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Safety Program

Last Updated: April 13, 2103

Contents................................................................Objective 5

...............................................Basics Safety Rules 5

..........................................Safety Responsibilities 6............................................................Responsibilities of All Employees 6

...............................................................Responsibilities of Supervisors 6

.........................................................Responsibilities of Safety Manager 7

.................................................Incident Reporting 7.............................................................Immediately Reportable Incident 7

...............................................................................................Near Miss 7

........................................................................Investigation Procedures 7

.....................................................................................Incident Reports 8

..................................................Substance Abuse 8....................................................................Pre-Employment Screening 8

..............................................................................Post-Incident Testing 9

................................................................................List of Drugs Tested 9

.....................................................................Reasonable Cause Testing 9

...................................................................................Random Testing 10

.................................................................................Drug Test Results 10

.....................................................................................Alcohol Testing 10

...............................................................................Legal Enforcement 10

........................................Training and Education 11.............................................................................New Hire Orientation 11

.....................................................................Weekly Toolbox Meetings 11

..............................................Other Training and Education Programs. 12

.................................Cutting and Welding Safety 12........................................................................Arc welding and cutting 12

......................................................................................Fire prevention 12

.............................................................................................Ventilation 12

........................................................Driver Safety 13

...................................................Electrical Safety 15

......................................................Fall Protection 16

Ceiling Systems Inc. | Safety Program | 3-15-2013 1

.................................................................Fall protection requirements 16

.........................................................................Unprotected Openings 17

........................................................................Fall Protection Systems 17

..............................................Stairs and Ladders 18..........................................................................General Requirements 18

.............................................................................................Stairways 18

................................................................................................Ladders 19

..........................................................................................Stepladders 19

..................................................................Straight/Extension Ladders 19

....................................................Scaffold Safety 19...........................................................................Platform Construction 19

.............................................................................Supported Scaffolds 20

..................................................................Fall Protection on Scaffolds 20

................................................................................Guardrail Systems 20

.............................................Personal Fall Arrest Systems (Harnesses) 21

.......................................................................Falling Object Protection 21

...................................................................................Use of Scaffolds 21

.............................................................................................Aerial Lifts 21

..............................................Power Tools Safety 21.................................................................................................General 21

...........................................................................................Hand Tools 22

.........................................................................................Power Tools 22

.....................................Heavy Equipment Safety 23...................................................................Daily Inspections and Tests 23

.....................................................................Equipment Requirements 23

.................................................................................................Parking 24

.....................................................................................Safety Devices 24

...........................Personal Protective Equipment 24................................................................................................Clothing 24

...................................................................................Head Protection 25

.......................................................................Eye and Face Protection 25

.....................................................................................Foot Protection 25

................................................................................Hearing Protection 25

...................................................................................Hand Protection 25

........................Housekeeping / Material Storage 26


...................................................................................Material Storage 26

......................................................................................Housekeeping 26

..................................................................Disposal of Waste Materials 26

..................................................Lockout / Tagout 26................................................................Control of Hazardous Energy 26

........................................................................Lockout / Tagout Tasks 26

.............................................................Release from Lockout / Tagout 27

.................................................................................................Training 27

............................................................Exceptions to Lockout / Tagout 27

.......................................Emergency Action Plan 27.................................................................Supervisor’s Responsibilities 27

..................................................................................Fire Emergencies 28

...........................................................................Medical Emergencies 28

.........................................................................Weather-Related Event 28

...................................................................................Vehicle Incidents 28

........................................................................................Union Activity 29

...............................................OSHA Inspections 29............................................Factors that Triggers an OSHA Inspection 29

.................................................................OSHA Inspection Procedure 30

.........................................Back Injury Prevention 31...............................................................Risk Factors for Back Injuries. 31

...........................................................................Safe Lifting Practices. 31

.......................................Bloodborne Pathogens 32.............................................................................................Definitions 32

..................................................................................Exposure Control 32

............................................Post Exposure Evaluation and Follow-Up. 33

.................................................................................................Training 33

....................Hazard Communication (HAZCOM) 34.....................................................................................Warning Labels 34

.....................................................Material Safety Data Sheets (MSDS) 34

.................................................................................Employee Training 34

................................................Carbon Monoxide 34.........................................................................................Forms of CO 35

.....................................................................................Sources of CO 35


...............................................................Hazards of Carbon Monoxide 35

.......................................................................................CO Poisoning 35

...........................Asbestos Containing Materials 35.................................................................................Control Measures 36

....................................................................Silica 37...................................................................................Chronic Silicosis 37

.............................................................................Accelerated silicosis 37

......................................................................................Acute Silicosis 37

.................................................................................Control Measures 37

.....................................................................Lead 38.....................................................................Nervous System Damage 38

....................................................................................Kidney damage 38

.......................................................................Cardiovascular Damage 38

.................................................................................Control Measures 38

........................................Temperature Extremes 39..........................................................................................Heat Stress 39

..........................................................................................Cold Stress 39

..................................Job Hazard Analysis (JHA) 40.............................................................................JHA Documentation 40

...............................................Disciplinary Action 40

..................................................Healthcare Clinic 42....................................................................................Clinic Locations 42


ObjectiveThis document outlines specific procedures and guidelines to help identify and prevent job site safety hazards. Ceiling Systems Inc. considers job site safety an important priority and historically the company has maintained an excellent safety record. However, due to company growth changing nature of government regulations, this document is part of a company-wide effort to continually improve the safety program and philosophy.

It is important to remember that many safety matters involve situation-specific factors, which can be difficult to anticipate. Accordingly, this document is not the only source for company safety concerns or procedures. This information will be updated, revised or supplemented in order to keep it current and relevant.

Basics Safety Rulesa. PPE (personal protective equipment) must be worn as prescribed for each job. Hard hats, safety glasses, work

boots and approved vest or shirt are to be worn at all times within the confines of the construction area.

b. No Horseplay is allowed on the job. Stay focused on your work at all times. Do not distract the attention of fellow workers or engage in any act which would endanger another employee. Removal from the job can result.

c. Electronic Devices such as iPods, MP3 players or similar devices are not allowed on the jobsite.

d. Cell Phones are allowed on the jobsite only for work-related use. No personal calls or texting is allowed.

e. Workplace Violence will not be tolerated and may result in termination and involvement of law enforcement.

f. A clean job is part of creating a safe working environment. Keep your working area free from rubbish and debris.

g. Lift objects correctly with your legs, not your back. If an object or load is too heavy get help.

h. Training and Instruction is required for before an employee can operate any power tools or equipment. In some cases proof of formal certification may be required.

i. Electrical Cords must be industrial grade and have three prongs. Use ground fault circuit interrupters at all times and when using tools in wet atmosphere (e.g. outdoors) or with any temporary power supply.

j. Ladders and Scaffolds must be used according to manufacturers' recommendations and OSHA standards.

k. Fall Protection procedures must be followed at all times and comply with OSHA standards for fall protection.

l. Firefighting Equipment must be easily located and training must be provided for proper operation.

m. Injured Workers must not be moved unless it is absolutely necessary. Further injury may result. Keep the injured as comfortable as possible and utilize job site first-aid equipment until an ambulance arrives.

n. Emergency procedures must be established for every job site including, location of first aid kit, location of fire extinguishers, evacuation plan, etc.

o. OSHA 10-Hour All employees are REQUIRED to participate in a certified OSHA “10 Hour” course on construction safety and health.


Safety ResponsibilitiesAll employees are responsible for creating and maintaining a safe working environment. All employees are expected to notify their supervisor and fellow workers of unsafe conditions and make recommendations for improvement. It is the responsibility of each supervisor to listen to recommendations made by workers and be willing to apply changes when appropriate.

Responsibilities of All Employeesa. Take immediate action(s) to halt unsafe acts and/or conditions.

b. Report any unsafe working condition to their immediate supervisor.

c. Keep individual work area in a clean, orderly and safe condition.

d. Report ALL incidents to supervisor immediately.

e. Cooperate with any necessary incident investigation.

f. Participate in any safety training courses.

g. Maintain a positive attitude toward safety and cooperate fully with the safety program.

Responsibilities of SupervisorsIt is the responsibility of every supervisor to act as the “Competent Person” as defined by OSHA.

OSHA Definition of Competent Person:One who is capable of identifying existing and predictable hazards in the surrounding or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has the authority to take prompt corrective action.

Supervisors are also required to:

a. Set a positive example by following all safety and health rules.

b. Ensure and protect the safety of all employees under their management.

c. Train employees in safe work practices and safety regulations.

d. Correct all unsafe working conditions immediately upon discovery.

e. Conduct frequent and regular inspections of the job site to identify hazardous conditions.

f. Investigate any reported incident immediately and complete the appropriate Incident Report Form.

g. Notify the Safety Manager immediately of any injury, accident or near miss.

h. Accommodate employees assigned to restricted duty and make sure employees working under doctor-ordered restrictions do not exceed their restrictions.

i. Enforce all safety and health rules with a positive attitude and stress the importance of working safely.


