Revised Safety Plan. Page 1. Penna. Prepared by Penna. October, 20100

Transcription

1 Accident Prevention/Safety Plan Penna Group, LLC Low Flow Gate Controllers at Ray Roberts, Texas Contract No: W9126G-10-C-0075 Date: October 15, 2010 (Revised January 18, 2011) Revised Safety Plan Ray Roberts Dam Page 1 Prepared by Penna Group, LLC October, 20100

2 SAFETY PROGRAM (Accident Prevention Plan) Revised Safety Plan Ray Roberts Dam Page 2 TABLE OF CONTENTS 1. SIGNATURE SHEET... 5 A. PLAN PREPARER (TITLE, SIGNATURE, AND PHONE NUMBER)... 5 B. PLAN APPROVAL... 5 C. PLAN CONCURRENCE BACKGROUND INFORMATION... 6 A. CONTRACTOR... 6 B. CONTRACT NO... 6 C. PROJECT NAME... 6 D. DESCRIPTION... 6 E. RATING... 6 F. PHASE OF WORK... 6 G. REFERENCES... 6 H. DEFINITIONS... 8 I. GOVERNMENT SAFETY FORMS... 9 J. REGULATORY REQUIREMENTS K. SITE QUALIFICATIONS, DUTIES AND MEETINGS L. PERSONNEL DUTIES M. MEETINGS SAFETY & HEALTH POLICY STATEMENT A. GENERAL STATEMENT OF SAFETY B. PHYSICAL QUALIFICATIONS OF EMPLOYEES RESPONSIBILITIES AND LINES OF AUTHORITIES A. STATEMENT OF EMPLOYER S ULTIMATE RESPONSIBILITY B. IDENTIFICATION AND ACCOUNTABILITY OF PERSONNEL RESPONSIBLE FOR SAFETY AT BOTH CORPORATE AND PROJECT LEVEL C. GENERAL SITE PERSONNEL LIST D. THE COMPETENT PERSON E. CONTINUOUS PRESENCE OF COMPETENT PERSON F. REVIEW OF PHASES OF WORK G. LINES OF AUTHORITY H. VIOLATIONS OF RULES SUBCONTRACTOR AND SUPPLIERS A. IDENTIFICATION OF SUBCONTRACTORS AND SUPPLIERS (IF KNOWN) B. SAFETY RESPONSIBILITIES OF SUBCONTRACTORS AND SUPPLIERS TRAINING A. REQUIREMENTS FOR NEW HIRE SOH ORIENTATION TRAINING B. MANDATORY TRAINING AND CERTIFICATIONS FOR THIS PROJECT... 29

3 Page 3 C. PROCEDURES FOR PERIODIC SAFETY AND HEALTH TRAINING FOR SUPERVISORS AND EMPLOYEES D. REQUIREMENTS FOR EMERGENCY RESPONSE TRAINING E. SAFETY LOCKOUT/TAGOUT PROCEDURES SAFETY AND HEALTH INSPECTIONS A. GENERAL PROJECT SAFETY POLICY B. PROCEDURES AND METHODS FOR DAILY SAFETY INSPECTIONS C. SUBCONTRACTOR RESPONSIBILITIES D. EXTERNAL INSPECTIONS AND CERTIFICATIONS ACCIDENT REPORTING A. TIMING OF REPORTS B. RESPONSIBILITY FOR INVESTIGATION C. NOTIFICATION D. ACCIDENT REPORTING AND RECORDKEEPING E. EMERGENCY PLANNING F. EMERGENCY OPERATIONS PLANS (PROGRAMS, PROCEDURES) REQUIRED BY THE SAFETY MANUAL (as applicable) A. LAYOUT PLANS (04.A.01) B. EMERGENCY RESPONSE PLANS Procedures and tests (01.E.01) Spill plans (01.E.01, 06.A.02) Firefighting Plan (01.E.01, Section 19) Posting of Emergency Telephone Numbers (01.E.05) Man Overboard/Abandon Ship (Section 19.A.04) Medical Support C. PLAN FOR PREVENTION OF ALCOHOL AND DRUG ABUSE (01.C.02) (DEFENSE FEDERAL ACQUISITION REGULATION SUPPLEMENT (DFARS) SUBPART D. SITE SANITATION PLAN (SECTION 02) E. ACCESS AND HAUL ROAD PLAN (4.B) F. RESPIRATORY PROTECTION PLAN (05.G) AND PERSONAL PROTECTIVE AND SAFETY EQUIPMENT G. HEALTH HAZARD CONTROL PROGRAM (06.A) H. HAZARD COMMUNICATION PROGRAM (06.B.01) I. PROCESS SAFETY MANAGEMENT PLAN (06.B.04) J. LEAD ABATEMENT PLAN (06.B.05 & SPECIFICATIONS) K. ASBESTOS ABATEMENT PLAN (06.B.05 & SPECIFICATIONS) L. RADIATION SAFETY PROGRAM (06.E.03.A) M. ABRASIVE BLASTING (06.H.01) N. HEAT/COLD STRESS MONITORING PLAN (06.I.02) O. CRYSTALLINE SILICA MONITORING PLAN (ASSESSMENT) (06.M) P. NIGHT OPERATIONS LIGHTING OLAN (07.A.08) Q. FIRE PREVENTION PLAN (09.A) R. WILD LAND FIRE MANAGEMENT PLAN (09.K) S. HAZARDOUS ENERGY CONTROL PLAN (12.A.01) T. CRITICAL LIFT PLAN (16.H) U. CONTINGENCY PLAN FOR SEVERE WEATHER (19.A.03) V. FLOAT PLAN (19.F.04) W. SITE SPECIFIC FALL PROTECTION & PREVENTION PLAN (21.C) X. DEMOLITION PLAN (TO INCLUDE ENGINEERING SURVEY) (23.A.01)

4 Page 4 Y. EXCAVATION/TRENCHING PLAN (25.A.01) Z. EMERGENCY RESCUE (TUNNELING) (26.A.) AA. UNDERGROUND CONSTRUCTION FIRE PREVENTION AND PROTECTION PLAN (26.D.01) BB. COMPRESSED AIR PLAN (26.I.01) CC. FORMWORK AND SHORING ERECTION AND REMOVAL PLANS (27.C) DD. PRECAST CONCRETE PLAN (27.D) EE. LIFT SLAB PLANS (27.E) FF. STEEL ERECTION PLAN (27.F.01) GG. SITE SAFETY AND HEALTH PLAN FOR HTRW WORK (28.B) HH. BLASTING SAFETY PLAN (29.A.01) II. DIVING PLAN (30.A.13) JJ. CONFINED SPACE PROGRAM (34.A) RISK MANAGEMENT PROCESSES ABBREVIATED APP FOR LIMITED SCOPE SERVICE SUPPLY AND R&D CONTRACTS ATTACHMENTS

5 Revised Safety Plan Ray Roberts Dam Page 5 This Safety Plan was approved by authorized to obligate the company. 1. SIGNATURE SHEET The elements of this Safety and Accident Prevention Plan (SAPP) identify the potential hazards associated with the scope of work and provide guidelines to eliminate or minimize those hazards. This plan shall apply to all contractors, subcontractors, suppliers, and lower tier subcontractors and their employees while performing work activities on this Project. All work shall be performed in accordance with the safety and health requirements set forth in the Code of Federal Regulations (CFR) Title 29, Part 1926 Safety and Health Standards for the Construction Industry, Title 29, Part 1910 Generall Industry Safety and Health Standards, and the Corps of Engineers EM , Safety and Health Requirements Manual, as well as other applicable regulations. Copies of all referenced material shall be available in Penna s office. All upper management personnel will insure that they concur with all aspects of the safety plan and that all subordinates are indoctrinated to the importance of this plan. A. PLAN PREPARER (TITLE, SIGNATURE, AND PHONE NUMBER) This Safety Plan was prepared by Michael Evangelista Ysasaga, CEO of The Penna Group, and Steven Ysasaga CQCM of The Penna Groupp and the in house plan approval will be by Michael Evangelista Ysasaga. B. PLAN APPROVAL The Pennaa Group, LLC and its corporate officer C. PLAN CONCURRENCE This Safety Plan is in concurrence with the CEO and project QCM. Michael Evangelista Ysasaga CEO Telephone: Steven Ysasaga CQC Manager Telephone: Penna Group, LLC 817 W. Daggett Ave. Ft. Worth, Texas Main (Toll Free) Facsimile (Toll Free)

6 Page 6 2. BACKGROUND INFORMATION A. CONTRACTOR: The Penna Group, LLC 817 W. Daggett Ave. Fort Worth, Texas (817) Main (817) Facsimile B. CONTRACT NO: W9126G 10 C 0075 C. PROJECT NAME: Low Flow Gate controllers at Ray Roberts, Texas D. DESCRIPTION: The project consists of performing replacement of 48 inch, low flow, Butterfly Gates, Minor Earthwork for Installation of Electrical Conduits and Concrete Equipment Pads. E. RATING: Penna Group has an EMR rating of 1.0 (See OSHA 300 log attached) F. PHASE OF WORK: Phases of work requiring hazardous activity analyses are: Site Preparation Excavate & Backfill Remove & Replace Butterfly Valve Install Electrical G. REFERENCES The publications listed below form a part of this specification to the extent referenced. The publications are referred to within the text by the basic designation only. AMERICAN SOCIETY OF SAFETY ENGINEERS (ASSE/SAFE) ASSE/SAFE A10.32 ASSE/SAFE A10.34 Public on (2004) Fall Protection (2001; R 2005) Protection of the or Adjacent to Construction Sites ASSE/SAFE Z359.1 (2007) Safety Requirements for Personal Fall Arrest Systems, Subsystems and Components

7 Page 7 NATIONAL AERONAUTICS AND SPACE ADMINISTRATION (NASA) NASA NPG NASA NPG Policy (2004a) NASA Mishap Reporting, Investigating and Record Keeping (2004) NASA Safety Manual NASA NSS (1993) NASA Safety Standard For Explosives, Propellants and Pyrotechnics NATIONAL FIRE PROTECTION ASSOCIATION (NFPA) NFPA 10 Portable NFPA 241 (2006; Errata 2006) Standard for Fire Extinguishers (2004) Safeguarding Construction, Alteration, and Demolition Operations NFPA 51B (2003) Fire Prevention During Welding, Cutting, and Other Hot Work NFPA 70 (2007) National Electrical Code 2008 Edition NFPA 70E in the (2004; AMD 2004) Electrical Safety Workplace U.S. ARMY CORPS OF ENGINEERS (USACE) EM (2008) Safety Safety and Health Requirements U.S. NATIONAL ARCHIVES AND RECORDS ADMINISTRATION (NARA) 10 CFR 20 Standards for Protection Against Radiation

8 Page 8 29 CFR 1910 Occupational Safety and Health Standards 29 CFR Permit required Confined Spaces 29 CFR 1915 Confined and Enclosed Spaces and Other Dangerous Atmospheres in Shipyard Employment 29 CFR 1919 Gear Certification 29 CFR 1926 Safety and Health Regulations for Construction 29 CFR Fall Protection H. DEFINITIONS Competent Person for Fall Protection. A person who is capable of identifying hazardous or dangerous conditions in the personal fall arrest system or any component thereof, as well as their application and use with related equipment, and has the authority to take prompt corrective measures to eliminate the hazards of falling. High Visibility Accident. Any mishap which may generate publicity and/or high visibility. Medical Treatment. Treatment administered by a physician or by registered professional personnel under the standing orders of a physician. Medical treatment does not include first aid treatment even through provided by a physician or registered personnel. Operating Envelope. The area surrounding any crane. Inside this "envelope" is the crane, the operator, riggers and crane walkers, rigging gear between the hook and the load, the load and the crane's supporting structure (ground, rail, etc.). Qualified Person for Fall Protection. A person with a recognized degree or professional certificate and with extensive knowledge, training and experience in the field of fall protection; who is capable of performing design, analysis, and evaluation of fall protection systems and equipment.

