SAFETY AND HEALTH STANDARDS Contract of Service, Repair and Construction Work Effective Date: 09/30/10 Standard: 14.1 Document: KUCSH0027 Rev: 13

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1 14.1 INTRODUCTION This standard prvides guidelines and requirements t KUC emplyees wh cntemplate using a cntractr t prvide services fr Kennectt. The standard is supprted by the Cntractr Management System (CMS) DEFINITIONS Fr the purpses f this standard, cntractrs fall int three categries: Categry 1 cntractrs - Individuals engaged n temprary cntracts t wrk within existing peratins. These cntractrs are hired thrugh a Temprary Emplyment Agency r are cnsultants. Wrk is requisitined directly by the plant and the cntractr prvides persnnel withut supervisin. Categry 2 cntractrs - Cmpanies r individuals engaged fr a discrete prject which will be carried ut in a designated area that is separate frm existing peratins. These cntractrs are independent f the facility and are respnsible t KUC fr carrying ut their cntracted wrk safely and in cmpliance with applicable KUC and regulatry requirements. An example includes (Greenfield Prjects) these cntracts are fr capital prjects and are managed by a cnstructin management cmpany with versight frm KUC. Categry 3 cntractrs - Cmpanies r individuals engaged under cntract t carry ut specific tasks r prvide specified services within existing peratins. Examples f the type f cntractr that may fall int this categry include: - Service Agreements - annual cntract agreements with a specific scpe f wrk; e.g. HVAC maintenance, waste il reclamatin, etc. Each plant will have a designated crdinatr t manage these cntracts. - Capital / Plant Requisitined Wrk - cntracts that are requisitined directly by plant persnnel. The cntractr prvides direct supervisin fr the wrk. Permit t Wrk (PTW) a permit required fr Categry 3 cntractr wrk. The PTW system ensures that cntractrs are fully infrmed and understand the principles f the permit and that the cntractr emplyees have been given the apprpriate training and understands their specific respnsibilities. Safety, Health, and Envirnmental Analysis (SHEA) an analysis that is prepared by the requestr f cntractr services and prvided t each cntractr with the prject bid infrmatin. The analysis will enable Page 1 f 19

2 the cntractr t better address the ptential safety, health, and envirnmental cncerns assciated with the prject t ensure that there is adequate pre-planning. Safety, Health, and Envirnmental Actin Plan (SHEAP) an actin plan prepared by the cntractr t address all issues raised in the Safety, Health, and Envirnmental Analysis (SHEA) REQUIREMENTS All Categry 1 cntractrs are t be treated in all aspects f safety, health and envirnmental as if they were KUC emplyees. Training cnsideratins must include New Emplyee Orientatin, Plant Safety Orientatin, Task Training and Refresher Training, as apprpriate. This type f cntractr requires a Categry 1 Cntractr hire frm t be entered thrugh ServU. These cntractrs must g thrugh initial cntractr rientatin but need nt g thrugh the annual renewal prcess if they have wrked all year and received all the KUC required training All Categry 2 cntractrs must have apprpriate safety systems and supervisin in place. The cntractr s safety duties must be embedded in the cntract and audited t see that the cntractr carries ut its safety duties in accrdance with the cntract and with applicable KUC and regulatry requirements. A cntractr safety representative is required t crdinate the safety prgram and mnitr implementatin and cmpliance Categry 3 cntractr s respnsibilities vary accrding t the nature f the wrk and its lcatin. The KUC Field Supervisr and Cntract Administratr must apply the requirements set ut in this standard as deemed apprpriate. Fr shrt-term wrk, the KUC representative wh requisitined the wrk will review the Safety, Health and Envirnmental Analysis and Risk Assessment Pre-jb Meeting Checklist (available n the KUC CMS Intranet website) and ensure site-specific hazard training is prvided t the cntractr emplyees prir t entering the prperty. Fr lng-term wrk, pre-bid, SHEA, pre-jb, SHEAP, and Site Specific Safety Orientatin are required. A cntractr safety representative may be required if the wrkfrce is large r wrk is cmplicated The fllwing chart is a summary f the types and the requirements that apply. Page 2 f 19