Responsibilities of Safety Managera. Meet with supervisors monthly to discuss incidents, inspections and any other safety or health issues.

b. Provide supervisors with forms and safety reporting tools to help facilitate the safety program.

c. Act as point of contact for general contractors regarding safety compliance.

d. Conduct incident investigations to identify root causes and initiate corrective actions to prevent recurrence.

e. Inspect job sites to ensure compliance with all safety and health rules.

f. Ensure compliance with all federal, state and local regulations.

g. Act as a resource to all levels of the company regarding matters of worker safety and health.

h. Coordinate all aspects of the Safety Program.

Incident ReportingImmediately Reportable Incident In case of an incident, a detailed incident report is to be completed and submitted to the Safety Manager. The purpose of the report is to identify root causes and recommend appropriate corrective actions. Incidents that are to be reported include:

a. Injuries or illnesses

b. Near misses

c. Property damage

d. Equipment damage

e. Vehicle damage

Near MissA Near Miss is an unplanned event that did not result in injury, illness, or damage – but had the potential to do so. Only a fortunate break in the chain of events prevented an injury, fatality or damage; in other words, a miss that was nonetheless very near. Although the label of 'human error' is commonly applied to an initiating event, a faulty process or system invariably permits or compounds the harm, and should be the focus of improvement. Other familiar terms for these events is a "close call", or in the case of moving objects, "near collision" or a near hit.

Investigation Procedures All incidents are to be investigated by the appropriate individual(s) as soon as possible after the incident occurs.The supervisor’s investigation should answer at a minimum, the following questions:


• WHO – was involved in the incident?

• WHAT – exactly happened?

• WHERE – did the incident occur?

• HOW – was the accident caused?

• WHEN – did the incident occur?

• WHY – did the incident occur?

• WHAT – immediate corrective actions were taken?

• WHAT – long-term corrective actions were taken?

Incident Reports After an incident, the supervisor must complete and submit the appropriate report to the Safety Manager. The report must be submitted within twenty-four hours of the incident. In case of an accident or incident, supervisors are responsible for completing the following reports:

a. Accident Report: To be filled out for any accident or safety incident occurring on a job site

b. Near Miss Report: To be filled out for any “near-miss” occurring on a job site

c. Vehicle Incident Report: To be filled out for vehicle incidents in company vehicles on public roadways.

d. Post Incident Drug and Alcohol Test Report: An employee involved in an incident is subject to this test.

Substance AbuseCeiling Systems Inc. requires that every employee report to work in a condition that will allow him to be physically and mentally alert to ensure safe performance of the job. Working while under the influence of drugs or alcohol or possessing these substances while at work, creates a safety hazard and is illegal. Employees of Ceiling Systems Inc. must adhere to the following substance abuse policies:

Pre-Employment Screeninga. Ceiling Systems Inc. will not employ a person who fails a pre-employment drug screen.

b. All job applicants will be informed at the time of application, the company’s substance abuse policy and informed that any offer of employment will be require the successful completion of a drug test.

c. In the event that an applicant’s drug test is positive the offer of employment will be revoked.

d. No job offer will be considered final and no employee may begin working until negative drug test results have been received.


Post-Incident TestingEmployees involved in an accident or incident may be subject to a post-incident test for both drugs and alcohol. Ceiling Systems Inc. will conduct drug testing under the following circumstances:

a. If an employee is driving a company vehicle and is in an incident where a fatality or bodily injury has occurred the driver must submit to a drug test.

a. If an employee is driving a company vehicle and is in an incident where the motor vehicle is required to be towed, the driver must submit to a drug test.

b. If an employee is involved in a work site incident which requires the employee to receive professional care at a medical facility the employee must submit to a drug test.

c. If after an incident, law enforcement officials conduct a sobriety test, the employee must allow Ceiling Systems Inc. to obtain the test results.

d. In the event that an employee is so seriously injured that a specimen cannot be obtained at the time of the incident, the employee must provide necessary authorization to allow Ceiling Systems Inc. to access medical records that may indicate if drugs or alcohol were present in the employee’s system at the time of the incident.

List of Drugs TestedCeiling Systems Inc. requires a standard 10-panel drug screen which measures the presence, if any, of an illicit substance in the body, most commonly through urine testing. The results of the test can be determined rather quickly, and accurately. The test also measures characteristics such as the pH level to show if the urine has been altered to cheat the test. This type of test detects if the following drugs are found in the urine sample:

1. Cocaine

2. Amphetamine

3. Methamphetamine (Ecstasy, crystal meth),

4. Tetrahydrocannabinol (Marijuana),

5. Methadone

6. Opiates (Heroin, OxyContin etc.)

7. Phencyclidine (PCP)

8. Barbiturates

9. Benzodiazepines (Xanax, Valium)

10. Tricyclic Antidepressant

Reasonable Cause Testing If a supervisor suspects that an employee may be working under the influence of alcohol or drugs, he should notify the Safety Manager immediately. The suspicion should be based on objective observations, the employee’s job performance or personal conduct at work.


Random TestingCeiling Systems Inc. will conduct random drug testing of all employees. The percentage and frequency of random selection will be at the discretion of Ceiling Systems Inc., but in all cases will be at or above the level of federally mandated programs.

Random selection, by its very nature, may result in employees being tested in successive random selections or more than once a calendar year. Alternatively, some employees may not be selected in a calendar year. Individuals selected for random testing will be notified by the Company. If a randomly selected individual engages in conduct that does not lead to a collection, such conduct may be considered a refusal to test.

Drug Test ResultsAll initial positive drug screens must be confirmed at the laboratory by a GC/MS test before the test result will be considered positive. A drug test will be considered positive if the reported result for any substance exceeds the permissible cut-off level for that substance.

If the confirmed test result is positive, the employee will be contacted by a medical professional, who will investigate the nature of the positive result with the employee/applicant. If the positive is the result of legitimate prescription drug use, the result will be reported to Ceiling Systems Inc. as “negative.” If there is no reasonable medical explanation for the positive result, it will be reported to the employer as “positive.” If the drug test result is reported as a Negative Dilute, the employee will be required to retest.

Employees with a confirmed positive result will be immediately removed from work and will be subject to corrective action, up to and including termination.

Alcohol TestingTesting for alcohol will be accomplished via breath in most cases. However, if breath alcohol testing is not available at the treating medical facility, a blood alcohol test may be performed.

Test results less than .02 will be considered negative. If the confirmation result is .02 or greater, the testing facility will notify Ceiling Systems Inc. of the results. Any employee with a positive breath alcohol result will be subject to corrective action, up to and including termination.

Legal EnforcementThe unauthorized use or possession of alcohol or illegal drugs on company property or while on company business subjects the employee to corrective action up to and including termination of employment.


Using, possessing, selling, trading or delivering an illegal drug on company property or while on company business is cause for immediate termination of employment. Ceiling Systems Inc. will, at its discretion, refer these illegal activities to law enforcement.

Training and EducationTraining and Education is an ongoing process for the employees of Ceiling Systems Inc. and we are committed to providing proper resources to maintain a safe and healthy work environment.

New Hire Orientation All field employees receive a new hire safety orientation and an overview of the Ceiling Systems Inc. Safety Program. Each new hire will be also be required to attend and complete an OSHA 10 Hour course. The 10 Hour course covers the following topics:

a. General Safety and Health Requirements

b. Competent Person Requirements

c. Personal Protective Equipment

d. Fall Protection Practices

e. Electrical Hazards

f. Lockout / Tagout

g. Excavation Hazards

h. Scaffold Hazards

i. Hazard Communication

j. Stairways and Ladders

a. Confined Spaces Safety

b. Fire Protection and Prevention

Weekly Toolbox Meetings Toolbox meetings are conducted weekly by each field supervisor. Materials and topics for these meetings will be provided by the Safety Manager. Toolbox meetings are held to discuss the following:

a. Changes or updates to OSHA regulations

b. Potential safety or health hazards and control measures in upcoming work

c. The results of safety inspections or incident investigations conducted within the previous week


Other Training and Education Programs.In some cases, additional training or certification may be required for devices such as lasers and powder-actuated tools. If required, this training will be provided by Ceiling Systems Inc. or other certified trainer.

Cutting and Welding SafetyArc welding and cutting

a. Any current carrying parts shall be fully insulated against the maximum voltage encountered to ground.

b. All cables shall be of the flexible type and fully insulated and capable of handling the maximum current requirements of the work in progress.

c. Welding leads must be free of repair or splice within ten feet of the stinger.

d. A ground return cable shall have a safe current carrying capacity equal to or exceeding the specified maximum output capacity of the welding machine it is servicing.

e. Pipelines containing gases or flammable liquids, or electrical conduits, shall not be used as a ground return.

f. The frames of all welding machines shall be grounded.

g. When electrode holders are left unattended, the electrodes shall be removed and the holder shall be placed so as to prevent accidental contact with employees or conducting objects.

h. Hot electrode holders must be kept away from water.

i. When the welder will be away from the electrode holder for any appreciable length of time, such as breaks or lunch, or when the machine is to be moved, the power supply switch to the machine must be opened.

j. Whenever possible, all arc welding and cutting operations shall be shielded to protect employees and other persons in the area from the direct rays of the arc.

Fire prevention a. When possible, welding or cutting should be done in a designated area free of combustible materials. If the object

to be welded or cut cannot be moved, all movable fire hazards in the vicinity shall be moved to a safe place or otherwise guarded.

b. If the object to be welded or cut cannot be moved, positive actions must be taken to contain the release of hot slag, sparks and flame.

c. No welding, cutting or heating of objects shall be done where the application of flammable paints or the presence of other flammable compounds, or heavy dust concentrations create a hazard.

d. Suitable fire extinguishing equipment shall be immediately available and shall be maintained in a state of readiness for instant use.

