contain concentrations of hazardous materials. All other field operations are to be conducted following the guidance of the CHASP.

1.3 Program Description

The CHASP provides Division Managers with guidance so that employees receive appropriate training and equipment to perform their respective duties safely. This can be accomplished by identifying the variety of tasks performed by employees, and then providing the appropriate training needed by the employees to perform those specific tasks. Additionally, a series of procedures are included as part of this document which are intended to be used as guidance for training, equipment, and documentation to allow each employee to perform their duties safely.

1.4 Pennoni Health and Safety Standards 1.4.1 Pennoni Health and Safety Standards are supplements to the CHASP.

1.4.2 The purpose of these Standards is to communicate the policies and procedures associated with specific safety issues employees may encounter during their work assignments. The current list of Standards is not an exhaustive list of potential health and safety issues.

1.4.3 These Standards are intended to comply with applicable regulations as set forth by the U.S. Occupational Health and Safety Administration.

1.4.4 Employees should read and understand the Standards that are applicable to their

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work assignments.

1.4.5 These Standards are not a substitute for training.

2.0 ORGANIZATION AND RESPONSIBILITIES

2.1 Organization Structure

2.1.1 Management

2.1.1.1 Corporate management is responsible for supporting the development, implementation, and maintenance of a safety program that will improve employee awareness of safe work habits, and increase employee ability to identify and correct unsafe work practices. Corporate Management will provide appropriate training and safety equipment to employees, and document and maintain medical and training records.

2.1.1.2 Corporate management will designate a Corporate Health and Safety Officer (CHSO) and delegate to the CHSO the authority to monitor the implementation of the CHASP, and to make recommendations regarding the implementation and modification of the plan.

2.1.1.3 Corporate management will appoint a Safety Committee comprised of a cross section of employees from various divisions and offices.

2.1.2 Safety Committee

The goals of the Safety Committee are:

2.1.2.1 Meet regularly to review workplace accidents looking for trends and to

raise awareness of unsafe work practices.

2.1.2.2 Continuously promote safety awareness in workplace.

2.1.2.3 Assist in the development/execution of the safety training plan.

The members of the safety committee will rotate periodically.

2.1.3 Human Resources

2.1.3.1 Human Resources is responsible for initial orientation of all employees and as such will notify them of the existence of the CHASP.

2.1.3.2 Human Resources will maintain records of health and safety training

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and any employee medical monitoring.

2.1.4 The Corporate Health and Safety Officer (CHSO) The Corporate Health and Safety Officer supports Human Resources as follows:

2.1.4.1 Development and monitoring of the CHASP.

2.1.4.2 Evaluation of employee safety training offerings.

2.1.5 Division Manager

2.1.5.1 It is the responsibility of the Division Manager to ensure that

employees receive the appropriate training for their job duties in a timely manner prior to performances of duties. The Division Manager is also responsible for ensuring employees receive refresher training as appropriate.

2.1.5.2 The Division Manager is responsible for ensuring that employees

reporting to them receive the appropriate personal protective equipment for their assigned duties.

2.1.5.3 The Division Manager is responsible for ensuring that employees

receive medical monitoring in keeping with their assigned duties. 2.1.5.4 In the event that the employee is assigned to a project managed by

others, it is the responsibility of the Division Manager, where the employee is regularly assigned, to determine, through consultation with the project manager, the conditions of this assignment and assess the necessary safety requirements.

2.1.6 Site Under Control of others

In many instances, Pennoni employees are working on sites controlled by other parties, who may have specific health and safety requirements for those active on their sites. Pennoni employees will need to abide by these site requirements or those defined by this plan, whichever are most stringent. This may require successful completion of specific training programs as required by the other parties.

2.1.7 Employees Employees have the following responsibilities:

2.1.7.1 Reading, understanding, and complying with the requirements of the

CHASP.

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2.1.7.2 Completing the Basic Health and Safety Training within two weeks of beginning work.

2.1.7.3 Taking precautions to prevent injury to themselves and to their fellow

employees. 2.1.7.4 Implementing the procedures specified in the CHASP, and verbally

reporting any deviations from the anticipated conditions described in the plan(s) to their Division Manager.

2.1.7.5 Being aware of what training they are required to receive and to avail themselves of the training prior to performing their assigned duties that require such training.

2.1.7.6 Performing only those tasks that they believe they can do safely, and verbally reporting any unsafe conditions immediately to their Division Manager.

2.1.7.7 Reporting any workplace injuries or illnesses immediately to their Division Manager. A report of the injury or illness must be completed and sent to Human Resources.

2.1.7.8 Using the personal protective equipment as needed while performing their duties, and to maintain the equipment in good working order. Employees must notify their supervisor in the event company issued equipment is lost or damaged so as to obtain a replacement.