9 Page 9 Recordable Injuries or Illnesses. Any work related injury or illness that results in: o Death, regardless of the time between the injury and death, or the length of the illness; o Days away from work (any time lost after day of injury/illness onset); o Restricted work; o Transfer to another job; o Medical treatment beyond first aid; o Loss of consciousness; or o A significant injury or illness diagnosed by a physician or other licensed health care professional, even if it did not result in (1) through (6) above. "USACE" property and equipment specified in USACE EM should be interpreted as Government property and equipment. Weight Handling Equipment (WHE) Accident. A WHE accident occurs when any one or more of the six elements in the operating envelope fails to perform correctly during operation, including operation during maintenance or testing resulting in personnel injury or death; material or equipment damage; dropped load; derailment; two blocking; overload; and/or collision, including unplanned contact between the load, crane, and/or other objects. A dropped load, derailment, twoblocking, overload and collision are considered accidents even though no material damage or injury occurs. A component failure (e.g., motor burnout, gear tooth failure, bearing failure) is not considered an accident solely due to material or equipment damage unless the component failure results in damage to other components (e.g., dropped boom, dropped load, roll over, etc.). I. GOVERNMENT SAFETY FORMS The most current copy of EM , Accident Prevention Plan Check Lists, and other Government Safety forms can be accessed and downloaded at

10 Page 10 J. REGULATORY REQUIREMENTS In addition to the detailed requirements included in the provisions of this contract, comply with USACE EM , and the following federal, state, and local laws, ordinances, criteria, rules and regulations: Texas Department of State Health Services Texas Commission on Environmental Quality Occupation Safety and Health Administration Submit matters of interpretation of standards to the appropriate administrative agency for resolution before starting work. Where the requirements of this specification, applicable laws, criteria, ordinances, regulations, and referenced documents vary, the most stringent requirements govern. K. SITE QUALIFICATIONS, DUTIES AND MEETINGS Personnel Qualifications Submit matters of interpretation of standards to the appropriate administrative agency for resolution before starting work. Where the requirements of this specification, applicable laws, criteria, ordinances, regulations, and referenced documents vary, the most stringent requirements govern. Site Safety and Health Officer (SSHO) Provide a site Safety and Health Officer (SSHO) at the work site at all times to perform safety and occupational health management, surveillance, inspections, and safety enforcement for Penna. Penna Quality Control (QC) person can be the SSHO on this project. Meet the following requirements within the SSHO: Level 1: Worked on similar projects. 10 hour OSHA construction safety class or equivalent within last 3 years. Competent person training as needed. NOTE: Use Level 1 for small non hazardous service or maintenance projects.

11 Page 11 Competent Person for Confined Space Entry Provide a competent person for confined space meeting the definition and requirements of EM Crane Operators Meet the crane operator's requirements in USACE EM , Section 16 and Appendix I. In addition, for mobile cranes with Original Equipment Manufacturer (OEM) rated capacitates of 50,000 pounds or greater, designate crane operators as qualified by a source that qualifies crane operators (i.e., union, a government agency, and/or organization that tests and qualifies crane operators). Provide proof of current qualification. Also meet the crane operator requirements of the State of Texas for Crane certification. L. PERSONNEL DUTIES Site Safety and Health Officer (SSHO) a. Conduct daily safety and health inspections and maintain a written log which includes area/operation inspected, date of inspection, identified hazards, recommended corrective actions, estimated and actual dates of corrections. Attach safety inspection logs to Pennas' daily quality control report. b. Conduct mishap investigations and complete required reports. Maintain the OSHA Form 300 and Daily Production reports for prime and sub Pennas. c. Maintain applicable safety reference material on the job site. d. Attend the pre construction conference, pre work meetings including preparatory inspection meeting, and periodic in progress meetings. e. Implement and enforce accepted APPS and AHAs. f. Maintain a safety and health deficiency tracking system that monitors outstanding deficiencies until resolution. Post a list of unresolved safety and health deficiencies on the safety bulletin board. g. Ensure sub Penna compliance with safety and health requirements. Failure to perform the above duties will result in dismissal of the superintendent and/or SSHO,

12 Page 12 and a project work stoppage. The project work stoppage will remain in effect pending approval of a suitable replacement. M. MEETINGS Preconstruction Conference Penna representatives who have a responsibility or significant role in accident prevention on the project shall attend the preconstruction conference. This includes the project superintendent, site safety and health officer, quality control supervisor, or any other assigned safety and health professionals who participated in the development of the APP (including the Activity Hazard Analyses (AHAs) and special plans, program and procedures associated with it). Discuss the details of the submitted APP to include incorporated plans, programs, procedures and a listing of anticipated AHAs that will be developed and implemented during the performance of the contract. This list of proposed AHAs will be reviewed at the conference and an agreement will be reached between Penna and the Contracting Officer's representative as to which phases will require an analysis. In addition, establish a schedule for the preparation, submittal, review, and acceptance of AHAs to preclude project delays. Deficiencies in the submitted APP will be brought to the attention of Penna at the preconstruction conference, and Penna shall revise the plan to correct deficiencies and re submit it for acceptance. Do not begin work until there is an accepted APP. Safety Meetings Conduct and document meetings as required by EM Attach minutes showing contract title, signatures of attendees and a list of topics discussed to Penna's daily production report. 3. SAFETY & HEALTH POLICY STATEMENT A. GENERAL STATEMENT OF SAFETY Penna Group, LLC recognizes that leadership in safety and health supports our strategy for excellence and growth. We are committed to protecting the safety and welfare of our employees, visitors and the community of which we are a part by conducting our business in a safe manner, consistent with our corporate standards and applicable safety and health regulations.

13 Page 13 Providing safety leadership is a fundamental part of our business and we encourage all employees to take responsibility and ownership for their safety and that of those around them. It is our commitment to manage safety and health aspects as part of and in parity with Penna s operational objectives. Penna continually strives to improve its safety and health systems and increase proactive involvement by all employees in those programs. Penna commits to the continuous reduction of occupational injuries and illnesses and to the creation and maintenance of a culture in which all employees have full ownership and involvement in safety and health decisions, supported by management. Penna recognizes that we are part of, and affect the communities in which we operate. We will keep our employees well informed about the safety, health and security consequences of our activities, and we will maintain an open dialogue with the public about these issues. It is the policy of Penna to: Maintain a safe and healthy workplace for all employees in compliance with country, federal, state or equivalent, and/or local laws and regulations; Establish safety and health objectives for all levels of management and employees; Commit appropriate and sufficient resources to protect company property and employees/others in their respective working environments; Provide management leadership and encourage all employees to take responsibility and ownership for safety; Assure compliance with all company safety, health and security policies/practices, and to train employees to comply with those policies; With regularity, review and evaluate safety, health and security programs and practices to assure they are effective and up to date; Provide technical support for development of effective approaches to control workplace risks; Hold all employees accountable for the safe execution of their work; and

14 Page 14 Assure timely and thorough reporting and investigation of all unplanned events including the identification of causal factors and establishment of timely and effective corrective actions aimed at minimizing recurrence. Penna has developed these safety, health and security standards which cover the key elements, obligations and responsibilities embodied in this policy statement. Penna will apply these standards in its business, demonstrating its commitment to continually improving its safety, health and security management systems, and maintaining its status as a good corporate citizen. Penna Group utilizes Penna SAFETY SELF EVALUATION form provided by the government. Through the use of this evaluation form and the input from management and field personnel we feel we can reach our goal to have no accidents or injuries. Penna Group is totally committed to making these Safety Goals attainable. (Penna Group has an EMR of 1.0.) B. PHYSICAL QUALIFICATIONS OF EMPLOYEES All persons shall be physically, medically, and emotionally (ready, willing and able) qualified for performing the duties to which they are assigned. Some factors to be considered in making work assignments are strength, endurance, agility, coordination, and visual and hearing acuity. While on duty, employees shall not use or be under the influence of alcohol, narcotics, intoxicants, or similar mind altering substances. Employees found to be under the influence of or consuming such substances will be immediately removed from the job site. Pennas shall enforce the drug free workplace requirements. Any employee under a physician's treatment and taking prescribed narcotics or any medication that may prevent one being ready, willing and able to safely perform position duties shall provide a medical clearance statement to his supervisor. Operators of any equipment or vehicle shall be able to read and understand the signs, signals, and operating instructions in use. Operators are not permitted to operate beyond the following limits: Operators of equipment, such as hoisting equipment and draglines, mobile construction equipment, electrical power systems, hydropower plants, industrial

15 Page 15 manufacturing systems, hydraulically operated equipment, powered vessels, and boats, shall not be permitted to exceed twelve (12) hours of duty time in any 24 hour period, including time worked at another occupation. A minimum of eight (8) consecutive hours shall be provided for rest in each 24 hour period. Operators of motor vehicles, while on duty, shall not operate vehicles for a continuous period of more than ten (10) hours in any 24 hour period; moreover, no employee, while on duty, may operate a motor vehicle after being in a duty status for more than twelve (12) hours during any 24 hour period. A minimum of eight (8) consecutive hours shall be provided for rest in each 24 hour period. 4. RESPONSIBILITIES AND LINES OF AUTHORITIES A. STATEMENT OF EMPLOYER S ULTIMATE RESPONSIBILITY The implementation of the Accident Prevention Plan relies solely on Penna Group as a company. The enforcement of this plan and success of the plan relies solely on the Officers, Management, Supervisors, Workers, Subcontractors and suppliers. The APP is a tool that must be used for the purpose intended, which is to insure a safe project with no accidents or injuries. B. IDENTIFICATION AND ACCOUNTABILITY OF PERSONNEL RESPONSIBLE FOR SAFETY AT BOTH CORPORATE AND PROJECT LEVEL Penna Group details below the personnel and the basic requirements of the positions. Also Penna Group will insure that the appropriate training for any persons that will be performing these tasks has been implemented and that all persons are in compliance as to any specialized certification that may be required. (OSHA 30, OSH Act/General Duty Clause, 29CFR 1904, Subpart C, D, E, F, K, M and construction trades)

16 Page 16 C. GENERAL SITE PERSONNEL LIST Position Name Certifications Project Manager (PM) Penna Quality Control Manager (CQCM) Site Safety and Health Officer (SSHO) Alternate SSHO Michael Evangelista Ysasaga Steven Ysasaga Steven Ysasaga Bill Fullbright CPR, First Aid CPR, First Aid, OSHA 30, CQM CPR, First Aid, OSHA 30, CQM CPR, First Aid, OSHA 30, CQM Site Superintendent Frankie Torrez CPR, First Aid, OSHA 10 Management Management will be held accountable for accomplishing the following safety and health responsibilities: Development and implementation of written and effective safety, health, and loss prevention plans. Support and enforce the Safety and Health Policies, including COE EM Provide safe work spaces and work environments within Penna Group and associate this with safe and healthful work practices and procedures. Ensure that operational management within the group has been delegated adequate safety and health responsibility and authority (in position descriptions or equivalent documentation), for which they are consistently held accountable. Take part in the Safety Committee and periodically measure the success or failure of the adopted safety policies and procedures. Establish annual safety objectives, ensuring that plans of action and responsibilities have been developed to accomplish the objectives, and periodically monitor progress being made. Communicate to all employees that safety, health and loss prevention are a vital part of all jobs and require their active participation and support for these activities. Require immediate notification of all serious accidents and incidents. Safety Committee Members CEO (Michael Evangelista Ysasaga)