Ventilationa. Contaminated air exhausted through either general mechanical ventilation or local exhaust ventilation shall be

discharged into the open air or otherwise clear of the source of intake air.


b. Oxygen shall not be used for ventilation purposes, comfort cooling, blowing dust off of clothing or for cleaning the work area.

c. Ventilation shall be provided whenever welding, cutting or other hot work is conducted within a confined space.

Eye Protection for Welding Operations Shade Number

Gas shielded arc welding 12

Shielded metal arc welding 3/16, 7/32, 1/4 inch electrode 12

Shielded metal arc welding 5/16, 3/8 inch electrode 14

Atomic hydrogen welding 10-14

Carbon-arc welding 14

Torch brazing, Light cutting, up to 1” 3-4

Medium cutting, 1” to 6” 4-5

Heavy cutting, over 6” 5-6

Gas welding, light up to 1/8” 4-5

Gas welding, medium 1/8” to ½” 5-6

Gas welding, heavy over ½” 6-8

Driver SafetyThis policy applies to all drivers of company owned vehicles and drivers of privately owned vehicles used for company business.

Authorization of Driving Privileges. Employees will not be permitted to operate a motor vehicle for company business if:

a. The driver does not have a valid driver’s license issued by their state of residence.

b. The driver possesses more than one driver’s license from more than one state.

c. The driver’s license has been suspended or revoked for any reason.

d. The employee has multiple moving violations.

Authorized Vehicle Usea. Company vehicles may not be driven for personal use.


b. Drivers of assigned vehicles may not allow unauthorized persons to operate company owned vehicles.

c. Disciplinary action, up to and including termination, may be taken for unauthorized use of company vehicles.

d. Employees may be held responsible for any losses incurred during an unauthorized use of company vehicles.

Motor Vehicle Records Checksa. A current driving record will be obtained for a new employee that is required to drive company vehicles.

b. Official state driving records will be checked yearly for all drivers.

c. Driving records will be stored confidentially in each employee’s private safety file

High Risk DriversA driver will be classified as “high risk” and restricted from driving company vehicles for any one of the following:

a. Driver’s license suspension, revocation, or restriction within the last three years.

b. Conviction for an alcohol and/or drug related driving offense.

c. Conviction for reckless driving.

d. Conviction for leaving the scene of an accident.

e. Conviction for being at fault in a fatal accident.

f. Conviction of felony committed involving a vehicle.

g. Two or more damage claims to a company vehicle.

h. Two or more speeding tickets in past year.

Safety Requirementsa. The driver and all occupants are required to wear seat belts when operating or riding in a company motor vehicle.

The driver is responsible for ensuring that all passengers are wearing seat belts.

b. A driver may not operate a company vehicle at any time when his or her ability is impaired, affected, or influenced by drugs, alcohol, medication, illness, fatigue, or injury.

c. Drivers are required to abide by all federal, state, and local motor vehicle regulations, laws and ordinances.

d. Each driver is responsible for ensuring that the motor vehicle is maintained in safe driving condition.

e. Drivers are required to drive with headlights on at all times when conditions warrant.

f. Drivers may not pick up hitch hikers.

g. Drivers may not use radar detectors, laser detectors, or similar devices.

h. Drivers may not push or pull another vehicle without authorization.

Cell Phone Usea. If you must use your phone in traffic use a hands-free device so both hands can stay on the wheel.

b. When using a phone, adjust your driving accordingly – drive slower and increase your following distance.

c. Avoid emotional or complex phone calls. Keep conversations as short as possible.


d. Never take notes or look up phone numbers while driving.

e. Never send or read text messages while driving.

f. Have passengers place and receive calls for you if possible.

g. Obey the laws and regulations on the use of wireless telephones in the areas where you drive.

Electrical SafetyGeneral Requirementsa. All electrical conductors and equipment shall be free from recognized hazards that are likely to cause death or

serious physical harm to employees.

b. Listed, labeled, or certified equipment shall be installed and used in accordance with instructions included in the listing, labeling, or certification.

Temporary Wiringa. Branch circuits shall originate in a power outlet or panel board.

b. Branch circuit conductors shall be located where they are not subject to physical damage.

c. Branch circuit conductors shall not be laid on the floor.

d. Branch circuit conductors shall be fastened at intervals not exceeding ten feet.

e. Receptacles shall be the grounding type.

f. Receptacles for uses other than temporary lighting shall not be installed on branch circuits that supply temporary lighting.

g. Extension cords shall be the three wire type and be designed for hard or extra-hard usage.

h. Cords for temporary lighting shall be designed for hard or extra hard usage.

i. Acceptable flexible cord designations include S, ST, SO, STO, SJ, SJO, SJT, SJTO.

j. Flexible cords and cables shall be protected from damage. Sharp corners and edges are to be avoided. Where cords pass through windows or doorways, they must be protected.

k. Temporary lighting shall not be suspended by the cord unless specifically designed to be fastened that way.

l. Light bulbs must be protected from accidental contact or breakage.

Working On or Near Exposed Electrical Conductorsa. Live parts to which an employee may be exposed shall be put into an electrically safe work condition before an

employee works on or near them, unless the work on energized components can be justified.

b. Working on any exposed parts or circuits that have not been put into an electrically safe work condition. Other Safety-Related Work Practices to be followed when working in an unsafe work condition shall include:

1. Holding a Job Briefing

2. Establishing Approach Boundaries for shock and arc flash hazards

3. Use of PPE


Establishing an Electrically Safe Work ConditionAn electrically safe work condition is only achieved after completing the following six steps:

a. Determine all possible sources of energy by checking up-to-date drawings, diagrams, or identification tags.

b. After properly interrupting the load current, open the disconnect for each circuit.

c. Wherever possible, visually verify that all disconnects are fully open (or that drawout-type circuit breakers are withdrawn to the fully disconnected position).

d. Apply lockout / tagout devices.

e. Use an adequately rated voltage detector to test each phase to verify they are de-energized. Test each conductor phase to phase, and phase to ground. Before and after each test, check that the meter is working properly.

f. Where the possibility of induced voltages or stored electricity exists, ground the phase conductors with ground connecting devices rated for the available fault duty.

Fall ProtectionFall protection requirements

a. Unprotected sides or edges. Employees on walking/working surfaces (horizontal and vertical surfaces) with an unprotected side or edge which is six feet or more above a lower level shall be protected from falling by the use of guardrails, safety net systems, or personal fall arrest systems.

b. Hoist areas. Employees shall be protected from falling six or more feet to lower levels by use of guardrail systems or personal fall arrest systems. If a guardrail system must be removed to facilitate landing material from the hoist, and employees are required to lean out over the opening, personal fall arrest systems shall be used.

c. Holes. Employees on walking/working surfaces shall be protected from falling through holes (including skylights) more than six feet to a lower level by the use of covers, guardrail systems or personal fall arrest systems.

d. Ramps runways and other walkways. Employees on ramps, runways and other walkways shall be protected from falling more than six feet to a lower level by the use of guardrail systems.

e. Wall openings. Employees working at, above or near wall openings with an outside bottom edge greater than six feet from a lower level and the inside lower edge less than thirty nine inches high shall be protected by guardrail systems, safety net systems or personal fall arrest systems.

f. Excavations. Each employees at the edge of an excavation six feet or more in depth shall be protected from falling by guardrail systems, fences, or barricades when the excavations are not readily seen because of plant growth or other visual barrier.

g. Roofing work on low slope roofs (less than or equal to a 4 in

h. 12 pitch). Employees engaged in roofing activities on low slope roofs, with unprotected sides and edges six feet or more above lower levels shall be protected from falling by guardrail systems, safety net systems, personal fall arrest system, or a warning line and safety monitoring system.

i. On low slope roofs fifty feet or less in width, the use of a safety monitor alone is permitted without perimeter warning lines.

j. Walking/working surfaces not otherwise addressed. Employees on any other walking or working surface with a fall potential of greater than six feet shall be protected by guardrail systems, safety net systems or personal fall arrest


systems.III. Protection from falling objects. When employees are exposed to falling objects they shall be protected by one of the following methods in addition to wearing ANSI Z89.1 certified hard hats:

k. Toe boards and screens shall be used in conjunction with standard guardrail systems to prevent objects from falling from higher levels.

l. Potential fall objects shall be kept far enough away from the edge of the higher level so that in the event of accidental displacement they would not fall to a lower level.

m. Areas below higher levels where objects may reasonably be expected to fall shall be barricaded to prevent employees and other personnel from entering these areas.

Unprotected Openings a. Holes are considered a gap or void two inches or more in the least dimension in a floor, roof or walking/working

surface.

b. Holes that have a falling distance of less than 6 feet must be covered or clearly marked out with caution tape or a guard rail system to identify the potential fall hazard.

c. Holes that have a falling distance greater than 6 feet above lower levels must be clearly labeled “Hole” or “Cover” and covered with a secured cover rated to withstand without failure at least twice the maximum load of the largest piece of equipment, employee’s, or materials that may be imposed on that cover at one time.

d. Wall openings such as windows, doors, elevator shafts, stairs, ladders access, material receiving areas and trash chutes with a distance greater than 6 feet above lower levels and the bottom edge of the wall opening is less than 39 inches above the walking or working surface must be protected from falling by the use of a guardrail system, safety net system or personal fall arrest systems.

e. Ramps, runways and other walkways shall be protected with a guardrail system when the walking surface is greater than 6 feet above the lower level.