3.0 OFFICE ENVIRONMENT and GENERAL SAFETY TRAINING

3.1 General Training

3.1.1 Employees whose primary duties are in the office environment may receive, at a minimum, training on the following topics in accordance with Pennoni’s health and safety procedures: Hazard Communication, Accident/Incident Recording and Reporting, Avoiding Slips, Trips, and Falls, Safe Lifting Practices, Personal Protective Equipment, Motor Vehicle Safety, Travel Safety, Alcohol and Drug Policy, and the Emergency Action Plan.

4.0 FIELD ENVIRONMENT

4.1 Roles and Responsibilities

4.1.1 It is the responsibility of Division Managers to periodically review the training status of each employee to ensure employees receive the appropriate initial and refresher training for their position classification and assignments prior to performance of

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duties.

4.1.2 It is the responsibility of Division Managers to ensure that employees receive the appropriate company assigned personal protective equipment and training for their assigned duties.

4.1.3 It is the responsibility of employees to be aware of what training they are required to receive and to avail themselves of the training prior to performing their assigned duties that require such training.

4.1.4 It is the responsibility of employees to use the personal protective equipment assigned to them while performing their duties, to maintain the equipment in good working order, and to notify their supervisor in the event of lost or damaged equipment so as to obtain a replacement.

4.1.5 Employees whose primary duties are in the field environment may receive, at a minimum, training on the following topics in accordance with Pennoni’s health and safety procedures: Hazard Communication, Accident/Incident Recording and Reporting, Avoiding Slips, Trips, and Falls, Safe Lifting Practices, Personal Protective Equipment, Motor Vehicle Safety, Travel Safety, Alcohol and Drug Policy, and the Emergency Action Plan.

4.2 Various Exposure Identification in Field Environments

The list below represents various types of environments to which Pennoni employees may be assigned. Listed below each environment are the suggested or required types of training that may be necessary. The Division Manager will identify the appropriate training necessary for each employee based on his/her specific assignment(s). These training topics are guidelines and not an exhaustive list of training that may be required. Training needs will be determined based on environment and work assignment.

4.2.1 Construction/Excavation Environment: Employees performing work activities at construction and/or excavation sites may receive training on the following topics in accordance with Pennoni’s health and safety standards: Control of Hazardous Energy (LOTO), Electrical Safety, Respiratory Protection, Personal Protective Equipment, Hearing Conservation, Portable Fire Extinguishers, Heat/Cold Stress, Fall Protection, and Excavation and Trenching.

4.2.2 Manufacturing Environment: Employees performing work activities in a manufacturing environment may receive training on the following topics in accordance with Pennoni’s health and safety standards: Control of Hazardous Energy (LOTO), Electrical Safety, Respiratory Protection, Personal Protective Equipment, Hearing Conservation, Portable Fire Extinguishers, Heat/Cold Stress, Fall Protection, and Excavation and Trenching.

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4.2.3 Traffic/Railroad Environment: Employees performing work activities on roadways and

railroads may receive training on the following topics in accordance with Pennoni’s health and safety standards: Personal Protective Equipment, Hearing Conservation, Heat/Cold Stress, and Confined Space Entry (if required to enter manholes), and Excavation and Trenching.

4.2.4 Utility Environment: Employees performing work activities on or around utility

equipment may receive training on the following topics in accordance with Pennoni’s health and safety standards: Electrical Safety, Control of Hazardous Energy (LOTO), Personal Protective Equipment, Fall Protection and Confined Space Entry.

4.2.5 Outdoor Environment: Employees performing work activities outdoors may receive training on the following topics in accordance with Pennoni’s health and safety standards: Personal Protective Equipment, and Hearing Conservation.

4.3 Special Assignments

4.3.1 Confined Space Entry: Employees entering confined spaces including manholes or

tanks, as part of their duties must receive Confined Space Entry training prior to their first assignment to perform confined space entries and annually thereafter as long as they continue to be assigned such duties.

4.3.2 Diving: Employees performing underwater investigations requiring the use of Surface Supplied Air (SSA) must receive training in accordance with Pennoni’s Health and Safety Standard No. 16– A Guide the Use of Surface Supplied Air Commercial Diving Technology for Underwater Engineering Inspection.

4.3.3 Aerial/Elevated Environment: Employees performing duties at elevations three feet or more above the ground must receive the following training in accordance with Pennoni’s health and safety standards: Personal Protective Equipment, and Fall Protection.

4.3.4 Laboratory Environment: Employees who perform analyses and other duties in a laboratory environment must receive training on the following topics in accordance with Pennoni’s health and safety procedures: Laboratory Use of Hazardous Chemicals, Personal Protective Equipment, Respiratory Protection, Portable Fire Extinguishers, and Electrical Safety training.

5.0 GUIDANCE TO PREPARING A SHASP

5.1 Situations Requiring a SHASP

5.1.1 A SHASP must be prepared for field operations when the site at which the work is to

be performed is known or strongly suspected to contain concentrations of hazardous

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materials or wastes.