17 Page 17 Project Manager (Michael Evangelista Ysasaga) General Superintendent/Site Quality Control (Steven Ysasaga) Alternate Quality Control (Bill Fullbright) Assistant Superintendent /Safety Manager (Frank Torres) Purpose It is the purpose of the Safety Committee to administer the Safety Program in an effort to reduce employee accidents and to maintain safe job sites. The Safety Committee reviews all reports and inspections submitted by the Safety Officer. The Safety Committee determines what needs to be done to ensure that Federal and State statutes are met, and more importantly that Penna Group is a safe company to work for. The Safety Committee coordinates the administration of safety education and training for supervisors and employees. Bi Monthly Meetings: The Safety Committee meets every other month, or a minimum of quarterly. Attendance is mandatory. The Project Manager will chair the committee. The company Safety Manager will be the secretary and take minutes. At each meeting the following is reviewed: OSHA Accident Log (Form 300) Accident investigations Corrective actions taken Open deficiencies from Site Inspection Reports Vehicle accidents Open discussion Operations Management Responsibilities Administrative Accountable to the senior executive of the operating company Adopts and administers the Safety & Loss Control program and associated manuals. Is a member of the Company Safety Committee

18 Page 18 Requires and approves annual safety and loss control objectives within their area of responsibility. Actively participates in the audit process Approves all project safety rules and procedures. Training Develops and maintains a positive attitude toward safety and loss control with the operations project management, and field supervision staff. Determines that operations, project management, and field supervision staff understand their role in the program. Makes available and requires direct reporting employees to attend training and education programs on Federal, State, or Local legislative requirements having a direct effect on the health and safety of their employees. Approves training program(s) for employees and requires that written documentation of the safety training performed be maintained. Control Holds operations, project management, and field supervision staff accountable for safety and loss control performance. Maintains daily participation in safety and loss control matters. Requires immediate notification of all serious accidents and incidents. Assesses the ability of line management in safety and loss control and uses this information in matters of performance evaluation. Holds direct reporting employees accountable for safety and loss control performance, and the safety of all employees under their responsibility. Personally ensures the follow up and investigation of all lost time injuries within the operating company. Monitors safety and loss control performance, including management systems control, follow up, and documentation of program responsibilities for direct hires and subcontractors. Regularly evaluates the attitudes, knowledge and performance of department managers in safety and loss control and uses their assessment in matters of performance evaluation. Annually assesses project accident prevention results and participates in the development of objectives and priorities for the next year. SSHO/Safety Manager s Responsibility The Safety Manager for this project is Steven Ysasaga. Steve s Safety Training includes: Storm Water Management during construction, Corps of Engineers CQC certification, OSHA 30. Resume attached.

19 As Safety Manager, Steven Ysasaga s responsibilities include: Revised Safety Plan Ray Roberts Dam Page 19 Responsible for the overall implementation of Penna Group Safety Program at the company level. Reports directly to the company executive management for all activities affecting the safety and loss control performance of the company. Communicates with all levels of management within the company, on issues directly affecting the health and safety of all employees. Reviews all first report of injury reports and company accident investigation reports. Analyzes accident trends to determine problem areas. Reports findings and analysis to the safety committee. Advises superintendents, foremen, and others on safety problems, OSHA activities, and other directives affecting job operations. Monitors all safety related activities in the field. Coordinates safety training activities. Performs the necessary employee safety and loss control training or conducts train the trainer classes for management and supervisory personnel to ensure that all office and field employees have received the training required by Federal, State, or Local legislation. Acts as the liaison between the company and governmental regulatory agencies and outside consultants. Maintains all records as required by legislation and the parent company (i.e. OSHA 300 and Daily Production reports) in areas of safety and loss control, and submits this information as required. Notifies the company (Penna Group) immediately in the event of a fatality or hospitalization of 3 or more employees as a result of a work related injury. Provides the company (Penna Group) with a copy of investigation reports within 5 days after any lost time injury. Performs documented site inspections of all job sites, noting deficiencies to the Penna, superintendent/foreman, and senior management or his/her subsidiary. Conducts HAZARD COMMUNICATION training as required. Develops and implements an employee safety incentive program. Serves as secretary for the safety committee. Provides to senior management on a monthly basis, a report of activities and achievements of the subsidiary to be included in the monthly CEO report Attends the pre construction conference, pre work meetings including preparatory inspection meeting and periodic in progress meeting. Presents to clients, as requested, the Safety and Loss Control Program of the company. Will follow up on all safety deficiency reports submitted by field personnel.

20 Page 20 Advise and assist line management in carrying out their safety and health responsibilities. Monitor the implementation of the Safety and Health Program within the company and recommend changes as necessary. Ensures sub Penna compliance with Safety and Health requirements Assist management in developing annual safety objectives, including plans of action for achieving results. Review and approve all accident investigation reports to ensure an acceptable level of quality and establish a follow up system to determine that recommended corrective actions have been implemented. Project Manager s Responsibility A good safety and health record at Penna Group work sites will depend upon the priority given to safety by the Project Manager in charge of the project. The Project Manager for this project will be held accountable for accomplishing the following safety and health responsibilities: The Project Manager for this project is Michael Evangelista Ysasaga. Interpret Penna Group s safety policies, practices and procedures and actively support them as an example to those responsible to them, giving safety equal emphasis and weight with matters of production, costs, and quality. Ensure that supervisory personnel have been delegated adequate safety and health responsibility and authority (in position descriptions or equivalent documentation) for which they are held accountable. Include safety and health issues as part of the established agenda for supervisory staff meetings. Monitor safety inspection reports to ensure an acceptable level of quality and timely implementation of corrective measures. Participate as an active member of the Safety Committee. Make sure that safety and loss prevention incentive programs and recognition for good performance as outlined by the Safety Committee is carried out on their job sites. Hold direct reporting employees accountable for safety and loss control performance and the safety of all persons under their responsibility. Personally ensure the follow up and investigation of all lost time injuries within their department. Assess safety and loss control performance of direct subordinates and use this assessment in matters of performance evaluation. Review accident reports in order to keep informed of accidents occurring under his control and to ensure that proper action is taken to prevent recurrences.

21 Page 21 Determine that received tools and equipment are in first class condition. Instruct foremen in the safety program, administrative procedures to be followed, and the safety conditions to be maintained throughout the job. Ensure that each foreman instructs his workers in safe practices and has indoctrinated them in the requirements of the company in regards to company policies (i.e. Safety, Drugs, Alcohol, etc.). Conduct documented safety inspections of jobs under their control with the appropriate parties notified, in writing, of deficiencies under their control. Make reports to the company (Penna Group) of job site safety and health deficiencies. Notify COR immediately in the event of a critical injury or fatality. Superintendents Responsibility The Superintendent for this project is Frank Torres, training includes Aerial Safety Training, Form Builder/ Structures Training, Forklift Certified, CPR & First Aid Certified, OSHA 10 Hour, OSHA 30 Hour. Resume attached. The Superintendent for this project is Frank Torres, his responsibilities include: Maintain a complete copy of the safety program and be thoroughly familiar with it so that he understands his own and other employee s responsibilities. Review accident reports in order to keep informed of accidents occurring under his control and to ensure that proper action is taken to prevent recurrences. Assist in accident investigation on serious accidents under his direct control. Determine that received tools and equipment are in first class condition. Any tools or equipment that are defective or unsafe (whether received thus or due to usage), will be tagged as Defective Do Not Use and shall be removed from the job site. Satisfy himself that the necessary safety precautions have been exercised when new job materials or operations are introduced onto the job. Instruct foremen in the safety program administrative procedures to be followed and the safety conditions to be maintained throughout the job. Ensure that each foreman instructs his workers in safe practices. Make available necessary personal protective equipment, job safety materials, and first aid equipment. Conduct daily safety and health inspections of jobs under their control. Coordinate with the foremen for delivery of job site inspection reports and toolbox talks to the safety director.

22 Page 22 Foremen Responsibility THE FOREMAN IS THE KEY MAN IN THE SAFETY PROGRAM BECAUSE HE IS IN CONSTANT CONTACT WITH THE EMPLOYEE. THE FOREMAN MUST ACCEPT THE RESPONSIBILITY FOR ACCIDENTS THAT OCCUR UNDER THEIR SUPERVISION. Notify Penna Group Safety Manager (or company management), by phone, immediately of job site accidents, other emergencies, or OSHA inspections. All accidents must be reported the same day, using the First Report of Injury form and Company Accident Investigation form. Adopt and administer the safety and loss control program and associated manuals, ensuring that a copy of the program is maintained on site at all times during the length of the project. Assist management personnel and the claim coordinator in a prompt and proper investigation of accidents. Conduct the new hire orientation program with new hires and transfers if this cannot be done at the main office. Provide instruction of safety awareness to the employees on each job. Take an active part in planning safety in the new operations. Make documented inspections for unsafe practices and conditions, and initiate needed corrective action using Site Inspection Report. If these types of situations are not satisfactorily corrected, they should be reported to the Superintendents or the Safety Manager. Make sure that the required safety equipment is on hand and is being used. Ensure that the proper maintenance of tools and equipment is performed. Secure company tools and equipment to prevent theft or damage. Attend safety meetings, as required by the Penna. Make verbal reports to the Safety Manager of job site Safety and Health Deficiencies. By personal example, communicate and demonstrate to employees the importance of working safely. Be knowledgeable of all General Safety Rules and Safe Work Practices, and enforce them as they apply to the area of supervisory responsibility. Insist upon and demand good housekeeping practice. Respond to all employee safety suggestions and take immediate action to correct any unsafe physical condition of which you become aware. Instruct each new and/or transferred employee on hazards of the job or tasks that the employee will be assigned. Plan, organize and conduct effective tool box meetings. Such meetings are to be held weekly and attendance sheets and topics discussed will be forwarded to the Safety Manager. Maintain first aid kit and be currently trained in First Aid and CPR.

23 Page 23 Employee s Responsibility Each employee has a responsibility toward their own safety, but likewise, they have responsibility to family, co workers, community and to Penna Group by whom they are paid. In the performance of their duties, therefore, they shall be expected to observe safety rules, practices and procedures, as well as instructions related to the efficient performance of their work. The ideal in safe and efficient construction operation is reached only when all employees are safety conscious and keenly alert, both mentally and physically. Employees are held accountable for the following safety and health responsibilities. All employees must report to work at the start of each shift physically and mentally qualified to perform his/her duties. If not physically and mentally able to perform his/her work, the employee will not be permitted to be on the project. Comply with instructions of supervisors, and abide by all safety rules, practices, and procedures. Attend a new employee orientation program on the safety and loss control program. Understand the safe and proper way to perform the work assignment and request additional training in the proper discharge of your task if needed. Wear safe, non flammable, non synthetic clothing, including proper footwear (no tennis shoes). Tank tops and shorts will not be permitted on the work site. Report all accidents, injuries and near miss incidents to direct supervision and cooperate with investigation efforts. No alcohol or drug use on the job. Work according to good safety practices as posted, instructed, and discussed. Refrain from any unsafe act that might endanger yourself or fellow workmen. Attend weekly tool box meetings and be accountable for applying increased safety knowledge to work habits. Maintain good housekeeping practices. Do not operate any equipment unless properly trained. D. THE COMPETENT PERSON The competent person is Steven Ysasaga, his training includes OSHA Excavations certificate, Storm Water Management during construction, Corps of Engineers CQC certification, OSHA 30, see attached resume. If additional training or certification is required this will be implemented prior to the start of a major phase of work.