Fall Protection Systems

Guardrail Systemsa. The top edge height of the guardrail system shall be 42 inches plus or minus three inches (39-45 inches).

b. Mid-Rails shall be installed midway between the top-rail and the walking working surface.

c. Guardrail systems shall be designed to withstand a force of 200 pounds applied within two inches of the top-rail in a downward or sideways direction. The top-rail shall not deflect to a height of less than 39 inches when the force is applied in a downward direction. Guardrail systems shall also be designed to withstand a force of 150 pounds applied in a downward or sideways direction along any point of the mid-rail.

d. Top-Rails and mid-rails shall be at least one-quarter inch nominal thickness or diameter to prevent cuts or lacerations. If wire rope is used for top-rails it shall be flagged at six foot intervals with high visibility material such as caution or danger tape.

Personal Fall Arrest Systems (PFAS)a. Personal fall arrest systems shall consist of a full body harness, lanyard and an approved anchorage point.

b. In some cases a PFAS may include a deceleration device. Maximum deceleration distance travel must be no more than 3.5 feet.


c. The anchorage point must be capable of supporting at least five thousand pounds or two times the weight of any force imposed on it.

d. Lanyards shall be attached to the full body harness at the center of the wearer’s shoulder blades.

e. Lanyards shall be rigged to prevent the wearer from falling more than six feet or striking a lower level.

f. Harnesses, lanyards, lifelines and other fall protection devices shall not be used for any purpose other than fall protection.

g. PFAS subjected to impact loading shall be removed from service until it has been inspected by a competent person and determined to be free from damage.

h. PFAS shall not be attached to guardrail systems.

i. PFAS used in the material hoisting areas shall be rigged to allow the movement of the employee only as far as the edge of the walking/working surface.

Covers. a. Covers for holes in floors, roofs, and other working surfaces must be capable of supporting at least two times the

weight of any employees, materials, or equipment that may be imposed on them.

b. Covers must be secured against displacement by wind, equipment, or employees.

c. Covers must be labeled “Hole” or “Cover”.

Stairs and LaddersGeneral Requirements

a. A stairway or ladder is required at any point of access where there is a break in elevation greater than nineteen inches and no ramp, runway, sloped embankment or other means of access is provided.

b. Stairway, ladders and their landings must be kept clear at all times.

c. If a stairway or ladder has to be blocked, another means of access must first be provided.

Stairwaysa. Riser heights and tread depths must be uniform within each flight of stairs.

b. Where doors or gates open onto a stairway, a landing must be provided. The landing must be at least 20 inches wider than the swing of the door.

c. Stair rails are required on any open side of a stairway having four or more risers or higher than thirty inches. A stair rail consists of a top-rail and mid-rail.

d. Stair rail height should be thirty-six inches measured from the front of the tread.

e. Mid-rail height is midway between the top-rail and the stair surface.

f. A handrail is required on at least one side of the stairway. A stair rail may also serve as a handrail as long as it is surfaced to prevent injury from punctures or lacerations, and to prevent snagging of clothing.

g. Stair rails must support at least 200 pounds.


Laddersa. Ladders must be kept free of oil, grease and other slippery substances.

b. Precautions must be taken when ladders are placed in doorways, passageways or aisles where they can be displaced by workers or activities in the area.

c. Ladders should not be moved or adjusted while occupied.

d. Conductive (aluminum) ladders cannot be used where the ladder or the employee could contact electrical equipment. On certain job sites fiberglass ladders may be required. Wood ladders are never allowed.

e. Ladders must be inspected frequently. Report any defects to your supervisor. The supervisor is responsible for removing from service any ladder that is not safe for use.

f. When climbing a ladder, the user must face the ladder and use the 3 points of contact system.

g. At least one hand must be completely free to grasp the ladder when climbing.

h. No tools or equipment are to be carried up or down a ladder that could cause an employee to lose balance and fall.

i. Use a hoist line to raise or lower larger objects at ladder ways.

Stepladdersa. Stepladders may only be used in the open position. A metal spreader or locking device is required to hold the ladder

in the open position.

b. The top and the last step of stepladders may not be used as a step.

c. Cross bracing on the back of a stepladder may not be climbed.

Straight/Extension Laddersa. When extension ladders are used to gain access to another level, the ladder must extend three feet above the

upper landing surface.

b. Ladders used to access another level must be tied off at the top.

c. The base of a straight ladder should be set up approximately one-quarter of the working height of the ladder away from the support (for example, the base of a ladder used to get on a twelve foot roof should be four feet from the building). A rule of thumb – If you place your feet at the bottom of the feet of the ladder, your arms should extend straight out to the side rails of the ladder.

d. Straight ladders must have slip resistant feet. Ladders set up on slippery surfaces must be tied off at the top or bottom to prevent the ladder from kicking out.

e. The rails of a straight ladder must be supported equally unless it is equipped with a single support attachment.

f. Ladders must be used on stable and level surfaces unless they are properly secured.

Scaffold SafetyPlatform Construction

a. Each working level must be fully planked or decked.


b. Scaffold platforms must be within fourteen inches of the work surface.

c. Eight foot scaffold planks must extend over their support at least six inches but less than twelve inches unless secured to prevent movement.

d. Sixteen foot scaffold planks must extend over their support at least six inches but less than eighteen inches unless secured to prevent movement.

e. Where planks are overlapped, the overlap must be a minimum of twelve inches and must occur over a support.

f. Scaffold planks should not be painted or coated with anything to make them slippery or which could cover up defects such as cracks.

Supported Scaffoldsa. Scaffolds must be built on a firm foundation. Scaffolds built on the ground require baseplates and mudsills.

b. Unstable objects such as masonry blocks may not be used to support scaffolds

c. Scaffolds frames must be plumb and platforms must be level.

d. Scaffolds over four times higher than their width must be secured to prevent tipping.

e. Scaffolds that require securing must be secured at both ends and every thirty feet counting from one end. Scaffolds must be secured vertically every twenty feet thereafter

Accessa. When scaffold platforms are more than two feet above or below a point of access, a ladder or some other safe

means is required to access the scaffold.

b. X-braces may not be used to access scaffolds.

c. Walk-through frames may not be climbed as ladders to access the scaffold (Note: Employees erecting and dismantling the scaffold may climb walk-through frames, but they may not climb the x-braces)

Fall Protection on Scaffoldsa. Fall protection is required for any scaffold over ten feet high.

b. Employees erecting or dismantling scaffolds may work at heights over ten feet without fall protection if a competent person determines that it is not feasible or creates a greater hazard to use fall protection.

Guardrail Systemsa. Guardrail systems are required on all open ends and sides of scaffolds.

b. The guardrail shall consist of a top-rail thirty-eight to forty-five inches high and must be capable of supporting two hundred pounds.

c. The mid-rail should be midway between the top-rail and the platform and must be capable of supporting one hundred-fifty pounds.

d. X-braces may be used in place of a mid-rail if the crossing point of the brace is between twenty and thirty inches high. X-braces may be used in place of a top-rail if the crossing point of the brace is between thirty-eight and forty-eight inches high. The end points of the x-brace may not be more than forty-eight inches apart for it to count as a top-rail or mid-rail.


Personal Fall Arrest Systems (Harnesses)a. Personal fall arrest systems used on scaffolds must comply with the Fall Protection section of this document.

b. Harnesses should be connected to vertical lifelines, horizontal lifelines, or structural members. Connection to the scaffold components is not acceptable in most situations.

Falling Object Protectiona. Toeboards are required on all platforms where work is being performed or material is stored.

b. Platforms shall only be loaded with the materials needed for immediate use.

c. Debris shall not be allowed to accumulate on scaffolds.

Use of Scaffoldsa. Scaffolds must be erected, moved, dismantled or altered only under the supervision and direction of a competent

person.

b. No work may be performed from snow or ice covered platforms (except to remove snow or ice).

c. Standing on boxes or buckets or other makeshift devices should not be used to extend reach on scaffolds.

d. Ladders may not be used on scaffold platforms for additional reach (except on large area platforms).

e. Scaffold frames must be secured together vertically with coupling pins or an equivalent.

f. Scaffold casters must be locked when the scaffold is occupied.

g. Mobile scaffolds may not be moved while occupied unless the floor is level and free of pits, holes and obstructions; and the scaffold is no higher than two times it’s width.

Aerial Liftsa. Personal fall arrest systems and tying-off in platform lifts is required in addition to full guardrails on boom lifts.

b. Tying off to structures other than the provided attachment points is not permitted.

c. Lifts must be inspected by a competent person each day prior to use.

d. Only authorized employees with proper training should operate lifts.

e. Employees must stand on the floor of the lift at all times. Standing on the rails to extend reach is not permitted.

f. Weight capacities and personnel limits must not be exceeded.

g. Lifts shall not be used for any purpose they were not designed for.

h. Follow all other safety requirements found in the operator’s manual located on the unit.