3 REQUIREMENTS CAT 1 CAT 2 CAT 3 Cnstructin Service Management Agreements Cntracts Temprary Replacement Persnnel Capital / Plant Requisitin Wrk Apprved Cntractr X X X Prf f Insurance X X X SHEA X X X Pre-bid Meeting X X X Pre-jb Meeting X If emergency r shrt duratin use Safety, Health and Envirnmental Analysis and Risk Assessment Pre-jb Meeting Checklist SHEAP X X X Hazard training / Site X X X X Specific Safety Orientatin Drug Test X X X X All Categry 2 and 3 cntractrs shall be safety pre-apprved t perfrm wrk n KUC prperty. Safety pre-apprval will be based n the cntractr s past safety perfrmance, safety prgram, regulatry recrd, and insurance cmpany rating. An apprval status list f cntractr and vendr cmpanies is available n the KUC CMS Intranet website. KUC has chsen t use a third-party t cllect the required cntractr pre-qualificatin infrmatin. The third party cllects and tabulates the required infrmatin and prvides an nline summary reprt t KUC. The KUC Safety Department reviews the safety pre-apprval submissin and makes a determinatin as t the cntractr s Safety Apprval status. Bid submittals will nt be cnsidered cmplete unless all f the requested safety related infrmatin is prvided. Cntractrs will als be required t submit t KUC an riginal signed certificate f insurance fr: - Statutry Wrker's Cmpensatin Insurance fr all emplyees. Such Insurance shall cver claims filed under the Wrker's Cmpensatin Law f the State. - Emplyer's Liability Insurance. - Cmprehensive General Liability Insurance. - Cmprehensive Autmbile Liability Insurance. Nte: Insurance requirements and limit f cverage are available n the KUC CMS Intranet Website Fr additins t the cntractr list, the cntractr r KUC representative must cntact Ri Tint Prcurement (RTP) fr a prequalificatin packet The Plant Manager may authrize a nn-apprved cntractr fr an emergency r a jb f shrt duratin, but nly when an apprved cntractr qualified t d the wrk is nt available. Page 3 f 19

4 The KUC Field Supervisr r Cntract Administratr in all such instances shall hld a Pre-jb meeting. (The Safety, Health and Envirnmental Analysis Pre-jb Meeting Checklist is available n the KUC CMS Intranet Website) The cntractr representative must sign the Pre-jb meeting frm and review all infrmatin presented with all emplyees wrking n the jb The requestr f cntractr services must prepare a Safety, Health, and Envirnmental Analysis (SHEA) fr each prpsed prject. (Exhibit ) The KUC Safety and / r Envirnmental representative shuld apprve the analysis prir t distributin t the cntractr A pre-bid cmmunicatin meeting will be held with all prspective bidders t discuss the scpe and requirements f the prject as needed. Safety, health, and envirnmental requirements identified in the SHEA will be included as part f the meeting agenda. The bid assessment must include cnsideratin f the cntractr s safety plan and ability t implement the plan. Safety cnsideratins shall receive n less weight than ther cnsideratins such as csts and technical capabilities The cntractr must prepare a site specific Safety, Health, and Envirnmental Actin Plan (SHEAP). KUC Safety and Envirnmental representatives must apprve the SHEAP befre wrk will be allwed t prceed. If scpe changes are made in a prject, n assciated wrk will prceed until all apprpriate changes r amendments are made t the plan and the revised plan is apprved and cmmunicated t all affected parties. Fr emergency jbs r shrt duratin jb with a lw degree f hazard, the cmpletin f Safety, Health, and Envirnmental Analysis Pre-jb Meeting Checklist may serve as a SHEAP Pre-jb safety meetings are required fr all cntractrs entering cmpany prperty regardless f the jb r time span invlved. The KUC Field Supervisr r Cntract Administratr will schedule and cnduct the prejb cnference using the Safety, Health and Envirnmental Analysis Prejb Meeting Checklist The cntractr must cmplete a Cntractr Cntrl Sheet (available n the CMS KUC Intranet Website) verifying that; within the last twelve (12) mnths: The cntractr has perfrmed all required regulatry medical examinatins, and substance abuse tests and that these dcuments will be n-site fr verificatin. Page 4 f 19

5 That each emplyee listed n the sheet has, where required, received a respiratr fit test, and all ther MSHA / OSHA training, as apprpriate. Dcumentatin f this training must be available fr verificatin. The cmpleted Cntractr Cntrl Sheet will be required befre the cntractr emplyees are scheduled fr Cntractr Orientatin Training and receive a KUC gate pass. The Cntractr Crdinatr is respnsible t schedule the rientatin. Cmpleted paperwrk must be submitted when scheduling the cntractr fr Orientatin (See SOP CMSSOP10018 Cntractr Orientatin Training). The infrmatin will be used t create a persnnel recrd ID # fr the cntractr emplyee and subsequently stre pertinent safety training recrds fr that cntractr emplyee. If the scheduled KUC rientatin training class is nt used, an Exceptin frm must be signed by the plant Manager / GM r designee, and the frm must be sent the Admin Assistant with the cmpleted Cntrl Sheets. Exceptin frms and a detailed prcess flw map are available n the KUC CMS Intranet Website Where cntractrs are wrking in OSHA regulated areas (designated areas in the Smelter and Refinery) there must be a prvisin fr medical surveillance and a written Cmpliance Plan (See OSHA Standards CFR and ). The Plan must Establish a written prgram that includes engineering cntrls t reduce expsures. Cntain mnitring data. Be updated at least every 6 mnths A Permit t Wrk (PTW) is required fr cntractr wrk. (See Exhibit r Exhibit fr Undergrund Mining). The PTW must: (a) Set ut the wrk t be dne, identify the hazards and the required safe wrk prcedures. (b) Be reviewed every shift and reissued if a change in cnditins r wrk scpe has ccurred. (c) Be signed by a designated manager fr the current shift wh is the persn with respnsibility fr the gegraphical area r fr the task t be cmpleted. Cntractr that may fall under a Permit t Wrk exemptin must be prperly identified thrugh a risk assessment analysis f the tasks they perfrm. Page 5 f 19