24 Page 24 E. CONTINUOUS PRESENCE OF COMPETENT PERSON Penna Group will insure that no work that requires a competent person will be performed unless that person is present on the job site. F. REVIEW OF PHASES OF WORK Each phase of work will be reviewed and the requirements of the task will be analyzed to see if any preliminary safety measures or additional preparation is necessary. G. LINES OF AUTHORITY Employee reports to his Foreman The Foreman reports to the Superintendent/Assistant Superintendent The Assistant Superintendent reports to Superintendent The Superintendent reports to the Project Manager The Quality Control Manager reports to the Project Manager, QA Assurance Representative and the Contracting Officer. Project Manager reports to the President of the Company and the Contracting Officer. H. VIOLATIONS OF RULES If any of the company safety rules or safe work practices are observed to be conducted in an unsafe manner, the following will be enforced by the Field Supervisor or Safety Department: Field Employees o First Violation Verbal Warning. This must be put on the Safety Violation form and kept by the on site Superintendent to be used in the case of a second offense. The first offense is between the employee and the Superintendent. o Second Violation Written Warning. This is a more serious offense and must be sent to the main office along with the first verbal documentation. The Supt./Foreman and a witness must be present. The Superintendent/ Foreman, the employee and the witness must sign the form. o Third Violation Suspension and/or Termination

25 Page 25 If Field Supervisors fail to comply and enforce established Safety Rules and Procedures or to make available the same to employees, or non compliance of Health and Safety Manual, the following will be enforced by the Safety Committee and/or a member of the Safety Committee: Field Supervisors o First Violation o Written Warning o Second Violation o Report to Safety Committee o Third Violation o Suspension and/or Termination Falsification of information submitted on an injury report is grounds for immediate termination. 5. SUBCONTRACTOR AND SUPPLIERS A. IDENTIFICATION OF SUBCONTRACTORS AND SUPPLIERS (IF KNOWN); Subcontractors and Suppliers Alliance Geotechnical Group 801 Airway Dr. Suite D Fort Worth TX (817) POC: Kim England Basecom, Inc 5209 Vesta Farley Fort Worth, TX (817) POC: Troy Hill Innovation Mechanical 3103 Wheelock Street Dallas, TX (214) All others to be identified at a later date and will be incorporated into this plan as required.

26 B. SAFETY RESPONSIBILITIES OF SUBCONTRACTORS AND SUPPLIERS Revised Safety Plan Ray Roberts Dam Page 26 The Penna s and the subcontractor s supervisory personnel will be furnished a copy of the accident prevention plan and be apprised of their accident prevention responsibility prior to commencement of work. All subcontractors will be instructed in writing concerning the requirements of their responsibility under this plan; subcontractors will be subject to and required to abide by the accident prevention plans and safety manual requirements. The Superintendents will enforce the regulations; all provisions of the plan apply equally to the Penna and all Subcontractors. Prior to each major phase of construction the Penna will prepare a Hazards Analysis which will be part of the Preparatory Inspection phase. Penna Required AHA. Before beginning each work activity involving a type of work presenting hazards not experienced in previous project operations or where a new work crew or subcontractor is to perform the work, Penna and/or Subcontractors performing that work activity will prepare an AHA. a. AHAs shall define the activities being performed and identify the work sequences, the specific anticipated hazards, site conditions, equipment, materials, and the control measures to be implemented to eliminate or reduce each hazard to an acceptable level of risk. b. Work shall not begin until the AHA for the work activity has been accepted by the GDA and discussed with all engaged in the activity, including Penna, subcontractor(s), and Government on site representatives at preparatory and initial control phase meetings. c. The names of the Competent/Qualified Person(s) required for a particular activity (for example, excavations, scaffolding, fall protection, other activities as specified by OSHA and this manual) shall be identified and included in the AHA. Proof of their competency/qualification shall be submitted to the GDA for acceptance prior to the start of that work activity. d. The AHA shall be reviewed and modified as necessary to address changing site conditions, operations, or change of competent/qualified person(s). (1) If more than one Competent/Qualified Person is used on the AHA activity, a list of names shall be submitted as an attachment to the AHA.

27 Page 27 Those listed must be Competent/Qualified for the type of work involved in the AHA and familiar with current site safety issues. (2) If a new Competent/Qualified Person (not on the original list) is added, the list shall be updated (an administrative action not requiring an updated AHA). The new person shall acknowledge in writing that he or she has reviewed the AHA and is familiar with current site safety issues. The Activity Hazard Analysis (AHA) format shall be in accordance with USACE EM Penna will submit the AHA for review prior to the start of each phase. The AHA analysis should be used during daily inspections to ensure the implementation and effectiveness of the activity's safety and health controls. The AHA list will be reviewed periodically (at least monthly) at Penna supervisory safety meeting and updated as necessary when procedures, scheduling, or hazards change. Penna will develop the activity hazard analyses using the project schedule as the basis for the activities performed. Any activities listed on the project schedule will require an AHA. The AHAs will be developed by Penna, supplier or subcontractor and provided to Penna for submittal to the Contracting Officer. Site Safety and Health Officer (SSHO). Penna shall employ a minimum of one Competent Person at each project site to function as the SSHO, depending on job complexity, size and any other pertinent factors. a. The SSHO shall be a full time responsibility unless specified differently in the contract. The SSHO shall report to a senior project (or corporate) official. See Responsibilities and Lines of Authorities. b. The SSHO(s), as a minimum, must have completed the 30 hour OSHA Construction safety class or as an equivalent, 30 hours of formal construction safety and health training covering the subjects of the OSHA 30 hour course. The SSHO is also required to have five (5) years of construction industry safety experience or three (3) years if he possesses a Certified Safety Professional (CSP) or safety and health degree. c. An SSHO (or a Designated Representative, as identified in the APP/AHA and as deemed appropriate/equivalent to SSHO by the GDA) shall be on site at all times when work is being performed. d. The SSHO shall be responsible for managing, implementing and enforcing Penna s Safety and Health Program in accordance with the accepted APP.

28 Page 28 e. SSHOs shall maintain this competency through 24 hours of formal safety and health related coursework every four (4) years. Penna s SSHO is responsible for ensuring subcontractor compliance with the safety and occupational health requirements contained in this Safety Plan. All visitors to USACE Government or Penna controlled sites presenting hazardous conditions shall be briefed by a Qualified Person on the hazards to be expected on the site and the safety and health controls required (for example, hard hat, foot protection, etc.). The person in charge of the site shall ensure that all visitors entering the site are properly protected and are wearing or provided with the appropriate PPE. Site personnel should maintain a stock of common PPE, such as hard hats, eye protection, ear plugs, and reflective vests, for use by visitors. The site manager shall provide an escort for all visitors while on site. A visitor sign in log shall be maintained on site. Safety meetings shall be conducted to review past activities, plan for new or changed operations, review pertinent aspects of appropriate AHA (by trade), establish safe working procedures for anticipated hazards, and provide pertinent safety and health training and motivation. a. Meetings shall be conducted at least once a month for all supervisors on the project location and at least once a week for all workers by supervisors or foremen. b. Meetings shall be documented, including the date, persons in attendance, subjects discussed, and names of individual(s) who conducted the meeting. Documentation shall be maintained and copies furnished to the GDA on request. c. The GDA shall be informed of all scheduled meetings in advance and be invited to attend. Emergency situations a. The subcontractors shall provide training in handling emergency situations that may arise from project activities or equipment operation. b. All persons who may have occasion to use emergency and rescue or lifesaving equipment shall be familiarized with the equipment location, trained in its proper use, be instructed in its capabilities and limitations, and medically qualified for its use.

29 Page TRAINING A. REQUIREMENTS FOR NEW HIRE SOH ORIENTATION TRAINING Superintendents and/or Foreman will instruct new employees in safety and security education and make them aware of Penna s policy in providing a drug free workplace. The instructions will be in accordance EM , Paragraph 01.B. Any person found to be creating continued safety and/or alcohol/drug abuse violations would be removed from the job. Instructions on safety and drug/alcohol abuse to individual employees will be given as needed and required during daily safety inspections. A SAFETY POLICY LETTER (attachment No.1) will be issued to all employees. A DRUG FREE AWARENESS PROGRAM LETTER (attachment No.2) will be issued to all employees. B. MANDATORY TRAINING AND CERTIFICATIONS FOR THIS PROJECT Penna Group Safety Policy Statement Required Personal Protective Equipment Hazard Communication Training First Aid/Injury Reporting Procedure Emergency Procedures (Fire, injury, etc.) Code of Safe Practices Employee Responsibilities Work Rules Drug & Alcohol in the Workplace Policy Hearing Conservation Program EEO and Sexual Harassment Policies Back Injury Prevention Trench Safety Heavy Equipment Safety Spill Prevention C. PROCEDURES FOR PERIODIC SAFETY AND HEALTH TRAINING FOR SUPERVISORS AND EMPLOYEES All employees, including those newly hired, will be instructed on Medical and Emergency Capabilities, Off Site Capabilities, Fire Capabilities, Fire, Police, Emergency Plans, Housekeeping, Material Storage, Work Area Access/Egress. All employees will be instructed to report all accidents, no matter how small, immediately to their supervisor.

30 Page 30 The First Aid personnel will examine any injured employee; at which time the decision to call for additional medical help will be made. Staff safety meetings will be held at least once a week or more often if conditions warrant. Means of reducing hazards and preventing unsafe working methods will be discussed at these meetings. Methods decided on will be passed on to the crews through toolbox safety meetings. Toolbox meetings will be held on a weekly basis and will be attended by all personnel on site. A sign in sheet will be provided. The subject matter will be given by the onsite Safety Manager and/or Superintendent. Copies of the attendance sheet and meeting subject matter will be maintained by Penna Group and attached to the Daily Report to be distributed to the Contracting Officer. Daily pre work meetings will be held to discuss work activities and correct procedures for working safely. New Hires will be informed of any specific during this meeting. Employees will be informed of hazardous substances prior to bringing them on the work site. At the beginning of the project, the onsite Safety Manager will review the Personal Protective Equipment (PPE) and company Safety Policy with all personnel, including demonstrations of the correct use of the PPE. Attendees will be required to sign a training sheet. A PPE Hazard Assessment Sheet will be filled out at the beginning of the project. No person shall be required or instructed to work in surroundings or under conditions that are unsafe or dangerous to his or her health. Penna Group is responsible for initiating and maintaining a safety and health program that complies with the US Army Corps of Engineers (USACE) safety and health requirements. Each employee is responsible for complying with applicable safety and occupational health requirements, wearing prescribed safety and health equipment, reporting unsafe conditions/activities, preventing avoidable accidents, and working in a safe manner. Safety and health programs, documents, signs, and tags shall be communicated to employees in a language that they understand. Worksites with non English speaking workers shall have a person(s), fluent in the language(s) spoken as well as English, on site when work is being performed, to interpret and translate as needed.