5.1.2 A SHASP must be prepared for field operations upon client request. 5.2 Roles and Responsibilities

5.2.1 Site Safety Officer In some cases, a project will require the assignment of an individual to monitor health and safety on a project site. This individual is the Site Safety Officer (SSO) who in conjunction with the Project Manager has the following responsibilities: 5.2.1.1 Develop and implement the SHASP 5.2.1.2 Ensure all employees and contractors associated with the project are

aware of the contents and requirements of the SHASP. 5.2.1.3 Possess a working knowledge of the site and potential site hazards and

ensure that employees and contractors assigned to the project possesses the same.

5.2.1.4 Perform periodic inspections of safety equipment and sampling

instrumentation to ensure proper operation. 5.2.1.5 Observer work practices of employees and contractors to ensure

adherence to appropriate safety rules and regulations. 5.2.1.6 Report and maintain records of unsafe conduct and/or working

conditions

5.2.2 Contractor Safety Officer If a project requires a SHASP and a SSO, the requirement for a contractor safety officer should be indicated in the project documents, which define the roles of the contractor, foreman, or others that may serve as the CSO.

5.3 Role in Project

The level of responsibility for employee safety is dependent upon Pennoni’s role in the project.

5.3.1 In situations where Pennoni has a low level of responsibility for site safety, Pennoni is

responsible for the safety of its own employees, but is not the hazard controlling or creating employer. Pennoni does not have responsibility for the safety of other partner employees. Low responsibility roles include: 5.3.1.1 Pennoni employees acting as construction observers.

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5.3.1.2 Pennoni employees acting as design sub-consultants to the builder, developer, or construction manager.

5.3.1.3 Pennoni employees acting as construction managers for a fee and its

contract and those of others make it clear that Pennoni is not responsible for site safety.

5.3.2 In joint venture (50:50) arrangements that are silent on site safety, Pennoni shares an

equal level of safety responsibility with its design-build partner. However, more typically, the contract between partners will designate one partner as being responsible for site safety. The partner responsible for safety would be considered the controlling employer, and ultimately would be responsible for all employees working on the site. Regular project site audits should be conducted to correct deficient or unsafe conditions. The partner responsible for safety must prepare a SHASP.

5.3.3 When Pennoni leads the team (designer lead or construction manager at risk),

Pennoni is responsible for controlling the hazards and safety of all employees working on the site. Regular project site audits should be conducted to correct deficient or unsafe conditions. A SHASP must be prepared.

5.4 Requirements of the SHASP

At a minimum, the SHASP must include the following components

5.4.1 Names of key personnel and alternates responsible for site health and safety and the appointment of an SSO.

5.4.2 Health and safety assessment for identified health and physical risks.

5.4.3 Employee training requirements.

5.4.4 Personal protective equipment to be used by employees for each of the site tasks and operations being conducted.

5.4.5 Medical surveillance requirements.

5.4.6 Frequency and types of air monitoring, personnel monitoring, and environmental sampling techniques and instruments to be used.

5.4.7 Methods of maintenance and sampling equipment to be used.

5.4.8 Site control measures.

5.4.9 Decontamination procedures.

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5.4.10 Site standard operating procedures.

5.4.11 Emergency information. 5.5 Preparing the SHASP

5.5.1 A template for preparing a SHASP can be found in Standard 19. 5.5.2 If additional help is needed to prepare a SHASP, employees should contact the CHSO.

5.5.3 A site location map should always be included at the end of the SHASP.

5.5.4 All employees who will be on the site must read the SHASP and acknowledge that

they understand its contents by signing section I. “Employee Certification.”

6.0 HEALTH AND SAFETY TRAINING DELIVERY

6.1 Basic Health and Safety Training Course

6.1.1 The Basic Health and Safety Training course covers general health and safety topics and procedures that all employees should know regardless of their job duties.

6.1.2 All employees must complete the Basic Health and Safety Training course within two (2) weeks of beginning work with Pennoni. Based on work assignment, employees may be required to complete this training immediately.

6.1.3 The Basic Health and Safety Training course is located on Pennoni Online and is self-

paced.

6.1.4 All employees must complete the quiz at the end of the Basic Health and Safety Training course and receive a score of 70%. Failure to attain this score requires re-taking the course and quiz.

6.2 Specific Health and Safety Training Courses

6.2.1 Dependent upon each employee’s specific job duties and work environment, specific

health and safety training courses may be necessary.

6.2.2 These courses will be administered on an as-needed basis through a variety of methods including instructor lead in-house training, off-site instructor lead training, self-paced computer training, and one-on-one peer training.

6.3 Selecting Appropriate Training Courses

6.3.1 The Division Manager will be responsible for selecting the appropriate courses for

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each employee in his/her division.

6.3.2 Human Resources will track successfully completed training and evaluate the need to add additional classes to the standard checklist based on the number of requests.

6.4 Employees in Remote Locations Employees working in remote locations and unable to attend in-house training programs may be sent to comparable training programs in their location.