6 Each department shall identify and train individuals Qualified Persns that are authrized t issue a Permit t Wrk. Authrizatin shall be valid fr a maximum perid f ne (1) year after which refresher training and re-authrizatin shall take place. The Qualified Persn will: Understand the scpe f wrk and facilitate a dialgue t make clear t the persn(s) carrying ut the jb, the hazards and risks invlved and precautins t be taken t cntrl the hazards; and minimize their risks. Make sure that the necessary pre-cautins are implemented, including islatins, befre wrk begins. Ensure all peple wh may be affected by the wrk are infrmed befre the wrk begins, when the wrk is suspended, and when the wrk is cmplete. Ensure effective arrangements are made fr the wrksite t be examined befre wrk begins, n cmpletin f wrk, and as apprpriate when wrk is suspended. Ensure cmmunicatins are made t discuss all nging r suspended permits with the ncming permit issuer and all changing cnditins r prcess changes that present a knwn hazard are cmmunicated Each facility shall develp an audit prcess t ensure the Permit t Wrk system is functining effectively All individuals wrking within the Permit t Wrk system will ensure that: They d nt start any wrk requiring a permit, until it has been prperly authrized, issued, and the necessary precautins have been taken. They have received instructin and have a gd understanding f the permit system at the wrkplace where the wrk is ccurring. They d nt start any wrk they suspect requires a permit, until it has been prperly authrized and issued r cnfirmatin received that a permit is nt required fr the planned scpe f wrk. They receive a briefing frm the Qualified Persn n the particular task and they understand the hazards and the precautins t be undertaken SERVICE VENDORS / SUPPLIERS - The fllwing applies t thse entering cmpany prperty that d nt fit the definitins f Categry 1, 2 r 3 cntractrs as described in and are nt cnsidered visitrs as described in KUC Safety and Health Standard 12.1 Visitr s Plicy. This grup includes individuals wh pickup r deliver materials, shrt term Page 6 f 19

7 service wrkers, emplyees f equipment manufactures, r fields r sales representatives all generally referred t as service vendrs r suppliers All service vendr and supplier cmpanies that send emplyees t KUC prperties are respnsible fr the fllwing: Emplyees cmply with all KUC Hazard and site specific training requirements prvided. Emplyees are in cmpliance with all regulatry training requirements fr the service they are t prvide and have received all required and apprpriate skills training fr any task that they are perfrming. If the specific jb assignment is fr frequent r extended perids, and ptential expsure t hazards, cmprehensive training is required that meet all KUC and regulatry requirements Dcumentatin f all training is available and shall be prvided as requested by KUC. Emplyees cmply with all applicable regulatry standards related t the tasks they are perfrming. All emplyees are cmpetent t understand instructins r warnings in English; bring t the attentin f thers unsafe cnditins r actins; and give adequate verbal warnings f unsafe cnditins r actins (unless granted an exceptin as identified in ). Emergency cntact infrmatin fr each emplyee entering KUC prperty is maintained and readily available KUC is respnsible fr the fllwing regarding service vendrs and supplier cmpany emplyees: The KUC Security Officer r designated KUC representative at each plant must prvide service vendrs r suppliers Plant Hazard Training and issue each persn a "Hazard Training" card, which is valid fr 12 mnths. In the event the service vendr r supplier cannt prduce the receipt fr hazard training, r if training is mre than 12 mnths ld, the service vendr r supplier will be required t cmplete the training and receive a new card. Security Officers r a designated KUC representative must visually check and ensure that service vendrs r suppliers are prperly equipped with persnal prtective safety equipment. Emplyees wh are n the site in a service r maintenance capacity must be given training in accrdance with their expsure t hazards. If the specific jb will nt entail expsure t hazards at the facility, they need nly be given hazard training. The designated KUC representative must ensure that all required site specific training is identified and prvided i.e. site specific driver s license, Prcess Page 7 f 19