31 Page 31 D. REQUIREMENTS FOR EMERGENCY RESPONSE TRAINING If emergency response training is required it will be implemented and will be in accordance with EM , Sept. 2008, Appendix A, para 9.b. Inspections a. APP or USACE Project Safety and Health Plan Safety Inspections/Audits Not applicable. b. Penna Quality Control (QC) personnel as part of their QC responsibilities shall conduct and document daily safety and occupational health inspections in their daily QC logs. c. Identified safety and health issues and deficiencies, and the actions, timetable, and responsibility for correcting the deficiencies, shall be recorded in inspection reports. Follow up inspections to ensure correction of any identified deficiencies must also be conducted and documented in inspection reports. d. Penna shall establish a safety and occupational health deficiency tracking system that lists and monitors the status of safety and health deficiencies in chronological order. The list shall be posted on the project safety bulletin board, be updated daily, and should provide the following information: (1) Date deficiency identified; (2) Description of deficiency; (3) Name of person responsible for correcting deficiency; (4) Projected resolution date; (5) Date actually resolved. e. Penna shall immediately notify the GDA of any OSHA or other regulatory agency inspection and provide GDA an opportunity to accompany Penna on the inspection. (The inspection will not be delayed due to non availability of the GDA.) Penna shall provide the GDA with a copy of any citations or reports issued by the inspector and any corrective action responses to the citation(s) or report(s). E. SAFETY LOCKOUT/TAGOUT PROCEDURES Penna shall ensure that each employee is familiar with and complies with these procedures and 29 CFR

32 Page 32 Contracting Officer will, at Penna's request, apply lockout/tagout tags and take other actions that, because of experience and knowledge, are known to be necessary to make the particular equipment safe to work on. No person, regardless of position or authority, shall operate any switch, valve, or equipment that has an official lockout/tagout tag attached to it, nor shall such tag be removed except as provided in this section. No person shall work on any equipment that requires a lockout/tagout tag unless he, his immediate supervisor, project leader, or a subordinate has in his possession the stubs of the required lockout/tagout tags. When work is to be performed on electrical circuits only qualified personnel shall perform work on electrical circuits. A supervisor who is required to enter an area protected by a lockout/tagout tag will be considered a member of the protected group provided he notifies the holder of the tag stub each time he enters and departs from the protected area. Identification markings on building light and power distribution circuits shall not be relied on for established safe work conditions. Before clearance will be given on any equipment other than electrical (generally referred to as mechanical apparatus), the apparatus, valves, or systems shall be secured in a passive condition with the appropriate vents, pins, and locks. Pressurized or vacuum systems shall be vented to relieve differential pressure completely. Vent valves shall be tagged open during the course of the work. Where dangerous gas or fluid systems are involved, or in areas where the environment may be oxygen deficient, system or areas shall be purged, ventilated, or otherwise made safe prior to entry. Tag Placement Lockout/tagout tags shall be completed in accordance with the regulations printed on the back thereof and attached to any device which, if operated, could cause an unsafe condition to exist. If more than one group is to work on any circuit or equipment, the employee in charge of each group shall have a separate set of lockout/tagout tags completed and properly attached.

33 Page 33 When it is required that certain equipment be tagged, the Government will review the characteristics of the various systems involved that affect the safety of the operations and the work to be done; take the necessary actions, including voltage and pressure checks, grounding, and venting, to make the system and equipment safe to work on; and apply such lockout/tagout tags to those switches, valves, vents, or other mechanical devices needed to preserve the safety provided. This operation is referred to as "Providing Safety Clearance." Tag Removal When any individual or group has completed its part of the work and is clear of the circuits or equipment, the supervisor, project leader, or individual for whom the equipment was tagged shall turn in his signed lockout/tagout tag stub to the Contracting Officer. That group's or individual's lockout/tagout tags on equipment may then be removed on authorization by the Contracting Officer. 7. SAFETY AND HEALTH INSPECTIONS A. GENERAL PROJECT SAFETY POLICY The overall safety of human life is of prime concern. In conjunction with protection of life, health and well being of all persons involved, protection to property is also important. Safety is clearly everyone s responsibility, but is specifically the responsibility of management and supervisory personnel, Steven Ysasaga, the SSHO will perform inspections on a daily basis. While basic characteristics of the General ACCIDENT PREVENTION PLAN are to be followed throughout our operations, it is management s desire that job details be handled in a manner suited to its problems, facilities and personnel. Any safety requirement needed on this project and not outlined in this program will be as required in accordance with good common sense, experience and the Safety Manual EM dated Sept B. PROCEDURES AND METHODS FOR DAILY SAFETY INSPECTIONS Generally, safety inspections will be continuous every day. Any safety deficiencies or instances where safety measures are being implemented will be noted daily on the Construction Daily Reports by the Superintendent. Other safety instances noted by foreman or others will be reported to the Superintendent for action and inclusion into the CQC Report.

34 Page 34 Superintendent will maintain Material Safety Data Sheets (MSDS) for any hazardous substances brought on the site and/or in contact with any employee. A copy of all MSDS will be provided to the contracting officer s representatives and a copy will be located at the jobsite. C. SUBCONTRACTOR RESPONSIBILITIES The subcontractor and subcontractors supervisory personnel will be furnished a copy of the accident prevention plan and be apprised of their accident prevention responsibility prior to commencement of work. All subcontractors will be instructed in writing concerning the requirements of their responsibility under this plan; subcontractor s required to abide by the accident prevention plan and the safety manual requirements. D. EXTERNAL INSPECTIONS AND CERTIFICATIONS No external inspections and or certifications are anticipated, but any that may be required will be co coordinated with site SSHO. 8. ACCIDENT REPORTING A. TIMING OF REPORTS On a monthly basis an exposure report will be generated, that reflects the amount of man hours worked. This information will be given to the USACE at the end of each month. B. RESPONSIBILITY FOR INVESTIGATION Responsibility for reporting and investigating lost time injuries, accident and/or property damage will be the Superintendent. This person will immediately notify the Contracting Officer s Authorized Representative as required in the case of: Fatality A permanent total disability A permanent partial disability The hospitalization of three or more people resulting from a single occurrence Property damage of $200,000 or more. C. NOTIFICATION Immediate e mail notification and phone call to: Michael Evangelista Ysasaga, CEO

35 Page 35 Penna Group, LLC Direct Dial Jill Evangelista Ysasaga, Compliance Officer Penna Group, LLC Direct Dial This must be reported as soon as possible, but not more than 24 hours after occurrence. YOU MUST SUBMIT DOCTORS REPORT WITH COMPLETED FORM 3394 ACCIDENT INVESTIGATING REPORT of all accidents requiring immediate notification as indicated above. THIS REPORT IS DUE AS SOON AS POSSIBLE, BUT NO LATER THAN FIVE WORKING DAYS FROM DATE OF ACCIDENT. Damages in any amount to other (public or private) property must also be reported immediately. All injuries that require treatment greater than First Aid are to be reported immediately to the Superintendent and to the USACE office on the prescribed forms, giving a complete description as to how the accident happened and corrective actions that will be implemented to prevent re occurrence. This information should be forwarded to the CO/COR for review immediately. All injury, incident or fatalities shall be reported immediately by phone to: Michael Evangelista Ysasaga, CEO Penna Group, LLC Direct Dial michael@pennagc.com Jill Evangelista Ysasaga, Compliance Office Penna Group, LLC Direct Dial jill@pennagc.com In the event an employee is sent to a doctor for treatment, a release will be obtained from the doctor on the date of treatment stating either (1) employee not fit for duty; (2) employee fit for light duty; (3) employee fit for duty. A copy of this release will accompany the accident report. A record will be maintained of all first aid treatment.

36 Page 36 D. ACCIDENT REPORTING AND RECORDKEEPING All accidents occurring incidentally to an operation, project, or facility for which this manual is applicable shall be investigated, reported, and analyzed as prescribed by the GDA. Employees are responsible for reporting all injuries or occupationally related illnesses as soon as possible to their employer or immediate supervisor. Employers and immediate supervisors are responsible for reporting all injuries to the GDA as soon as reasonably possible but no later than 24 hours. No supervisor may decline to accept a report of injury from a subordinate. An accident that has, or appears to have, any of the consequences listed above shall be immediately reported to the GDA. Except for rescue and emergency measures, the accident scene shall not be disturbed until it has been released by the investigating official. Penna is responsible for obtaining appropriate medical and emergency assistance and for notifying fire, law enforcement, and regulatory agencies. Penna shall assist and cooperate fully with the GDA conducting the Government investigation(s) of the accident. Daily records of all first aid treatments not otherwise reportable shall be maintained on prescribed forms and furnished to the GDA upon request. In addition to any other applicable requirements within this section on contract operations, Penna shall: Maintain records of all exposure and accident experience incidental to the work (this includes exposure and accident experience of Penna and subcontractors and, at a minimum, these records shall include exposure work hours and a log of occupational injuries and illnesses OSHA Form 300 or equivalent as prescribed by 29 CFR 1904); provide a current copy of OSHA Form 300 or equivalent to the GDA upon request; Maintain health hazard assessment documentation and employee exposure monitoring to chemical, biological, and physical agents as required by Section 06. Provide this information to employees who are characterized by these assessments and exposure monitoring in accordance with OSHA requirements. Immediately notify the GDA of any exposure in excess of the limits specified in Section 06 and the hazard control measures that have been taken to reduce or eliminate such exposures.

37 Page 37 Submit project work hours to the COR monthly in the format provided by the COR. Work hours include all hours on the project where an employee is in an on duty pay status. E. EMERGENCY PLANNING Emergency plans to ensure employee safety in case of fire or other emergency shall be prepared, in writing, and reviewed with all affected employees. Emergency plans shall be tested to ensure their effectiveness. Plans shall include escape procedures and routes, critical plant operations, employee accounting following an emergency evacuation, rescue and medical duties, means of reporting emergencies, and persons to be contacted for information or clarification. On site emergency planning shall be integrated with off site emergency support. (Documentation of specific on site emergency services shall be made and may include written agreements, memoranda for record, telephone conversation logs, etc.) The emergency services provider should be offered an on site orientation of the project and associated hazards. Planning for any operation shall include the total system response capabilities to minimize the consequences of accidents or natural disaster and shall consider communications, rescue, first aid, medical, emergency response, emergency equipment, and training requirements. The number of persons permitted in any location shall correspond to rescue and escape capabilities and limitations. Emergency alert systems shall be developed, tested, and used to alert all persons likely to be affected by existing or imminent disaster conditions and to alert and summon emergency responders. Emergency telephone numbers and reporting instructions for ambulance, physician, hospital, fire, and police shall be conspicuously and clearly posted at the work site. Employees working alone in a remote location or away from other workers shall be provided an effective means of emergency communications. This means of communication could include a cellular phone, two way radios, hard line telephones or other acceptable means. The selected communication shall be readily available (easily within the immediate reach) of the employee and shall be tested prior to the start of work to verify that it effectively operates in the area/environment. An employee checkin/check out communication procedure shall be developed to ensure employee safety.

38 Page 38 F. EMERGENCY OPERATIONS In addition to the other pertinent parts of this Plan, Civil Disaster Emergency Operations for floods, earthquakes, and hurricanes shall be conducted in accordance with EM , Appendix B for both USACE and Penna activities. 9. PLANS (PROGRAMS, PROCEDURES) REQUIRED BY THE SAFETY MANUAL (as applicable) A. LAYOUT PLANS (04.A.01) The size and duration of this project warrants the use of a project/ tool trailer, the trailer will be anchored in accordance with state and local requirements. Parking by employees will be in designated areas Minimal public traffic is anticipated, but signs denoting the construction area as well as hard hats required will be posted. Temporary fencing will be required to prohibit public access and as the need for security dictates. Any other signage will be posted in accordance with EM Section 8. B. EMERGENCY RESPONSE PLANS: 1. Procedures and tests (01.E.01) All persons will be indoctrinated in the procedure of the emergency plan. Those who are assigned specific responsibilities, such as to direct emergency vehicles to work site or to secure the area until the needed emergency personnel arrive will be knowledgeable of their assigned duties. Emergency alert system will be implemented if workers are too far apart to warn one another of an impending emergency evacuation due to inclement weather, fire, etc. Three (3) long blasts from a vehicle horn to alert the employees of impending danger. If employees are working alone or in a remote area of the project, they will by provided with effective means of communication (cell phone, two way radio, etc.). Each foreman/superintendent will be responsible for performing a head check to make sure everyone is accounted for.