Power Tools SafetyGeneral

a. All tools, whether supplied by Ceiling Systems Inc., or by an employee, must be maintained in a safe condition.


b. Power tools equipped with guards must only be used with the guards in place.

c. Appropriate PPE must be used while operating power tools to prevent safety hazards.

d. Any tools which are found to be defective or unsafe must be reported to a supervisor and taken out of service.

e. Always use the proper tool for the job.

Hand Toolsa. Hand tools shall be kept in proper working order and condition. All hand tools will be properly secured and stored

when not in use.

b. Impact tools such as drift pins, wedges and chisels shall be kept free of mushroomed heads.

c. Wooden handles shall be free of splinters and cracks and shall be tight in the tool.

Power Tools

Electric Toolsa. Electric power tools shall be properly insulated and grounded.

b. Tools shall not be unplugged, hoisted, or lowered by their cords.

c. Tools shall be unplugged from the power source when they are not being used.

d. When tools are not in use they should be stored safely and in protected containers or boxes.

Pneumatic Power Toolsa. Pneumatic power tools and all air line couplings shall be secured together to prevent them from becoming

disconnected.

b. Compressed air shall not be used for cleaning unless reduced to less than 30 p.s.i.

c. Air guns shall never be pointed toward or dead-ended against or towards another individual.

Fuel Powered Toolsa. Fuel powered tools must be shut off when refueling.

b. Fuel powered tools shall not be used in enclosed spaces unless adequate ventilation is supplied.

Powder-Actuated Toolsa. Only licensed operators shall use powder-actuated tools.

b. Powder-Actuated tools shall be tested, used and maintained in accordance with the manufacturer’s recommended guidelines.

c. Loaded tools must be used immediately and never left unattended.

d. In the event of a misfire follow these steps:

1. Wait 30 seconds then try firing again

2. If it still does not fire, wait an additional 30 seconds before carefully removing the cartridge.


Tool Guards and Safety Switchesa. All guards and safety switches must be installed and in proper working order.

b. Guards shall be provided to protect the operator from:

1. Point of operation

2. In-running nip points

3. Rotating parts

4. Flying chips and sparks

c. Momentary contact “on-off” switches must be provided on the following hand held-drills, tappers, fastener drivers, grinders, disc and belt sanders, reciprocating saws, saber saws, and other similar tools.

Heavy Equipment SafetyDaily Inspections and Tests

a. All machinery and equipment should be inspected before use to ensure safe operating procedures (Appendix A- Operator’s Inspection Report).

b. Tests shall be performed to ensure that brakes and all other operational systems are in proper working order.

c. Whenever machinery or equipment is found to have any major deficiencies, it shall be tagged out of service immediately.

1. Tags shall be placed in a conspicuous location and shall indicate that the equipment shall not be used or the tag shall not be removed. Tags shall only be removed by the person who affixed it, after repairs are completed (refer to the lockout/tagout section of this handbook).

d. Only qualified individuals shall operate any machinery or equipment.

e. Equipment and machinery shall not be operated in a manner that will endanger persons or property nor shall the operating speeds or loads be exceeded.

f. Climb into or out of equipment only using steps or rungs provided on the machine, do not jump out of the cab. Accessing or exiting any piece of moving equipment is prohibited.

g. Use of mobile phones, headphones, or similar items is strictly prohibited while operating machinery or equipment.

Equipment Requirementsa. Equipment is only designed to carry as many passengers as there are belted seats.

1. Seat belts are not required for equipment that is designed to be operated in the standing position.

2. Seat belts are not required on those pieces of equipment that is not equipped with ROPS (roll-over protective structure).

b. Mobile equipment to be driven on public roadways shall be properly registered and tagged.

c. Lights shall be in good working order.

d. Warning systems, alarms and horns shall be in good working order.

e. Maintenance and repairs shall only be performed while the equipment is shut off, unless specifically designed for lubricating while the engine is running.


f. Equipment shall have all blades, buckets, dump bodies or similar equipment fully lowered or blocked when not being used.

g. Clearance around power lines shall be the same as that specified for mobile cranes in the Cranes and Rigging section.

h. Internal combustion engines shall not be run within an enclosed building unless adequate ventilation controls are in place to ensure hazardous atmospheres are not being created.

Parkinga. All parked equipment shall have the parking brake set.

b. Equipment parked on an incline shall have the wheels chocked and the parking brake set.

c. Equipment left adjacent to roadways shall have lights or reflectors that are visible to passing motorists.

d. Modifications that affect the unit’s capacities or safe operations shall not be made unless written approval is given by the manufacturer, and proper tags are placed on the unit.

Safety Devicesa. All vehicles shall be equipped with an audible warning device accessible from the operator’s station.

b. No equipment having an obstructed view to the rear shall be used unless:

1. It is equipped with an audible reverse signal that is distinguishable from surrounding noises or:

2. The equipment is only back under the direct signaling of a specified spotter.

c. Equipment being used in clearing and demolition operations shall be protected by guards, canopies or grills.

Personal Protective EquipmentThe use of specialized Personal Protective Equipment (PPE) is the most basic way to protect employees from job site hazards. Selection and use of PPEs is determined by correct hazard assessment and is enforced through stringent safety regulations. Ceiling Systems Inc. follows regulatory and industry standards by outfitting employees with the latest protective devices and equipment. Training is also provided on the proper use, maintenance, inspection, and limitations of all required PPE.

Clothinga. Employees are required to wear full length work pants and shirts with at least a three inch sleeve. Half or three-

quarter length shirts are not permitted.

b. Excessively loose or baggy clothing is not permitted.

c. Excessively worn or ragged clothing or clothing with large holes is not permitted.

a. Employees are expected to provide their own work clothing for all types of weather conditions.


Head Protection a. All employees are required to wear protective hard hats while working in the field. Hard hats must meet the

specifications contained in American National Standards Institute Safety Requirements for Industrial Head Protection.

b. Hard hats shall not be customized or painted by employees and shall not be altered in any way that may weaken the structure or protective properties of the material.

c. Hard hats shall be kept in good repair and worn in accordance with the manufacturer’s recommendations.

d. Employees shall be provided with quality hard hats at no cost.

Eye and Face Protectiona. All employees are required to wear protective safety glasses while working in the field. Hard hats must meet the

specifications contained in the ANSI Safety Requirements for Industrial Eye Protection.

b. Certain situations require the use of face shields in addition to eye protection, such as cutting or grinding of metal or handling corrosive liquids.

c. Employees shall be provided with all necessary eye and face protection at no cost with the exception of prescription safety glasses. Employees whose vision requires the use of glasses shall be supplied with goggles that can be worn over glasses.

Foot Protectiona. Employees are required to wear leather over-the-ankle work boots that comply with the ANSI Z41 standard.

Certified work boots will have "ANSI Z41" printed inside the boot. This standard specifies impact and compression tests with which the work boots must comply.

b. Employees are not required to wear steel-toe work boots.

c. Employees are required to provide their own leather work boots for all types of weather conditions.

Hearing Protection a. Employees are required to use hearing protection devices such as ear plugs and muffs when they are exposed to

excessive noise levels as determined by OSHA, which is when noise exposure exceeds a time-weighted average of 85 decibels over the course of eight hours, or if the noise level reaches 115 for more than 15 minutes.

b. Employees will be provided with hearing PPE at no cost. Equipment will be selected relative to the tasks performed and the potential hazards.

Hand Protectiona. Cut-resistant gloves will be provided and mandatory use will be enforced to prevent hand injuries when working with

metal studs, or other materials that could cause hand or finger lacerations. Use of protective gloves will be standard procedure unless otherwise determined by the onsite supervisor.

b. Cut-resistant gloves will not be mandatory when working with materials such as drywall that are less likely to result in hand and finger lacerations. In some cases, protective gloves make it more difficult to grip drywall or other materials, which creates an additional safety hazard.

c. Employees will be provided with protective gloves at no cost.


Housekeeping / Material StorageMaterial Storage

a. Materials shall not be stored in walkways, ladder areas or near doorways that are in excess of what is needed for the immediate operation.

b. Materials shall not be stored on scaffolds or runways that are in excess of what is needed for the immediate operation.

c. Heavy materials shall not be stacked or piled at a height that could easily be toppled and create a crushing hazard.

Housekeepinga. Job sites and company property shall be kept in a clean orderly fashion.

b. Accumulation of waste materials shall be removed from the job site daily and put in proper containers. In some cases, waste material may need to be removed throughout the day if required to maintain a clean, orderly job site.

c. Tool boxes, gang boxes and company vehicles shall be maintained in a clean orderly fashion.

d. Electrical cords and tools shall be maintained in an orderly fashion.

Disposal of Waste Materialsa. Materials that are being dropped 20 feet or more shall be contained with an enclosed debris chute.

b. When debris is dropped to a lower level, the landing area shall be adequately taped off with danger tape and signs shall be posted.

Lockout / TagoutControl of Hazardous EnergyMachinery and equipment can contain hazards to workers such as, electrical, pneumatic, hydraulic and mechanical sources. Hazards may come from hot fluids, presses, blades, propellers, heat, chains, ultraviolet light, etc.