8 Safety Management (OSHA PSM), respiratr requirements etc Delivery Persns (Individuals wh are briefly n prperty t pick up r deliver materials) The extent f delivery persns' expsure t facility hazards varies. Cmprehensive training is nt required if there is n expsure t facility hazards. Delivery persns must receive hazard training cmmensurate t their expsure t hazards. In additin, they must be trained in the health and safety aspects and safe perating prcedures f any machinery r equipment that they are required r allwed t perate while n mine prperty. (See KUC Delivery Driver Unlading Standard 14.4) RESPONSIBILITIES Ri Tint Prcurement (RTP) is respnsible fr cntracting fr services n behalf f KUC. RTP is respnsible fr: Sliciting bids nly frm cntractrs n the KUC Apprved Bidder List. Cmpiling a cntract with general and special terms and cnditins. RTP will ensure that the cntractr s safety duties are embedded in the cntract. The cntract dcument must cntain prvisins cvering safety including: - Cntractr respnsibility t cmply with the KUC safety plicy, rules and prcedures, and all applicable laws. - Prf f adequate levels f insurance. - Indemnificatin agreement and terminatin clause r penalties fr lack f perfrmance in safety KUC is respnsible fr the day-t-day management f the cntractr and the administratin f the cntract. The KUC service requestr (persn wh identifies the need fr cntractr services and wh has the authrity t request the services f a cntractr) is respnsible fr: Preparing a scpe f wrk including a Safety, Health, and Envirnmental Analysis (SHEA) The KUC Plant Manager is accuntable fr: Authrizing a nn-apprved cntractr fr an emergency r a jb f very shrt duratin when an apprved cntractr qualified t d the wrk is nt available. The Permit t Wrk system and implementatin within their wn facility. The Plant Manager will ensure that: - All persnnel wh perate r use the PTW are trained and cmpetent t d s. Page 8 f 19

9 - An audit prcess is in place t ensure the system is functining effectively The KUC Field Supervisr is the n-site manager wh is respnsible fr ensuring the effectiveness f the cntractr safety management system in relatin t the cntract. The KUC Field Supervisr is respnsible fr: Ensuring that the cntractr emplys an audit prcess that will ensure that the cntractr carries ut all safety duties in accrdance with the cntract and with applicable regulatry requirements. Ensuring that, where practical, the wrk area is clearly demarcated. Ensuring a Permit t Wrk system is implemented - Ensuring that the permit is available fr inspectin at the wrkplace. - Mnitring the wrk t check cmpliance with the permit cnditins. Reprting and recrding all cntractr safety incidents, accidents, injuries and near miss incidents. - A cpy f the cntractr's accident investigatin reprt must be submitted by the end f the shift. Reviewing the cntractr's accident investigatin reprt and cmpleting a fllw-up investigatin. A cpy f the cmpleted accident investigatin must be sent t the KUC Safety Department. Prviding ttal man-hurs wrked fr each cntractr under his / her jurisdictin t the KUC Safety Department by the last day f each mnth. Cmmunicating when required between KUC and a cntractr during a prject. The KUC Field Supervisr r designee will be the single persn respnsible fr the cmmunicatins. All ther affected KUC persnnel must be made fully aware f any issue. When cntractrs are wrking clsely (same area r nearly, same equipment r nearly) with KUC emplyees, the cntractr Safety, Health, and Envirnmental Actin Plan (SHEAP) will be discussed in detail with the KUC area supervisrs The KUC Cntract Administratr is respnsible fr the daily administratin f the cntract including: Cmpliance and implementatin f the CMS requirements. Ensuring cmpliance with the KUC Management f Change requirements when apprpriate. (See KUC Safety and Health Standard 14.3) Mnitring the activities f the cntractr, and cmpleting frmal reviews with the cntractr that includes safety perfrmance, and Page 9 f 19

10 capturing and acting n safety imprvement ideas. Actin plans will be agreed and dcumented t crrect nted deficiencies. Ensuring that the Permit t Wrk is implemented. Ensuring that Cntractr emplyees have been given the apprpriate Permit t Wrk training The cntractr is respnsible fr running a safe jb-site and fr cmpliance with all prvisins f this standard. The cntractr is respnsible fr: Preparing a Safety, Health, and Envirnmental Actin Plan (SHEAP) addressing all issues identified in the Safety, Health, and Envirnmental Analysis (SHEA). Require each emplyee t prepare a Persnal Health and Safety Plan. Cmpleting a Cntractr Cntrl Sheet fr all emplyees that will be perfrming wrk n KUC prperty. Cnducting jb specific training prir t beginning wrk that will include a review f the SHEAP and pre-jb checklist. Verificatin that the training has been cmpleted must be prvided t the Cntract Administratr. Reprting immediately all accidents / injuries t the apprpriate plant Cmmunicatins / Cntrl Center and t the KUC Field Supervisr, cmpleting an accident investigatin reprt and submitting a cpy by the end f the shift. Prviding verificatin f a Drug Plicy. Cnfirming that all tls and equipment t be used are in a safe cnditin. Prviding t the KUC Field Supervisr the fllwing dcumentatin as required: - Accident and injury investigatin reprts summaries and fllw-up. - General inspectin reprts. - Outside agency inspectin reprts. - Recrds f safety meetings. Fully implementing the requirements f the Permit t Wrk System and ensuring that all emplyees receive and understand the Permit t Wrk training. - Permit precautins are maintained thrughut the wrk activity s that the wrker understands that if circumstances change, wrk must be stpped and advice sught. - The wrkgrup stays within limitatins set n the permit (physical bundaries, type f wrk, and duratin f permit). - On cmpletin r suspensin f wrk, the site is left in a safe cnditin and the Qualified Persn is infrmed. Page 10 f 19