39 Page 39 Emergency phone numbers will be posted at work site. The local emergency offsite support services should be indoctrinated as to what procedures will be implemented for the most complete and successful handling of any given emergency. Each work area should be evaluated to insure that the number of persons working there in fact have the necessary corresponding rescue and escape capabilities. 2. Spill plans (01.E.01, 06.A.02) All substances, agents or materials incorporated into the work or any substance utilized by equipment or machinery will be evaluated to determine if it could be hazardous or toxic and become an environmental concern. If in fact any substances are noted as hazardous or toxic then they should be addressed in the Activity Hazard Analysis or the Position Hazard Analysis. The MSDS for the substance should be obtained and added to the AHA. The appropriate method for containing this substance should be addressed and through administrative, engineering and PPE. A determination will be made as to the best method of containment or prevention of exposure. Once the hazard assessment is complete, the name of the person performing the evaluation and the date the assessment was performed, must be submitted to the appropriate COR. For this project we anticipate the use of diesel fuel, gasoline, non potable water, hydraulic fluid, most of which the method discussed in the AHA provides for the guidelines for containment and disposal of these materials in the event of a spill. 3. Firefighting Plan (01.E.01, Section 19) a. Fire Capabilities o Firefighting equipment class B fire extinguisher will be placed at the office, fuel storage area, all company trucks, and all operated equipment. o Fire Department: Dial (911).(notify operator of your location) o Police Department: Dial (911). (notify operator of your location)

40 Page 40 o The emergency plan will provide for maximum response from equipment and manpower to minimize the consequences of a natural disaster, i.e., Storm/Tornado, or accidents. All workers, Penna and subcontractors, in the event of severe storms or tornado will move to the nearest low lying area away from trees, power lines, and equipment. In the event of no structural shelter the workers will move to available vehicles. The number of persons in any locations will be limited to the capabilities of the emergency plan to afford maximum protection. The emergency system personal will coordinate and supplement the local firefighters and law enforcement as necessary. o Emergency Telephone numbers will be conspicuously posted at the work site and a copy will be given to all supervisors. o All fire extinguishers will be inspected monthly to insure all are operational. If any are found to be discharged or inoperative, they are to be replaced immediately. o Trained Personnel in First Aid & CPR Steven Ysasaga & Frank Torres 4. Posting of Emergency Telephone Numbers (01.E.05) Penna Group will erect and maintain a safety and health bulletin board in a commonly accessed area in clear view of the on site workers. The bulletin board shall be continually maintained and updated and placed in a location that is protected against the elements and unauthorized removal. It shall contain, at minimum, the following safety and health information: a. A map denoting the route to the nearest emergency care facility; Map will be available at the jobsite. b. Emergency phone numbers; Hospital: Texas Health Presbyterian Hospital Denton 209 N. Bonnie Brae Denton, TX (940)

41 Page 41 Clinic: Minor Emergency of Denton 4400 Teasley Lane, Suite 200 Denton, Texas :00 am 10:00 pm (Mon Fri) 10:00 am 5:00 pm (Sat) 12:00 noon 5:00 pm (Sun) c. A copy of the most up to date Accident Prevention Plan (APP) shall be mounted on or adjacent to the bulletin board, or a notice on the bulletin board shall state the location of the APP. The location of the APP shall be accessible on the site by all workers; d. A copy of the current Activity Hazard Analysis/analyses (AHA) shall be mounted on or adjacent to the bulletin board, or a notice on the bulletin board should state the location of the AHAs. The location of the AHAs shall be accessible on the site by all workers; e. The Occupational Safety and Health Administration (OSHA) Form 300A, Summary of Work Related Injuries and Illnesses, shall be posted, in accordance with OSHA requirements, from February 1 to April 30 of the year following the issuance of this form. It shall be mounted on or adjacent to the bulletin board, which shall be accessible on the site by all workers; f. A copy of the Safety and Occupational Health deficiency tracking log shall be mounted on or be adjacent to the bulletin board or a notice on the bulletin board shall state the location where it may be accessed by all workers upon request; > See 01.A.12.d. g. Safety and Health promotional posters; h. Date of last lost workday injury; i. OSHA Safety and Health Poster. 5. Man Overboard/Abandon Ship (Section 19.A.04) Not Applicable. 6. Medical Support. Outline on site medical support and off site medical arrangements including rescue and medical duties for those employees who are to perform them, and the name(s) of on site Penna personnel trained in first aid and

42 Page 42 CPR. A minimum of two employees shall be certified in CPR and first aid per shift/site (Section 03.A.02; 03.D). Steven Ysasaga is the onsite person with first aid and CPR training. Hospital: Texas Health Presbyterian Hospital Denton 209 N. Bonnie Brae Denton, TX (940) Ambulance Service DIAL 911 Firefighting Service DIAL 911 Police Department DIAL 911 MEDICAL AND FIRST AID REQUIREMENTS GENERAL Prior to the start of work, arrangements shall be made for medical facilities and personnel to provide prompt attention to injured employees and for consultation concerning occupational safety and health matters. a. An effective means of communication (hard wired or cellular telephone, two way radio, etc.) with #911 access or other emergency response source, and transportation to effectively care for injured workers shall be provided. Communication devices shall be tested in the area of use to assure functionality. b. The telephone numbers of physicians, hospitals, or ambulances shall be conspicuously posted, at a minimum, on the safety bulletin board and near the on site project office telephones. Medical facilities and personnel expected to treat injured employees shall be informed of the nature of the work to be performed and the injuries/illnesses prevalent on such jobsites. c. A highly visible map delineating the best route to the nearest medical facility shall be prepared and posted on the safety bulletin board. First aid and cardiopulmonary resuscitation (CPR) availability a. When a medical facility or physician is not accessible within five (5) minutes of an injury to a group of two (2) or more employees for the treatment of injuries, at least two (2) employees on each shift shall be qualified to administer first aid and CPR.

43 Page 43 b. Individuals who are required to work alone in remote areas shall be trained in first aid and shall be provided with an effective means of communication to call for assistance in the event of an emergency. First aid and medical facility requirements a. All projects, activities, installations, or contracts for which fewer than 100 persons are employed (greatest total number of employees on a shift) at the site of the work, and where neither a first aid station nor an infirmary is available, shall be provided with a first aid kit complying with the criteria contained in ANSI Z There shall be one first aid kit for every 25 (or fewer) employees. In addition to the basic fill requirements of the first aid kit, the employer, in consultation with a health care professional or competent first aid person, shall evaluate the hazards found in the work environment to determine the necessity of optional fill contents. b. All projects, activities, installations, or contracts for which more than 99 and fewer than 300 persons are employed (greatest total number of employees on a shift) at the site of the work, shall establish and equip, as directed by a Licensed Physician (LP), a first aid station. In non rural locations, medical clinics, hospitals, or doctors offices, accessible within five (5) minutes of an injury may be approved for use provided the requirements of paragraph 03.A.03.a. are met. c. Where tunnels are being excavated, a first aid station and transportation facilities shall be provided so that treatment is available within five (5) minutes of the occurrence of an injury. d. All projects, activities, installations, or contracts for which 300 or more persons are employed (greatest total number of employees on a shift) at the site of the work shall establish and equip, as directed by a licensed physician, an infirmary. Should work activities present any potential exposure (of any part of the body) to toxic or corrosive materials, drenching and/or flushing facilities shall be provided in the work area for immediate emergency use. Before commencing use of epoxy resins, concrete, or other dermatitisproducing substances, employees shall be made aware of the manufacturers skin protection recommendations. Barrier cream ointment or other skin protection measures recommended by the manufacturer for the specific exposure shall be available for use.

44 Page 44 FIRST AID KITS The performance requirements of the first aid containers shall be based on the storage area location of the first aid kit and shall conform to ANSI Z308.1: a. Type I container is for permanently affixed indoor or atmospherecontrolled settings. Type 1 first aid kits are required to meet the requirements of a ten (10) unit container. b. Type II and Type III first aid kits shall, at a minimum, meet the requirements for a 16 unit container: (1) Type II container is for portable indoor settings; (2) Type III container is for portable outdoor settings. c. The contents of the first aid kit shall, at a minimum, contain the items detailed in EM , Section 3, Table 3 1. d. First aid kits shall be easily accessible to all workers and protected from the weather. The individual contents of the first aid kits shall be kept sterile. First aid kit locations shall be clearly marked and distributed throughout the site(s). The contents of first aid kits shall be checked by the employer prior to their use on site and at least every three (3) months when work is in progress to ensure that they are complete, in good condition, and have not expired. Automatic External Defibrillator (AED) Not applicable. FIRST AID STATIONS AND INFIRMARIE Not applicable. PERSONNEL REQUIREMENTS AND QUALIFICATIONS (over 1000 employees) Not applicable.

45 Page 45 C. PLAN FOR PREVENTION OF ALCOHOL AND DRUG ABUSE (01.C.02) (DEFENSE FEDERAL ACQUISITION REGULATION SUPPLEMENT (DFARS) SUBPART During the indoctrination of all new employees they are informed of company policies concerning drugs and alcohol. Policy states that anyone found under the influence of or consuming such substances will be immediately terminated and removed from the job site. All persons are made aware that random drug testing can and will be conducted. At the completion of the employer indoctrination they are required to sign a Drug Free Awareness Program Letter and upon doing so they agree to any company imposed drug test. D. SITE SANITATION PLAN (SECTION 02) Penna shall maintain all sanitation matters in compliance with EM (2008), Section 2, including the following: housekeeping; drinking water; non potable water; toilets; washing facilities; showers; changing rooms; clothes drying facilities; food service; waste disposal; and vermin control Drinking Water Water coolers will be provided along with individual drinking cups. The cooler will be marked drinking water. The supervision will insure all coolers are kept clean and sanitized daily to insure no contamination of the drinking water. Toilets On site portable toilets will be provided in accordance with TABLE F2 1 Pg. 26 EM

46 Page 46 Toilets will be serviced by a licensed sanitation company (Toilet Provider). Service requirements will be maintained once a week and more often if necessary. Washing Facilitates No Running water will be available at the jobsite. Hand sanitizers will be provided at area adjacent to toilet facility. Food Service Non Applicable to the contract Waste Disposal No putrescible or liquid waste is anticipated Containers will be provided for disposal of rubbish or debris that is generated from the worksite. These containers will be taken to appropriate dump sites or landfills and documented as to the amount of debris and the location taken to. Vermin Control No enclosed work places are expected storage areas will be monitored for rodents. Appropriate measure will be taken if a problem develops. MATERIAL HANDLING, STORAGE, AND DISPOSAL Employees shall be trained in and shall use safe lifting techniques. Requirements for PPE are covered in Section 5. Material handling devices shall be available for the material handling needs of an activity. Whenever heavy or bulky material is to be moved, the material handling needs shall be evaluated in terms of weight, size, distance, and path of movement. The following hierarchy shall be followed in selecting a means for material handling: a. Elimination of material handling needs by engineering; b. Movement by mechanical device (e.g., lift truck, overhead crane, or conveyor); c. Movement by manual means with handling aid (e.g., dollie or cart); or d. Movement using safe lifting techniques. > Reference NIOSH, Work Practices Guide for Manual Lifting.

47 Page 47 Materials will not be moved over or suspended above personnel unless positive precautions have been taken to protect the personnel from falling objects. Where the movement of materials may be hazardous to persons, taglines or other devices shall be used to control the loads being handled by hoisting equipment. These devices shall be nonconductive when used near energized lines. MATERIAL STORAGE All material in bags, containers, bundles, or stored in tiers shall be stacked, blocked, interlocked, and limited in height so that it is stable and secured against sliding or collapse. a. Material shall be stacked as low as practical and in no case higher than 20 ft (6m) unless otherwise specified in this Section. b. Storage of flammable and combustible materials is covered in Section 9. c. Storage of hazardous and toxic agents is covered in Section 6. Material stored inside buildings under construction shall not be placed within 6 ft (1.8 m) of any hoistway or floor opening, nor within 10 ft (3 m) of an exterior wall that does not extend above the material stored. Accessways shall be kept clear Unauthorized persons shall be prohibited from entering storage areas. All persons shall be in a safe position while materials are being loaded or unloaded from railroad cars, trucks, or barges. Material shall not be stored on scaffolds or runways in excess of needs for normal placement operations or in excess of safe load limits. Noncompatible materials shall be segregated in storage. Storage of lumber a. Storage of lumber during construction shall be in sections containing a maximum of 1 million board feet with at least a 10 ft (3m) clearance from buildings. b. Lumber shall be supported on stable sills and shall be stacked level, stable, and self supporting.