Lockout / Tagout is the safety procedure followed to make sure dangerous machines, equipment or power sources are properly shut off and not re-started which could cause injury to employees. It requires that hazardous power sources be "isolated and rendered inoperative" before a procedure is started. "Lockout" describes a locking device that prevents a power source from being turned on. "Tagout" requires that a tag be affixed to the locked device and indicating that it should not be turned on.

Lockout / Tagout Tasks To properly isolate an energy source and initiate Lockout / Tagout, do the following::

1. Identify the energy source


2. Isolate the energy source with an approved method

3. Lock the energy source with a proper device

4. Tag the energy source with an approved tag

5. Prove that isolation of the energy is effective

Release from Lockout / Tagout Before locks or tags are removed and energy restored make sure that:

1. Nonessential items have been removed from the work space

2. Equipment components are operationally intact.

3. All employees have been safely positioned or removed.

4. Affected employees are notified that the lockout or tagout devices are being removed.

TrainingAuthorized employees shall receive training in the recognition of hazardous energy sources and the type of energy sources to be locked out. Training will also cover the method for locking and tagging each piece of equipment or machinery and how to safely restore isolated energy.

Exceptions to Lockout / TagoutLockout/Tagout does not apply to work on electric equipment with a cord and plug. Simply unplugging the equipment from the power source eliminates exposure to the hazards of unexpected energization or start up.

Emergency Action PlanThis section provides a general outline for the actions to be followed in emergency situations.

Supervisor’s ResponsibilitiesThe supervisor in charge of each project is responsible for communicating with all employees and ensuring that the elements of the plan are executed properly. The supervisor must:

e. Make sure all employees are contacted in the event of an emergency. This can be verbal or by radio or phone.

f. Establish a point such as the job trailer where all employees are to meet in the event of an evacuation.

g. Account for all employees after an evacuation has been ordered.

h. Report any missing employees to emergency services personnel.

d. Manage First Aid supplies and administer First-Aid and CPR.

e. Transport any employee requiring medical treatment to an approved medical clinic.


Fire Emergenciesa. Trained employees may put out small fires with fire extinguishers. If a fire extinguisher is used, have it replaced.

b. For large fires, sound any fire alarms and evacuate the jobsite.

c. Account for all employees.

d. Take photographs of the scene. Include any property or equipment damage and any conditions that may have contributed to the fire.

e. After the fire is under control, contact the Safety Manager.

Medical Emergenciesf. Never move a victim unnecessarily to avoid aggravating any injuries.

g. Provide First Aid and/or CPR as needed.

h. Call 9-1-1 if an ambulance is required.

i. If an ambulance is not required, transport the injured employee to an approved medical clinic.

j. After the emergency is under control, contact the Safety Manager.

k. After the emergency is under control, contact the Safety Manager.

Weather-Related Eventa. Immediately suspend any work from roofs, scaffolds, ladders or other work at elevations.

b. Account for all employees.

c. Make sure all loose materials are secured to prevent flying in the wind.

d. Seek shelter indoors until it is safe to begin working again.

e. Contact the Safety Manager

Vehicle Incidents a. Check for any injuries of all persons involved in the incident and call for medical assistance as necessary.

b. Do not attempt to move injured persons except in emergency situations.

c. Move any damaged vehicles out of roadways if possible and shut down the engine.

d. Report the incident to the Safety Manager and the police as soon as possible.

e. Protect the scene by activating flashers and setting up reflective triangles if available.

f. Make a sketch of the scene and collect names and phone numbers of witnesses.

g. Take photos of the scene and damage to any vehicles. Include license plates numbers and any potential contributing factors such as road hazards.

h. Never admit fault or apologize. Apologizing may be construed as an admission of guilt.

i. Never argue with other drivers or witnesses.

j. Never argue with police.


k. Never make any statements to the media. Refer them to the company.

l. Never discuss details of the incident with anybody other than the police or company representatives.

m. Never agree with other drivers to not report an incident. They may be uninsured or the car may be stolen.

n. Never speak to anybody stopping at your home or calling at home about the incident. Refer them to the company.

Union Activitya. Never provoke picketers.

b. Call the police if necessary.

c. Contact the Project Manager.

d. Take pictures of the picketers especially if they are blocking entrance points or disrupting work.

e. Take pictures of any physical damage to the jobsite, materials or equipment.

f. Take pictures of any physical evidence such as nails dropped in travel paths.

OSHA InspectionsThe Occupational Health and Safety Organization (OSHA) is the national agency that governs worker safety. All employees should be aware of the inspection procedures of OSHA and be prepared to participate if required.

Factors that Triggers an OSHA InspectionOSHA can initiate a job site inspection for various reasons. Inspections are conducted according to the following priority schedule:

a. Imminent Danger. Responding to situations of imminent danger is OSHA’s highest priority. Imminent danger is a situation that is likely to cause death or serious physical harm. If a compliance officer witnesses any situation they consider to be an imminent danger to workers, they have the right to initiate an inspection.

b. Investigations of Fatalities and Catastrophes. Second priority is given to investigations of fatalities and catastrophic accidents.

c. Response to Employee Complaints. OSHA responds to every complaint they receive. Serious allegations may result in on-site inspections.

d. Referrals from Other Agencies. Other government agencies may refer OSHA to work sites to investigate worker safety and health conditions.

e. Random Inspections. In construction, work sites are chosen randomly for compliance inspections. Long-term or large commercial projects are almost guaranteed to be inspected at some point by an OSHA compliance officer.

f. Follow-up Inspections. OSHA has the right to conduct follow up inspections to verify abatement of previously cited hazards.


OSHA Inspection ProcedureOSHA inspectors will show up on a job site unannounced. Before the inspection begins, the inspector will hold an opening conference. Call the Safety Manager as soon as it is learned that OSHA is on site. An OSHA inspector can cite Ceiling Systems Inc. for any violations they witness at any time during any type of inspection. Violations may also cause the inspector to expand the scope of the inspection to a comprehensive inspection of the entire project.

An OSHA inspector may do any of the following:

a. Inspect the work area for unsafe acts or conditions. They will especially be concentrating on fall hazards, electrical hazards, “struck by” and “caught between” type hazards.

b. Inspectors will inspect equipment such as power tools, extension cords, scaffolds, ladders, lifts, PPE etc.

c. Inspectors may Interview workers privately. Questions should be answered truthfully but do not offer any unnecessary information.

If possible, take pictures of anything the compliance officer takes pictures of. Any hazards that are pointed out during the inspection should be corrected immediately. Do not argue with OSHA inspectors, even if you don’t agree with them. It is not a good idea to stop work while the inspector is on site. This will only aggravate the inspector and prolong the inspection.

Top 24 Most Frequently Cited OSHA Standards:1. General Requirements for Scaffolding

2. Fall Protection

3. Electrical, Wiring Design and Practices

4. Electrical Wiring Methods, Components and Practices

5. Ladders

6. Fall Protection Systems Criteria and Practices

7. Construction, General Safety and Health Provisions

8. Stairways

9. Head Protection

10. Hazard Communication

11. Manually Propelled Mobile Ladder Stands & Scaffolds

12. Fall Protection Training Requirements

13. Electrical, General Requirements

14. Asbestos

15. Concrete/Masonry, General Requirements

16. Construction, Safety Training & Education

17. Excavations, General Requirements

18. Construction, Housekeeping

19. Gas Welding & Cutting

20. Additional Requirements for Specific Scaffolding


21. Lead

22. Material Handling Equipment

23. Training Requirements for all types of Scaffolding

24. Electrical, Safety-Related Work Practices,General

Back Injury PreventionBack injuries account for a large percentage of construction related accidents. This section discusses the anatomy of the back, risk factors for back injury, how to prevent back injuries and tips for treating sore backs.

Anatomy of Your Back The term back injury may refer to an injury to any one of the following structures in your back.

a. Vertebrae. Your spine consists of a stack of 33 bones called vertebrae. The vertebrae form an S-shaped column that houses the spinal cord, the message center from your brain to your body.

b. Discs. The discs are the cushions between the vertebrae. Discs are like a jelly doughnut with a soft inner core and a tough outer coating. Herniated, slipped, bulging or ruptured disc are all terms meaning the inside of the disc is squeezing out of the tough outer coating.

c. Ligaments and Muscles. Most back injuries are strains to the muscles or ligaments in the back. These injuries typically heal completely but can recur if prevention techniques are not followed.

Risk Factors for Back Injuries. a. Lifting heavy objects, especially from low, high or awkward positions.

b. Objects lifted from below knee height or above shoulder height place additional strain on the back.

c. Performing jobs that require frequent bending.

d. Weak and fatigued muscles cannot support the back as well and are more likely to result in back injury.

e. Poor posture while standing or sitting can lead to back injury.

f. Being overweight. People more than 20% overweight are at increased risk of back injury.