11 TRAINING Befre wrk begins n any cntract, all cntractr persnnel must be given apprpriate rientatin and inductin training including emergency prcedure drills, and attend all required hazard training and site-specific rientatin and training All cntractr cmpanies must assure KUC that they are in cmpliance with all regulatry training requirements fr each wrker by certifying that the training has been cmpleted and that the required dcumentatin is available upn demand English Language Requirements All Cntractr emplyees must be able t read and speak the English language sufficiently t allw them t: Understand and cmply with verbal and / r written safety requirements and instructins, and warning signs and labels; Understand and be capable f executing emergency ntificatin and emergency management prcedures; Bring t the attentin f English speaking emplyees any unsafe cnditins r actins; and Participate in and understand pre-task risk assessments and effectively participate in a KUC Quality Safety Interactin (explain in English the wrk they are perfrming; the risks assciated with the tasks; and hw thse risks are being cntrlled) Exemptin t English Language Requirement Nn-English speaking (NES) Cntractrs may be allwed t perfrm wrk at KUC if they receive an exemptin in accrdance with the requirements f this paragraph. Exemptins may be requested when English speaking wrkers with the required skill set are nt available thrugh nrmal channels and the use f nn-english speaking wrkers will nt cmprmise HSE requirements. NES exemptin request - The KUC Cntract Administratr is respnsible fr requesting the exemptin by cmpleting a KUC Level 1 nline Risk Assessment including all HSE aspects (i.e. number f peple invlved, number f bi-lingual emplyees required, expsures, safety cntrls etc.) The NES exemptin request must include the fllwing: - Date / Plant / Lcatin / Scpe f Wrk - Name f Cntracting Cmpany - Name f NES Cntractr/s - Relevant language - Prpsed date / duratin f tasks Page 11 f 19

12 - Verificatin f Minimum NES Safety Cntrls (attach dcumentatin) - Risk Assessment (Level 1) Minimum Nn English Speaking (NES) Safety Cntrls. As a minimum, the fllwing NES safety cntrls must be applied t any NES Cntractr wrking at KUC. Training - The cntractr must prvide training t the NES cntractr in the relevant nn-english language including: - KUC Orientatin infrmatin and all plant and task specific KUC and / r regulatry training. - Validatin f participant s knwledge will be demnstrated by achieving passing scre n required test. - Dcumentatin t verify training must be available. Bi-lingual cntractr emplyees - There will be an adequate number f bi-lingual cntractr emplyees assigned with the nn English speaking wrkers at all times, als bi-lingual HSE representatives may be a required full-time psitin depending n the jb scpe and Risk Assessment. The exemptin must be: - Cmpleted and signed by the KUC Cntract Administratr; - Reviewed and signed by a Plant Safety Advisr; - Reviewed and apprved by the Plant GM/M RECORDKEEPING The KUC Cntract Administratr will maintain cpies f Pre-bid / Pre-jb cnferences, SHEAs, SHEAPs, audits, and accident investigatin reprts The cntractr is respnsible fr maintaining all required regulatry recrds including hazard training, site-specific rientatin, emergency prcedure drills, all required medical examinatins, substance abuse tests, respiratr fit test, and all ther MSHA / OSHA training, as apprpriate The cmpleted Permit t Wrk must remain at the jb site until the wrk is cmpleted and then frwarded t the facility recrd strage center / lcatin where they are t remain n file fr 2 years. REFERENCES: KUC Safety and Health Standard 12.1 Visitrs Plicy KUC Safety and Health Standard 14.3 Management f Change KUC Safety and Health Standard 14.4 Delivery Driver KUC Safety and Health Standard 16.2 Cnfined Space Entry Page 12 f 19

13 KUC Safety and Health Standard 16.4 Cranes and Hists KUC Safety and Health Standard 16.5 Aerial Lifts and Platfrms KUC Safety and Health Standard 16.7 Scafflds KUC Safety and Health Standard Islatin KUC Safety and Health Standard Fall Prtectin, OSHA Standards CFR and HSEQ MS Element 7 Supplier and Cntractr Management KUC Cntractr Management System (CMS) Lcated n the KUC Intranet Website KUC SOP CMSSOP10018 Cntractr Orientatin Training REVISION HISTORY: MOC# Descriptin f Change Prepared By Date TS00125 Add Exhibit Undergrund Mining Permit t Wrk; add Service Vendrs / Suppliers; Update Cntractr Cntrl Sheet t include SAP required infrmatin Safety and Health Standards Cmmittee 07 / 2007 T10012 Changes submitted as the result f a Cntractr Orientatin Six Sigma prject review and update, Cntractr Safety Imprvement Prject - English Language Requirements, and a review f the Permit t Wrk requirements. Transferred insurance limits, Pre-jb Checklist and Cntractr Cntrl frms t KUC CMS nline website. Updated frmat and Dcument number added Revised Permit t Wrk t define when an area inspectin is required Revised Permit t Wrk t imprve clarity and intent. The key message is that n wrk may start until the items checked n the permit are cmpleted. Safety and Health Standards Cmmittee Safety and Health Standards Cmmittee Safety and Health Standards Cmmittee 08 / / /2010 Page 13 f 19