48 Page 48 c. Reusable lumber shall have all nails withdrawn before it is stacked for storage. d. Lumber piles shall not exceed 20 ft (6m) in height; lumber to be handled manually shall not be stacked more than 16 ft (4.8m) high. Storage of bagged materials. a. Bagged materials shall be stacked by stepping back the layers and cross keying the bags at least every 10 bags high. b. Bags of cement and lime shall not be stacked more than 10 high without setback, except when restrained by walls of appropriate strength. c. The bags around the outside of the stack shall be placed with the mouths of the bags facing the center of the stack. d. During unstacking, the top of the stack shall be kept nearly level and the necessary setback maintained. Storage of brick a. Brick shall be stacked on an even, solid surface. b. Bricks stacks shall not be more than 7 ft (2.1 m) high. when stacked loose brick reaches a height of 4 ft (1.2 m), it shall be tapered back 2 in (5 cm) in every 1 ft (0.3 m) of height above the 4 ft (1.2 m) level. c. Unitized brick (brick securely gathered into large standard packages and fastened with straps) shall not be stacked more than three units high. Storage of floor, wall, and partition block a. Blocks shall be stacked in tiers on solid, level surfaces. b. When masonry blocks are stacked higher than 6 ft (1.8 m), the stack shall be tapered back one half block per tier above the 6 ft level. Storage of reinforcing and structural steel a. Reinforcing steel shall be stored in orderly piles away from walkways and roadways.

49 Page 49 b. Structural steel shall be securely piled to prevent members sliding off or the pile toppling over. Storage of cylindrical material a. Structural steel, poles, pipe, bar stock, and other cylindrical materials, unless racked, shall be stacked and blocked so as to prevent spreading or tilting. b. Pipe, unless racked, shall not be stacked higher than 5 ft (1.5 m). c. Either a pyramid or battened stack shall be used. d. Where a battened stack is used, the outside pile or pole shall be securely chocked. Battened stacks shall be tapered back at least one pile or pole in each tier. e. Unloading of round material shall be done so that no person is required to be on the unloading side of the carrier after the tie wires have been cut or during the unlocking of the stakes. HOUSEKEEPING Work areas and means of access shall be maintained safe and orderly. a. Sufficient personnel and equipment shall be provided to ensure compliance with all housekeeping requirements. b. Work areas shall be inspected daily for adequate housekeeping and findings shall be recorded on daily inspection reports. c. Work will not be allowed in those areas that do not comply with the requirements of this Section. All stairways, passageways, gangways, and accessways shall be kept free of materials, supplies, and obstructions at all times. Loose or light material shall not be stored or left on roofs or floors that are not closed in, unless it is safely secured. Tools, materials, extension cords, hoses, or debris shall not cause tripping or other hazards.

50 Page 50 Tools, materials, and equipment subject to displacement or falling shall be adequately secured. Empty bags having contained lime, cement, and other dust producing material shall be removed periodically as specified by the GDA. Form and scrap lumber and debris shall be cleared from work areas and accessways in and around building storage yards and other structures. Protruding nails in scrap boards, planks, and timbers shall be removed, hammered in, or bent over flush with the wood. Storage and construction sites shall be kept free from the accumulation of combustible materials. a. Weeds and grass shall be kept down. b. A regular procedure shall be established for the cleanup of the areas as specified by the GDA. c. Rubbish, brush, long grass, or other combustible material shall be kept from areas where flammable and combustible liquids are stored, handled, or processed. Accumulation of liquids, particularly flammable and combustible liquids, on floors, walls, etc., is prohibited. All spills of flammable and combustible liquids shall be cleaned up immediately. DEBRIS NETS When used with personnel safety nets, debris nets shall be secured on top of the personnel safety net but shall not compromise the design, construction or performance of the personnel nets. A competent person shall determine and document the size, weight and height of fall of anticipated debris. The debris netting shall have a mesh of the size and strength sufficient to contain the expected debris without penetration when properly supported. Materials, scraps, equipment, tools and debris that have fallen into the net shall be removed as soon as possible from the net and at least before the next work shift. Nets and debris shall be protected from sparks and hot slag resulting from welding and cutting operations.

51 Page 51 Inspection of debris nets. a. Debris nets shall be inspected by a competent person in accordance with the manufacturer s recommendations. b. Inspections shall be conducted after installation, at least weekly thereafter, and following any alteration, repair or any occurrence that could affect the integrity of the net system. Inspections shall be documented and maintained on site. c. Defective nets shall not be used; defective components shall be removed from service. d. When welding or cutting operations occur above the nets, frequency of inspections shall be increased in proportion to the potential for damage to the nets. MATERIAL DISPOSAL Waste material and rubbish shall be placed in containers or, if appropriate, in piles. Waste materials and rubbish shall not be thrown down from a height of more than 6 ft (1.8 m), unless the following are complied with: a. The materials or rubbish are dropped through an enclosed chute constructed of wood or equivalent material. Chutes for debris shall be enclosed, except for openings equipped with closures at or about floor level for the insertion of materials. The openings shall not exceed 4 ft (1.2 m) in height measured along the wall of the chute. Openings shall be kept closed when not in use. b. When debris cannot be handled by chutes, the area into which the material is dropped shall be enclosed with barricades not less than 42 in (1.1 ) in height. Barricades shall be positioned to keep personnel from all debris landing areas. Signs warning of the hazard of falling material shall be posted at all debris landing areas and at each level exposed to falling debris. See Section 9 for burning requirements. Separate covered, self closing, nonflammable/nonreactive containers shall be provided for the collection of garbage, oily, flammable, and dangerous wastes. a. The containers shall be labeled with a description of the contents.

52 b. The contents shall be properly disposed of daily. Revised Safety Plan Ray Roberts Dam Page 52 Hazardous material waste (i.e., vehicle and equipment oils and lubricants, containers and drums for solvents, adhesives, etc.) shall be collected, stored, and disposed of in accordance with Federal, State, and local requirements. E. ACCESS AND HAUL ROAD PLAN (4.B) The location of the proposed haul roads are shown on Contract Drawing CG 108. These locations will be adhered too unless jobsite conditions require them to be relocated. F. RESPIRATORY PROTECTION PLAN (05.G) AND PERSONAL PROTECTIVE AND SAFETY EQUIPMENT Responsibilities a. The use of PPE is a control measure that is to be used only after a hazard evaluation identifies hazards associated with a particular job or activity, and it is determined that the hazards cannot be eliminated and/or controlled to an acceptable level through engineering design or administrative actions. Utilize process and engineering controls before PPE to protect employees. b. Based on hazard evaluations conducted by supervisors, employers shall identity and select, and each affected employee shall use, PPE and safety equipment that will provide appropriate protection. > See 29 CFR c. Penna and all Subcontractors shall communicate PPE and safety equipment decisions to each affected employee. Employees shall use all PPE and safety equipment that may be required to maintain their exposure within acceptable limits. d. Penna will make all reasonable efforts to accommodate employees with religious beliefs that may conflict with determined PPE requirements. However, when reasonable efforts to accommodate employee s religious beliefs do not provide the necessary safe working environment (without PPE), then the employee must use the appropriate PPE or the employee will not be allowed to work in the area where the hazard requiring protection exists. Employees shall be appropriately trained in the use and care of all required PPE and safety equipment. a. Employees must be trained in and shall demonstrate an understanding of the following aspects of PPE prior to use: selection (for specific hazard); donning,

53 Page 53 doffing and adjusting; limitations and useful life; inspection and testing; and proper care including maintenance, storage and disposal. b. When the employer has reason to believe that any affected employee who has been trained does not have the understanding and skill required for the use of the PPE, the employer shall make certain that the employee receives the necessary re training to acquire the appropriate skills. c. The employer shall verify through written certification that each affected employee has received and understood the required training. The written certification shall identify the name of each employee trained, the date(s) of the training, and the subjects taught. A copy of the manufacturer's use, inspection, testing, and maintenance instructions shall be maintained with the PPE and safety equipment. Personal protective and safety equipment shall be tested, inspected, and maintained in a serviceable and sanitary condition as recommended by the manufacturer. a. Defective or damaged equipment shall not be used. It shall be tagged as out of service and/or immediately removed from the work site to prevent use. b. Previously used PPE must be cleaned, disinfected, inspected, and repaired as necessary before issuing to another employee. When employees provide their own safety equipment or PPE, Penna is responsible for assuring its adequacy in protecting against the hazard and its state of repair. Minimum requirements. a. Employees shall wear clothing suitable for the weather and work conditions. For fieldwork (for example, construction sites, industrial operations and maintenance activities, emergency operations, regulatory inspections, etc.), at a minimum, this shall be: (1) Short sleeve shirt; (2) Long pants (excessively long or baggy pants are prohibited); and (3) Leather or other protective work shoes or boots. b. Protective equipment shall be of heat, fire, chemical, and/or electrical resistive material when conditions require protection against such hazards.

54 Page 54 Miners lights and flashlights used around explosives, and in atmospheres likely to contain explosive vapors, dusts, or gases shall be approved by the Mine Safety and Health Administration (MSHA) or National Institute for Occupational Safety and Health (NIOSH) for use in such locations. Persons involved in activities that subject the hands to injury (for example, cuts, abrasions, punctures, burns, chemical irritants, toxins, vibration, and forces that can restrict blood flow) shall select and use hand protection appropriate for the hazard in accordance with ANSI/International Safety Equipment Association (ISEA) 105. Protective leg chaps shall be worn by workers who operate chain saws. Protective leg chaps must meet the specifications in American Society for Testing and Materials (ASTM) Standard F1897. EYE AND FACE PROTECTION Persons shall be provided with eye and face protection equipment, as outlined in EM , Section 5, Table 5 1, when machines or operations present potential eye or face injury from physical, chemical, or radiation agents. a. Eye and face protection equipment shall meet the requirements of ANSI/ American Society of Safety Engineers (ASSE) Z87.1, and bear a legible and permanent "Z87" logo to indicate compliance with the standard. b. Eye and face protection equipment shall be distinctly marked to facilitate identification of the manufacturer. c. Employees shall use eye protection providing side protection. When required by this regulation to wear eye protection, persons whose vision requires the use of corrective lenses in eyeglasses shall be protected by one of the following: a. Prescription safety glasses providing optical correction and equivalent protection; b. Protective glasses with sideshields designed to fit over corrective lenses without disturbing the adjustment of the glasses; c. Goggles that can be worn over corrective lenses without disturbing the adjustment of the glasses, or d. Goggles that incorporate corrective lenses mounted behind the protective lenses.