Safe Lifting Practices. Most work related back injuries occur over a period of time as a result of workers using poor lifting techniques or improper body mechanics. In addition to reducing or eliminating the other risk factors listed above, following these safe lifting practices will minimize back injury and low back pain.

a. Do not move large or heavy objects manually if it can be done with a piece of equipment. Use a forklift, hoist or other piece of equipment to do the job if one is available.

b. Teamwork is important. Get help to lift heavy objects if mechanical equipment is not available.

c. Break down the load into two smaller loads if possible. Make two small lifts rather than one heavy lift.


d. Pre-plan your route before you lift heavy or large objects. Make sure there are no tripping hazards, slippery surfaces or obstacles in your way. Have someone open doors, gates, etc. for you.

e. Get as close to the load as possible. Squat down with one foot slightly forward for balance. Position the load between your legs if possible. Keep your back straight and lift with your legs. Keeping the load as close to your center of gravity as possible reduces strain on your back.

f. Try to store heavy objects between knee and shoulder height to avoid awkward lifts.

g. Place your free hand on the outside of your thigh and mentally “glue” it there. This will help keep your back aligned. Bending or tilting to the side can be just as bad for your back as bending forward.

h. Do not twist your body while lifting a heavy load. Move your feet and turn your whole body.

i. Avoid fast jerking motions when lifting a heavy load.

j. Push heavy carts rather than pulling on them. This is less stressful on the back.

Bloodborne PathogensThe following section applies to all employees who may have been exposed to blood or other potentially infectious material.

Definitionsa. Bloodborne Pathogen Pathogenic microorganisms that are present in human blood and can cause disease in

humans. These pathogens include, but are not limited to, hepatitis B virus (HBV), and human immunodeficiency virus (HIV).

b. Contaminated The presence or reasonably anticipated presence of blood or other potentially infectious materials on an item or surface.

c. Decontamination The use of physical or chemical means to remove, inactivate, or destroy blood-borne pathogens on a surface or item to the point where they are no longer capable of transmitting infectious particles and the surface or item is rendered safe for handling, use or disposal.

d. Exposure Incident When blood or other potentially infectious materials comes in contact with an eye, mouth, mucous membrane, or skin during the performance of an employee’s duties.

e. Occupational Exposure Potential exposure of blood or other potentially infectious materials coming in contact with an eye, mouth, mucous membrane, or skin during the performance of an employee’s duties.

f. Universal Precautions The concept of treating all human blood and certain human body fluids as if known to be infectious for HIV, HBV or other bloodborne pathogens.

Exposure ControlSupervisors trained in First Aid and CPR may have an occupational exposure to bloodborne pathogens while administering care to injured or ill employees. The following controls should be followed to limit the potential of an exposure incident.

a. Universal Precautions will be observed at all times to prevent contact with blood or other potentially infectious materials.


a. Employees shall wash their hands and any other skin with soap and water, or flush mucous membranes with water immediately after contact of such body areas with blood or potentially infectious materials.

b. The following Personal Protective Equipment (PPE) shall be available for use when the possibility of contact with blood or other potentially infectious materials exists:

1. Employees will wear appropriate eye and face protection as conditions warrant.

2. Latex gloves will be provided in all first aid kits and used for all care administered.

3. CPR shields equipped with a one way valve will be supplied to any individual required to perform CPR.

c. Hepatitis B Vaccination Series and Post-Exposure Evaluation:

1. Ceiling Systems Inc. shall make available the Hepatitis B vaccination to all employees who have an occupational exposure.

2. Employees have the right to refuse the hepatitis B vaccination series.

Post Exposure Evaluation and Follow-Up. Following a report of an exposure incident, a confidential medical evaluation and follow-up will be provided. They shall consist of the following:

a. Documentation of the route of exposure and the circumstances leading to the exposure incident.

b. Identification and evaluation of the source individual if possible.

c. If consent is received, the source individual shall receive screening for HIV infectivity.

d. Screening of the affected employee’s blood for HIV infectivity

e. Post-exposure treatment if necessary.

Training Only employees who participate in training for bloodborne pathogens are permitted to render first aid or CPR. The bloodborne pathogens training shall consist of the following:

a. An explanation of the bloodborne Pathogens Standard.

b. A general explanation of the epidemiology and symptoms of bloodborne diseases.

c. An explanation of the modes of transmission of bloodborne diseases.

d. An explanation of the Exposure Control Plan.

e. An explanation of the controls to be used to limit exposures to bloodborne diseases.

f. Information on the PPE to be used to control exposures.

g. Information on the hepatitis B vaccine, including its effectiveness, safety, method of administration, the benefits of being vaccinated, and that the vaccine is free of charge.

h. Information on the procedure to follow in the event of an exposure incident.

i. Information on post-exposure evaluations and follow-up treatment.


Hazard Communication (HAZCOM)The purpose of HAZCOM is to ensure that the hazards of chemicals known to be present on the jobsite are clearly labeled and communicated. Although employees of Ceiling Systems Inc., do not work with hazardous chemicals directly, they work in close quarters with other sub-contractors who utilize such chemicals.

Warning Labelsa. Each container of hazardous chemicals shall be labeled, tagged or marked with the following information:

b. Identity of the hazardous chemicals contained therein; and, appropriate hazard warnings, or alternatively, words, pictures, symbols, or combinations thereof, which provide at least general information regarding the hazards of the chemicals. The preferred hazard warning label will be the NFPA 704 Labeling System.

c. Labels are not required for portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the use of the person who performed the transfer.

Material Safety Data Sheets (MSDS)Supervisors are required to keep an up-to-date index of all hazardous material that is being used or stored onsite. This index should be kept in a location that is easily accessible if an MSDS is requested by the general contractor or local or federal agency such as OSHA. Each supervisor shall maintain a job-site poster with the MSDS index or post in the job or tool trailer.

Employee TrainingEmployees shall be provided with effective information and training on hazardous chemicals in their workplace. Employees shall be informed of the following information:

a. The requirements of the OSHA Hazard Communication Standard 29CFR1910.1200.

b. Any operations in the work area where hazardous chemicals are present.

c. The location and availability of the written Hazard Communication program, including the lists of hazardous chemicals and MSDS index.

d. Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area such as odor or visual appearance.

e. The physical and health hazards of the chemicals in the work area.

f. The measures employees can take to protect themselves from these hazards, including specific procedures such as work practices, emergency procedures, and PPE.

Carbon MonoxideThe following guidelines will help prevent adverse health effects associated with working around Carbon Monoxide (CO).


Forms of COa. CO is an odorless, colorless gas.

b. When under high pressure CO is a liquid.

Sources of COa. CO is produced as a result of incomplete burning of carbon-containing fuels including gasoline, coal, wood,

charcoal, natural gas, and fuel oil.

b. CO can be emitted by combustion sources such as unvented kerosene and gas space heaters, furnaces, wood stoves, gas stoves, fire places, water heaters, automobile exhaust, gas powered tools, and tobacco smoke.

Hazards of Carbon Monoxidea. CO is an asphyxiant to humans.

b. CO interferes with the distribution of oxygen in the blood to the rest of the body.

c. Inhalation of CO prevents blood from carrying sufficient amounts of oxygen to the brain.

d. Depending on the amount inhaled , CO can impede coordination, worsen cardiovascular conditions, and produce fatigue, headache, weakness, confusion, disorientation, nausea, and dizziness.

e. Very high levels of CO can cause death.

CO Poisoningif CO poisoning is suspected do the following immediately:

a. Get individual to fresh air immediately.

b. Turn off CO producing vehicles, equipment or tools immediately.

c. If symptoms do not improve call 9-1-1.

Asbestos Containing MaterialsAsbestos is a naturally occurring mineral that is made of tiny, sharp fibers that are too small to see, feel or taste. Asbestos was used in many building materials and products and has been associated with many health hazards when it is breathed in. Such materials may include: spray-on fireproofing, boiler and pipe insulation, duct insulation, acoustical plaster and tiles, and floor tiles.

Any material is considered to be an Asbestos Containing Material (ACM) if it contains more than one percent asbestos. A material is considered to be friable if it can be crumbled under hand pressure. Spray-on fire proofing would be considered friable. Transite pipe would be considered non-friable.

Asbestos is one of the most heavily regulated hazardous materials. Contact the Safety Manager with any questions regarding the regulations on asbestos.


Class I asbestos workWork involving the removal of thermal systems insulation or surfacing ACM. Examples include the removal of boiler insulation, pipe insulation or spray-on fireproofing.

Class II asbestos work Work involving the removal of any other type of ACM. Examples include Transite sheeting and pipe, floor tiles and mastic and roofing and siding shingles.

Class III asbestos work Repair and maintenance operations where any type of ACM is likely to be disturbed.

Class IV asbestos workMaintenance or custodial activities where ACM may be contacted but not disturbed. Includes clean up of Class I, Class II or Class III work.

Asbestos is harmful when it becomes airborne. All of the diseases related to asbestos exposure have a latency period of ten to forty years. This means that you may not become sick until up to forty years after being exposed to asbestos. Exposure to airborne asbestos has been linked to the following diseases:

Asbestosis “White Lung Disease,” a scarring of the lungs caused by chronic exposure to asbestos fibers.

MesotheliomaA cancer of the lining of the lungs or stomach. Mesothelioma is not dose-related like the other associated diseases (dose-related means the more asbestos you are exposed to, the greater the likelihood of developing an asbestos related disease).

CancerLung cancer is the most common disease related to asbestos exposure. Smokers exposed to asbestos are at a much greater risk of developing lung cancer. Exposure to asbestos is also related to cancers of the stomach.