14 Exhibit SAFETY, HEALTH & ENVIRONMENTAL ANALYSIS (SHEA) OUTLINE (Cntractr is respnsible t address each item identified in a Safety, Health, and Envirnmental Actin Plan - SHEAP.) Prject Title And Scpe Of Wrk Descriptin f Prject including the equipment t be used. Jb Hazard Analysis (Risk A summary f each phase f the prject r area f wrk Assessment) and Required identifying all ptential hazards, including safety, health Cmpliance and envirnmental. Management Of Change Review Safety and Health Standard Air Pllutin Descriptin f knwn air pllutin prblems and mnitring requirements. Water Pllutin Descriptin f knwn water pllutin and mnitring requirements. SPCC Descriptin f SPCC Plan (i.e., spill cntainment). Slid Waste Management Descriptin f knwn slid waste management issues (i.e., where material will be stred, remval f spent cntainers and unused prduct). Hazardus Waste Management Descriptin f any knwn hazardus waste issues and acceptable dispsal techniques. Remediatin Descriptin f plans t address cntaminatin f sils. Medical Surveillance Requirements, if any; (i.e. physicals, respiratr use, medical certificatin, bld/urine tests). Training Training required such as safety rientatins, task training, hazard training, regulatry required, ISO General Awareness etc. Fire Prtectin Type required fr this prject. Safety Hazards Descriptin f knwn hazards such as high wrk, crane use, cnfined space etc. Safety Meetings Type and schedule f meetings. Persnal Prtectin Descriptin f required prtectin and special equipment. Inspectin Prcedures Hw and by whm the prject will be inspected and mnitred. Standards Descriptin f which standards apply t Prject; i.e., UOSH, MSHA, EPA, etc. Als, descriptin f which KUC/Ri Tint and site specific standards apply t the prject. Testing & Permits Descriptin f required testing and permits (i.e., Cnfined Space, Ht Wrk, Permit t Wrk, etc.). Descriptin f lgs, reprts, phtgraphs, training Recrdkeeping recrds etc. required fr this prject. Other Anything nt cvered abve. Page 14 f 19

15 Exhibit PERMIT TO WORK (Standard 14.1) Rev 7 08/10 Originated By: (Print Name Belw) Qualified Persn: (Print Name Belw ) Qualified Persn: (Signature Belw) Date and Time Issued: AM PM Equipment Number / Descriptin: Lckut Bx / Bard: Wrk Descriptin: Wrk Area / Specific Lcatin: Wrk Order / PO Number: Cntractr Name and Phne #: Cntractr Supervisr: PRE-JOB REVIEW 1. Has a visual inspectin f the wrksite been perfrmed by a Qualified Persn and the cntractr r designated KUC maintenance persnnel? NOTE: A visual inspectin may be mitted based n the judgment f the Qualified Persn if: - There is a frmal risk assessment which shws that a visual inspectin is nt necessary, r - An initial visual wrksite inspectin was cnducted with the persnnel perfrming the wrk and the Qualified Persn, there have been n significant changes in the wrksite, and the jb is rutine r repetitive in nature. 2. Has a cnversatin taken place abut the hazards assciated with the wrk prir t starting the wrk? Yes N 3. Did the Qualified Persn and cntractr persnnel review the TRACK CARD prir t beginning the wrk? Yes N 4. Shuld a safety, health, and / r envirnmental representative be invlved in this wrk? Yes N If items 2 r 3 are marked N d nt prceed with the wrk. Cnsult the apprpriate Area Supervisr. EMERGENCY NUMBERS (All Incidents must be reprted thrugh the Plant emergency ntificatin system) Mine Cppertn Smelter Refinery / MAP Pwer Plant Tailings AREA Check thse that apply (Required t be cmpleted befre wrks begins) Equipment Cnditin Pressurizatin Islatin Electric Pwer Preparatin In service Pressurized Lck and Tag Breaker Lcked Out Water Washed Out f Service Bleeds Open Blck / Blind Fuses Remved N2 Purged Prduct in Line Vented Valved Grunded Steam Purged Drained Ventilatin Required Other Other N Purge Required Other: Other r nn applicable Nt Required Nt Required Other: POSSIBLE HAZARDS and PRECAUTIONS (Required precautins must be reviewed with wrkers befre wrk begins) Ht Surfaces / Burns Carbn Dixide Oxygen Depletin Barricade Area Txic gases Hydrgen Sulfide Gas Oxygen Enrichment Prper Warning Signage Caustics Sulfur Dixide Gas Radiatin Device Fire Prtectin Acid Sulfur Trixide Gas Pinch Pints GFCI Regulated Prcess Dust Arsine Gas Avid Skin Cntact Arc Flash / Shck / Electrcutin Trips / Falls/Slippery Surfaces Carbn Mnxide Steam Blasting Haul Rads Kress / Mine Ammnia Gas Access Rad Cnditin High Vltage Trail Cable Other knwn ptential hazards nt identified abve: (describe) REQUIRED PERMITS (T be cmpleted befre wrk begins) Cnfined Space Excavatin Ht Wrk Persnnel Histing Wrking at Heights Clse Prximity Fire Prtectin Impairment Jumper Scaffld Crane Critical Lift Line Break Permit t Unlad ADDITIONAL PERSONAL PROTECTION EQUIPMENT REQUIREMENTS Chemical Resistant Clthing Heat Resistant Clthing Glves Fall Prtectin Hearing Prtectin Gggles / Face Shields Respiratr Cveralls, Sleeves / Hds Other: WORKER REVIEW and ACCEPTANCE - I have been instructed as t the cnditins f this permit and I am adequately trained t perfrm this wrk. Print Name Signature Date Nte: If additinal space is required fr authrized persnnel, an additinal rster sheet may be attached t the permit. SHIFT CHANGE INSPECTION/ACCEPTANCE - Wrk cnditins are at the date and time f issue. Cntractr persnnel must verify the cnditins and apply designated safeguards fr their wn prtectin. KUC shall mnitr the wrk site n a regular basis. If the permit extends t the next shift, it must be revaluated at the wrk site fr accuracy at the beginning f each shift. This permit is vid if wrk r scpe cnditins change. Yes Nt Required Date Shift Time AM PM AM Any Change in Cnditins r Wrk Scpe? (1) Checklist Area Demarcated Permit Psted Permit Cmpliance N Incidents Safety Imprvements Area Demarcated Permit Psted Cntractr Acceptance (Print Name and Sign) KUC Acceptance (Print Name and Sign) Page 15 f 19 supersede all ther revisins.

16 PM Permit Cmpliance N Incidents Safety Imprvements WORK COMPLETION r CANCELLATION Cmpletin r Cancellatin Date: Cmpletin r Cancellatin Time: AM PM If cancelled, prvide reasn: Cntractr Acceptance Signature: Qualified Persn Acceptance Signature: Page 16 f 19 supersede all ther revisins.

17 (Back f Permit) Permit will be psted at wrk site until wrk is cmplete r a new permit is issued. This permit must be reviewed every shift r if a change in cnditins r wrk scpe has ccurred. Expired permit must be sent t the Cntract Administratr. The maximum duratin f the permit is 24 hurs. If changes in cnditins r wrk scpe exist, then a permit must be reissued. A mdified SHEAP and Management f Change may be applicable. The purpse f the Permit t Wrk System is t: Prvide fr the prper authrizatin f cntractr wrk and the identificatin f respnsible persnnel. Prvide fr a dialgue between the Qualified Persn and cntractr t make clear t the persn(s) carrying ut the jb the hazards and risks invlved and precautins t be taken t cntrl the hazards and minimize risks. Ensure that the persn respnsible fr an area f the facility is aware f all wrk being undertaken in their wrkplace. Assure that the equipment r system has been prperly prepared fr the crrespnding task. Assure that perating persnnel understand when the wrk is cmplete, the extent and effect f repairs, and that the repair is acceptable and safe fr peratin. The Qualified Persn wh issues the permit will: Understand the scpe f wrk and facilitate a dialgue t make clear t the persn(s) carrying ut the jb, the hazards and risks invlved and precautins t be taken t cntrl the hazards and minimize their risks. Cnduct a visual inspectin f the wrk site with the cntractr persnnel unless there is a frmal risk assessment in place which shws that a visual inspectin is nt necessary, r if an initial visual wrksite inspectin was cnducted with the persnnel perfrming the wrk and the Qualified Persn, there have been n significant changes in the wrksite, and the jb is rutine r repetitive in nature. Stress the requirement that the necessary precautins need t be implemented, including islatins, befre the wrk begins. Be trained and prperly listed as a Qualified Persn. Ensure all peple wh may be affected by the wrk are infrmed befre the wrk begins, when the wrk is suspended and when the wrk is cmplete. Ensure effective arrangements are made fr the wrksite t be examined n cmpletin f wrk and as apprpriate when wrk is suspended. Ensure that cmmunicatins are made t discuss all nging r suspended permits with the ncming permit issuer. Cntractr Supervisrs will ensure that: They have received training in the Permit t Wrk System and the peple wrking fr them have received adequate instructin n the system. Permit precautins are maintained thrughut the wrk activity s that the wrker understands that if circumstances change wrk must be stpped and advice sught. The wrkgrup stays within limitatins set n the permit (physical bundaries, type f wrk and duratin f permit). Individuals wrking within the permit t Wrk System will ensure that: They d nt start any wrk requiring a permit, until it has been prperly authrized and issued. They have received instructin and have a gd understanding f the permit t Wrk System at the wrkplace where the wrk is ccurring. They d nt start any wrk they suspect requires a permit, until it has been prperly authrized and issued r cnfirmatin gained that a permit is nt required fr the planned scpe f wrk. They receive a briefing frm the Qualified Persn n the particular task and they understand the hazards and the precautins t be undertaken. On cmpletin r suspensin f wrk the site is left in a safe cnditin and the Qualified Persn is infrmed. Page 17 f 19 supersede all ther revisins.