Control Measuresa. Ceiling Systems Inc. employees are not permitted to perform any Class I removal or any Class II removal of ACM

that may become friable.

b. Employees removing or disturbing any kind of ACM must be properly trained. Class II work, Class III work and Class IV work all have specific training requirements for employees.

c. Cleanup of ACM should be done with a High Efficiency Particulate Air (HEPA) filtered vacuum cleaner so fibers are not released into the air.

d. Wet methods should be used to minimize airborne fibers. Prompt cleanup and disposal of materials in leak tight containers is required. If a lot of dust is to be created from sanding, sawing, drilling, etc., an enclosure such as a glove bag must be used.


e. Respirators with P-100 filters and disposable coveralls must be worn if friable asbestos is removed or disturbed. Work must be done in a regulated area to keep unauthorized employees away.

SilicaCrystalline silica is a basic component of soil, sand, granite, and many other minerals. Quartz is the most common form of crystalline silica. Cristobalite and tridymite are two other forms of crystalline silica. All three forms may become respirable size particles when workers chip, cut, drill, or grind objects that contain crystalline silica. Crystalline silica has been classified as a human lung carcinogen. Additionally, breathing crystalline silica dust can cause silicosis, which in severe cases can be disabling, or even fatal. The respirable silica dust enters the lungs and causes the formation of scar tissue, thus reducing the lungs’ ability to take in oxygen. There is no cure for silicosis. Since silicosis affects lung function, it makes one more susceptible to lung infections like tuberculosis.

Chronic Silicosis Chronic Silicosis occurs after 15–20 years of moderate to low exposures to respirable crystalline silica. Symptoms associated with chronic silicosis may or may not be obvious; therefore, workers need to have a chest x-ray to determine if there is lung damage. As the disease progresses, the worker may experience shortness of breath upon exercising and have clinical signs of poor oxygen/carbon dioxide exchange. In the later stages, the worker may experience fatigue, extreme shortness of breath, chest pain, or respiratory failure.

Accelerated silicosis Accelerated Silicosis can occur after 5-10 years of high exposures to respirable crystalline silica. Symptoms include severe shortness of breath, weakness, and weight loss. The onset of symptoms takes longer than in acute silicosis.

Acute Silicosis Acute Silicosis occurs after a few months or as long as 2 years following exposures to extremely high concentrations of respirable crystalline silica. Symptoms of acute silicosis include severe disabling shortness of breath, weakness, and weight loss, which often leads to death.

Control Measures a. Wearing approved respirators for protection against crystalline silica-containing dust.

b. Engineering Controls such as spraying water and proper ventilation.

c. Knowing work operations where exposure exists.

d. Wash hands and face before eating, drinking, or smoking in areas where there is dust containing crystalline silica.

e. Air Monitoring


LeadThis program applies to all projects where employees may be exposed to lead. Examples of such projects include demolition or salvage of structures where lead or materials containing lead (such as lead based paint) are present; removal or encapsulation of materials containing lead or installation of materials containing lead. Keeping lead dust out of the air and practicing good hygiene are the keys to reducing lead exposure.Lead can enter the body through inhalation when it is airborne or through ingestion. Exposure to lead effects the following systems:

Nervous System DamageMood and personality changes and retarded mental development at high doses. Lead affects the peripheral nervous system (especially motor nerves) and the central nervous system.

Kidney damageKidney damage occurs with exposure to high levels of lead, and evidence suggests that lower levels can damage kidneys as well.

Cardiovascular DamageLead exposure is associated with high blood pressure, and studies have also found connections between lead exposure and coronary heart disease

Control Measuresa. Employees exposed to airborne lead will be provided appropriate respiratory protection in accordance with the

Respiratory Protective Equipment section.

b. If large amounts of lead containing dust are created, protective clothing will be provided to prevent contamination of workers clothing and the spread of lead contamination.

c. Employees exposed to lead containing materials shall not eat, drink, smoke or apply cosmetics in the work area.

d. Work areas will be kept as clean as possible to reduce the spread of lead contamination.

e. Washing facilities will be provided to employees exposed to lead dust to wash before leaving regulated areas and taking breaks.

f. Employees who may be exposed to high levels of lead will be enrolled in a medical surveillance program to monitor blood lead levels and other indicators of lead exposure. Employees over-exposed to lead will be transferred to another project.


Temperature ExtremesThis policy will provide guidance in preventing adverse health effects associated with Hot / Cold Temperature Extremes.

Heat StressHeat is a serious hazard in construction. Your body builds up heat when you work and sweats to get rid of extra heat. But sometimes your body may not cool off fast enough. Heat Stress depends on many things: Physical condition, weather, clothing, and physical exertion. The effects of heat stress are:

a. Cramps: Often the first sign of heat related illness.

b. Dehydration: When your body loses water, you can’t cool off fast enough feeling thirsty and weak.

c. Heat Exhaustion: Symptoms include fatigue, nausea, headache, and dizziness. Skin will feel damp to the touch and look pale, ashen, or flushed and there is a possibility of fainting.

d. Heat Stroke: Skin will feel hot to touch, dry and body temperature will be very high. Confusion, convulsions, unconsciousness and death may result from heat stroke.

Safeguards for Reducing Exposure to Hot Temperature Extremesa. Drink plenty of cool water all day (Every 15 minutes drink 5-7 ounces of water)

b. Take rest breaks in cool shaded areas.

c. Wear light-colored clothing made of cotton.

d. Do the heaviest work during coolest time of the day.

Cold StressWhen in a cold environment, most of the body’s energy is used to keep your internal temperature warm. Over time, the body will begin to shift blood flow from the extremities (hands, feet, arms and legs) and outer skin to the core (chest and abdomen). This allows exposed skin and the extremities to cool rapidly and increase the risk of the following:

a. Frostbite: The freezing of body parts. Frostbite may lead to the loss of fingers, hands, toes, feet or other parts of extremities. Lack of feeling and skin that appears waxy or discolored are signs of frostbite.

b. Hypothermia: A condition when the body loses its ability to stay warm. Shivering, numbness, apathy, impaired judgement, and weakness are all signs of hypothermia.

Safeguards for Reducing Exposure to Cold Temperature Extremes:

a. Dress in layers. Cotton, wool and modern synthetics are all effective. Avoid nylon and plastics.

b. Wearing a hardhat liner. Up to 40% of body heat can be lost if head is left exposed.

c. Wear quality gloves, work boots and socks that resist water and retain body heat.


d. Stay dry and change clothing if it becomes wet.

e. Take rest breaks in warm, dry areas.

f. Work during the warmest time of the day.

Job Hazard Analysis (JHA)A job hazard analysis is a process of analyzing job tasks to identify safety hazards before they occur. It focuses on the relationship between the worker, the task, the tools, and the work environment. After hazards are identified, steps are then identified to eliminate or reduce them to an acceptable risk level.

It is important that supervisors understand that it is not the JHA document that will keep them safe on the job, but rather the process it represents. It is of little value to identify hazards and devise controls if the controls are not put in place.

The goal of a daily JHA is to determine the following:

a. How could the hazard arise ?

b. What are the consequences ?

c. How likely is it that the hazard will occur ?

d. What control measures can eliminate or reduce the hazards ?

e. If a hazard occurs, what action will be taken ?

JHA DocumentationCompleting a daily JHA document is required on most job sites. To assist supervisors with this requirement, an application for mobile devices has been developed. Supervisors without access to a compatible mobile device will be supplied with paper forms.

Disciplinary ActionThe following steps follow a progression of disciplinary action. However, Ceiling Systems Inc. reserves the right to skip steps in the disciplinary process depending on the severity of the issue.

1st Violation: Informal Meeting and Coaching

2nd Violation: Verbal Warning (documentation sent to the Safety Manager)

3rd Violation:Written Warning (may include suspension or removal from the project)

4th Violation: Final Written Warning and Termination


Employee RecordsCeiling Systems Inc. maintains a safety file for each employee. The information in each file is updated frequently to maintain accuracy. The information may require the signature of the employee to confirm accuracy. The following information will be recorded and kept in each employee’s safety file:

• Pre-Employment Drug Test• Results of Random Drug Tests• Fitness for Duty Test Results• Incident Reports Involving Employee• Record of PPE provided (signed by employee)• Training Provided or Certifications Held by Employee (signed by employee)• Employee Safety Agreement (signed by employee)• Skills and Capabilities Summary (signed by employee)• Records of Verbal or Written Safety Warnings


Healthcare ClinicWork Care Utah is the approved medical clinic for Ceiling Systems Inc. The clinic provides the following medical services:

• Comprehensive Medical and Injury Care• Pre-Employment Drug Test• Random Drug Test• Reasonable Suspicion Drug Test• Post Incident Drug and Alcohol Test• Fitness for Duty Testing• Return to Work Evaluations• Hazmat Exposure Exam• Asbestos Exposure Exam• Bloodborne Pathogen Exposure Exam

Clinic Locations

Salt Lake City Layton2390 South Redwood Road 2084 North 1700 West Suite D(801) 975-1600 (801) 773-3400

Draper Orem12422 South 450 East 601 North 1200 West(801) 748-1600 (801) 224-4211

Websitewww.workcareutah.com


Documents

Safety Program - ceilingsystemsinc.netceilingsystemsinc.net/wp-content/uploads/2013/04/Safety-Program.pdfDisposal of Waste Materials ... continually improve the safety program and