18 Exhibit Undergrund Mining Permit t Wrk Standard 14.1 Cntractr Cmpany Name: Cntractr Supervisr: Wrk Lcatin: Wrk Descriptin: Rev. 1 07/07 Cntractr Persnnel must verify the cnditins and apply designated safeguards fr their wn prtectin. KUC Persnnel shall mnitr and evaluate the jb site n a regular basis. PRIOR TO BEGINNING WORK, THE FOLLOWING MUST BE REVIEWED AND MET HAZARD RECOGNITION Cntractr has been infrmed f the ptential hazards assciated with their wrk. COMPLETED: YES NO SITE SPECIFIC ORIENTATION - Cntractr has been riented t the specific prject r wrk area including evacuatin and vehicle driving requirements. COMPLETED: YES NO TRACK PROGRAM/RISK ASSESSMENT -TRACK Prgram and / r risk assessments assciated with this wrk reviewed with cntractr and JHA s cmpleted. COMPLETED: YES NO PERSONAL PROTECTIVE EQUIPMENT SAFETY STANDARDS REVIEW REQUIRED PERMITS Hardhat Safety Glasses with Sideshields Metatarsal Bts Hearing Prtectin Glves CHECK ALL THAT APPLY Respiratr Self Rescuer Fall Prtectin Face Shield Mine Lights Other: Cntractr has been infrmed f the fllwing KUCC standards relevant t the wrk being perfrmed Emergency Respnse Plan Wrking at Heights Mbile Equipment Cnfined Spaces Islatin and Lckut Ht Wrk Electrical Safety Undergrund Mine Standards Hazardus Chemicals Grund Cntrl Requirements Ventilatin Plan Other: CHECK ALL THAT APPLY Cnfined Space Ht Wrk Wrking at Height Scaffld Line Break Persnnel Histing Excavatin Clse Prximity Other: CHECK ALL THAT APPLY LIST ADDITIONAL IDENTIFIED HAZARDS LIST ADDITIONAL REQUIRED SAFE WORK PROCEDURES Jb Site is prepared t turn ver t Cntractr? YES NO Nt Applicable Permit t be Renewed Each Shift Each 24 Hurs This permit is always subject t terminatin if lcatin, scpe f wrk, r cnditins change. Permit Start Date: Time: Expected Permit End Date: Time: CONTRACTOR VERIFYING AND ACCEPTING PERMIT Name: Signature: Date: Time: KUC UNDERGROUND QUALIFIED PERSON AUTHORIZING PERMIT Name: Signature: Date: Time: Page 18 f 19 supersede all ther revisins.

19 (Back f Permit) PERMIT REVIEW AND ACCEPTANCE: Permit requirements and all pertinent safety and health requirements must be explained t all wrkers wh will perfrm wrk under this permit. This permit will be reviewed and signed prir t the start f wrk and at each permit renewal by the cntractr wrkers wh will be wrking in the area cvered by this permit. A list f wrkers may be attached t this permit if there is insufficient space belw. DATE TIME PRINT NAME SIGNATURE Cmments WORK AREA INSPECTION AND PERMIT RENEWAL: The KUC Undergrund Qualified Persn verifies each shift that lcatins, scpe f wrk, and cnditins meet KUC standards. This permit will be terminated and a new Permit t Wrk will need t be issued if lcatins, scpe f wrk, r cnditins change r if all spaces belw have been filled. Any YES checked belw will require immediate permit terminatin. Wrk Lcatin Changed? Date Time KUC UG Qualified Persn Signature Changes in Cnditin r Scpe? Permit Terminated? Cntractr Signature YES NO YES NO YES NO YES NO YES NO YES NO YES NO YES NO YES NO CONTRACTOR VERIFYING PERMIT TERMINATION Name: Signature: Date: Time: KUC UNDERGROUND QUALIFIED PERSON TERMINATING PERMIT Name: Signature: Date: Time: Jb Site is prepared t turn ver t KUC? YES NO TEMPORARY PERMIT TERMINATION ONLY Page 19 f 19 supersede all ther revisins.