55 Revised Safety Plan Ray Roberts Dam Page 55 TABLE 5 1 EYE AND FACE PROTECTOR SELECTION GUIDE f'1 6U A. Spectacle, No sideshield ~ B. Spectacle, Half Sideshield "'ffijm E. Spectacle, Non-Removable Lens ~, F. Spectacle, Lift Front I. Cover Goggle, Direct Ventilatior O(p J. Cup Goggle, Direct Ventilatior C'~ C. Spectacle, Full Sideshield G. Cover Goggle, No Ventilation K. Cup Goggle, Indirect Ventilatior ~ D. Spectacle, Detachable Sideshield H. Cover Goggle, Indirect Ventilation L. Spectacle, Headband Temple

56 Revised Safety Plan Ray Roberts Dam Page 56 TABLE 5 1 (CONTINUED) EYE AND FACE PROTECTOR SELECTION GUIDE M. Cover Welding Q. Welding Helmet, Goggle, Indirect Lift Front Ventilation S. Respirator N. Faceshield T1. Respirator o. Welding Helmet, hand Hold T2. Respirator P. Welding Helmet, Stationary Window R. Respirator U. Respirator

57 Revised Safety Plan Ray Roberts Dam Page 57 TABLE 5 1 (CONTINUED) EYE AND FACE PROTECTOR SELECTION GUIDE IMPACT: Chipping, grinding, machining, masonry'nork, riveting and sanding Assessment Protector Protectors Lim itations Not See Note (1) Type Recom mended Flying B, C, D, E, F, Spectacles, Protective Protectors that do fragments, G, H, I, J, K, goggles, devices do not not provide objects, large L, N faceshields provided protection from chips, unlimited side exposure particles, SEE protection. SEE NOTE (10) sand, dirt, etc. NOTES (1 )(3)(5)(6) SEE NOTE (7) Filter or tinted (10) lenses that restrict For severe light transmittance, exposures add N HEAT: Furnace operations, pouring, casting, hot dipping, gas cutting, and v.elding unless it is determined that a glare hazard exists. Refer to OPTICAL RADIATION. Assessment Protector Protectors Lim itations Not See Note (1) Type Recom mended Hot sparks B, C, D, E, F, Faceshields, Spectacles, Protectors that do G, H, I, J, K, goggles, cup and cover not provide L, N spectacles type goggles protection from For severe do not provide side exposure exposure unlimited facial add N protection Splash from N Faceshields molten metals 'NOrn over goggles H, K SEE NOTE SEE NOTE (2) (2)(3) SEE NOTE (2)(3) High N Screen SEE NOTE (3) temperature faceshields, exposure reflective faceshields

58 TABLE 5 1 (CONTINUED) EYE AND FACE PROTECTOR SELECTION GUIDE CHEMICAL: Acid and chemical handling, degreasing, plating Revised Safety Plan Ray Roberts Dam Page 58 Assessment Protector Protectors Lim itations Not See Note (1) Type Recommended Splash G, H, K Ventilation Spectacles, should be v.elding helmets, For severe adequate but hand shields N exposure protected from add N splash entry Irritating mists G Special SEE NOTE (3) purpose goggles DUST: Wood..-.orking, buffing, general industry conditions Assessment Protector Protectors Lim itations Not See Note (1 ) Type Recomm ended Nuisance dust G, H, K Goggles, Atmospheric eyecup and conditions and cover types the restricted ventilation of the protector can cause the lenses to fog. Frequent cleaning may be required. OPTICAL RADIATION: Welding: electric arc Assessment Protector Protectors Lim ital ions Not See Note (1 ) Type Recom mended o,p,a Typical filter Protection Protectors that do lens shade from optical not provide radiation is protection from directly related optical radiation. to filter lens density. SEE NOTE (4). Select the darkest shade that allows adequate task performance.

59 Page 59 NOTES: (1) Care should be taken to recognize the possibility of multiple and simultaneous exposure to a variety of hazards. Adequate protection against the highest level of each of the hazards must be provided. (2) Operations involving heat may also involve optical radiation. Protection from both hazards shall be provided. (3) Faceshields shall only be worn over primary eye protection. (4) Filter lenses shall meet the requirements for shade designations in Table 5 2. (5) Persons whose vision requires the use of prescription (Rx) lenses shall wear either protective devices fitted with prescription (Rx) lenses with sideshields or protective devices designed to be worn over regular prescription (Rx) eyewear. (6) Wearers of contact lenses shall also be required to wear appropriate covering eye and face protection devices in a hazardous environment. It should be recognized that dusty and/or chemical environments may represent an additional hazard to contact lens wearers. (7) Caution should be exercised in the use of metal frame protective devices in electrical hazard areas. (8) Refer to ANSI/ASSE Z87 1, Section 6.5, Special Purpose Lenses. (9) Welding helmets or hand shields shall be used only over primary eye protection. (10) Non sideshield spectacles are available for frontal protection only. Personnel who are considered blind in one eye and are working in other than administrative functions shall wear safety glasses with sideshields at all times. Operations that require the use of, or exposure to, hot or molten substances (for example, babbitting, soldering, pouring or casting of hot metals, handling of hot tar, oils, liquids, and molten substances) shall require eye protection, such as goggles with safety lenses and screens for side protection, or face masks, shields, and helmets giving equal protection. Lens mountings shall be able to retain in position all parts of a cracked lens. Operations that require handling of harmful materials (for example, acids, caustics, hot liquids, or creosoted materials) and operations where protection from gases, fumes, and liquids is necessary shall require the wearing of goggles with cups of soft pliable rubber

60 Page 60 and suitable faceshields, masks, or hoods that cover the head and neck, and other protective clothing appropriate to the hazards involved. Operations where protection from radiant energy with moderate reduction of visible light is necessary, including welding, cutting, brazing, and soldering, shall require eye and face protection suitable to the type of work, providing protection from all angles of direct exposure, and with lenses of the appropriate shade. > See Table 5 2. Glare resistant glasses that comply with ANSI Z80.3 with an ultraviolet A region (UVA) and ultraviolet B region (UVB) 99% filtration shall be worn when conditions require protection against glare. When conditions so warrant, polarized lenses shall also be considered. Tinted or automatically darkening lenses should not be worn when work tasks require the employee to pass often from brightly to dimly lighted areas.

61 Revised Safety Plan Ray Roberts Dam Page 61 TABLE 5 2 REQUIRED SHADES FOR FILTER LENSES AND GLASSES IN WELDING, CUTTING, BRAZING, AND SOLDERING OPERATION SHADE NUMBER Soldering 2 Torch Brazing 3 or 4 Cutting (light) up to 1 in (2.5 em) 3 or 4 Cutting (medium) 1 to 6 in (2.5 to 15.2 em) 40r5 Cutting (heavy) 6 in (15.2 em) or more 5 or 6 Gas welding (light) up to 1/8 in (0.3 em) 40r5 Gas welding (medium) 1/8 to 1/2 in (0.3 to 1.2 em) 5 or 6 Gas welding (heavy) 1/2 in (1.2 em) or more 6 or 8 Atomic hydrogen welding Inert-gas metal-arc welding (nonferrous) - 1/16 to 5/32 in 11 (0.1 to 0.4 em) electrodes Inert-gas metal-arc welding (ferrous) -1 /16 to 5132 in 12 (0.1 to 0.4 em) electrodes Shielded metal-arc welding - 1/16 to 5/32 in (0.1 to 0.4 em) 10 electrodes Shielded metal-arc welding - 3/16 to 1/4 in (0.4 to 0.6 em) 12 electrodes Shielded metal-arc welding - 5/16 to 3/8 in (0.7 to 0.9 em) 14 electrodes Carbon arc welding 14

62 Page 62 HEARING PROTECTION AND NOISE CONTROL Sound pressure level limits. Non DOD personnel shall be provided, as a minimum, protection against the effects of hazardous noise exposure whenever the sound pressure level exceeds the limits and/or exposure times specified in EM , Section 5, Table 5 3. DOD personnel shall be provided protection against the effects of hazardous noise exposure whenever sound pressure levels exceed 85 decibels A weighed [db(a)] steady state expressed as a time weighted average (TWA) as specified in Table 5 4 or 140 db(a) impulse. Practical engineering or administrative controls shall be considered and used when personnel are subjected to sound pressure levels exceeding the limits specified in Tables 5 3 and 5 4. When such controls fail to reduce sound pressure levels to within the specified limit, PPE shall be selected, evaluated, provided, and used in accordance with the hearing conservation program. Hearing protection provided must be capable of reducing worker noise exposure below an 8 hour TWA of 85 db(a). When hearing protection devices do not provide sufficient attenuation to reduce the worker noise exposure level below 85 db(a), administrative control of exposure will be necessary.

63 Revised Safety Plan Ray Roberts Dam Page 63 TABLE 5 3 PERMISSIBLE NON DoD NOISE EXPOSURES (Penna) Whenever sound pressure levels equal or exceeds 85 db(a) (measured as an 8 hour TWA), a continuing, effective hearing conservation program shall be administered in accordance with 29 CFR For DODD personnel the hearing conservation program shall conform to DODI and Department of the Army Pamphlet (DA Pam) When sound pressure levels exceed 115 db(a) steady state, personal ear protection equivalent to the combination of earplugs and earmuffs shall be required. Sound pressure level measurements shall be made by qualified personnel using calibrated instruments.

64 Revised Safety Plan Ray Roberts Dam Page 64 Ear insert devices, to include disposable, preformed, or custom molded earplugs, shall be fitted to the exposed individuall by an individual trained in such fitting and able to recognize the difference between a good and a poor fit. Plain cotton is not an acceptable protective device. Noise hazard areas (areas in which sound pressure levels exceed the limits specified in 05.C.01) shall be marked with caution signs indicating both the presence of hazardous noise levels and the requirement for hearing protection. TABLE 5 4 PERMISSIBLE DoD NOISE EXPOSURE (Government) HEAD PROTECTION All persons working in or visiting hard hat areass shall be provided with and required to wear Type I or Type II, Class G (General low voltage electrical protection) or Class E (Electrical high voltage electrical protection) headgear.. For emergency response operations and other activities with greater need for side impact protection, Type II head protection is recommended. Hard hat areas or activities are those areas with potential hazard of head injury; in general, all construction areas are considered hard hat areas. However, areas may be considered non hard hat areas, or activities may be considered non hard AHA. The hat activities, if identified and properly documentedd in the associated identification and analysis of head hazards will be documented in an AHA, APP, or project safety and health plan, as appropriate.

65 Page 65 Points of entry to a hard hat area shall have a sign warning of the requirement to wear hard hats. All protective headgear shall meet the requirements of ANSI Z89.1. No modification to the shell or suspension is allowed except when such changes are approved by the manufacturer. Hard hats shall be worn with the bill facing forward unless the GDA has determined exceptions for certain trades in order to accommodate appropriate mission accomplishments. Headgear must be designed to accommodate these needs. Protective headgear worn near electric lines and equipment shall be Class E. No ball caps, knit caps, or other headdress shall be worn under the hard hat that could interfere with the fit or stability of the hard hat. Protective headgear and components shall be visually inspected on a daily basis for signs of damage (dents, cracks, etc.) that might reduce the degree of safety integrity originally provided. Headgear will be periodically inspected for ultraviolet degradation as evidenced by cracking or flaking of the helmet. Drilling holes or in any way changing the integrity of the hard hat is prohibited. Alterations that will reduce the dielectric or impact strength will not be made. Protective headgear worn by USACE employees Will be used as required above. PROTECTIVE FOOTWEAR Protective footwear that addresses the hazard(s) identified in the PHA/AHA shall be provided and worn. All protective footwear shall meet ASTM F2412 and F2413 standards. Add on type devices, such as strap on foot, toe or metatarsal guards, shall not be used as a substitute for protective footwear and must be demonstrated by the employer to be equally effective via independent testing data for these devices). For activities in which USACE or Penna personnel or official visitors are potentially exposed to foot hazards, the applicable PHA/AHA, APP, or project safety and health plan

66 Page 66 shall include an analysis of, and prescribe specific protective measures to be taken for, reducing foot hazards. Personnel shall, as a minimum, wear safety toed boots meeting ASTM Standards F2412 and F2413 while working on construction sites unless it can be demonstrated by a PHA/AHA to the GDAs satisfaction that a different type of foot protection is required. Footwear providing protection against impact and compressive forces, conduction hazards, electrical hazards and sole puncture shall comply with the applicable requirements of ASTM F2412 and F2413. Footwear providing protection against impact and compression hazards shall be rated as I/75 and C/75. Unexploded ordnance (UXO) personnel whose job tasks required protective footwear but require no metal parts in or on their footwear shall wear Conductive footwear (Cd) with protective toe cap/composite toe footwear. Personnel participating in wild land fire management activities shall wear leather lace up boots with slip resistant soles, such as a hard rubber lug type or tractor tread, a top height of 8 in (20.3 cm) or more with composite toes. Soles shall not be made of composition rubber or plastic, which have low melting points. HIGH VISIBILITY APPAREL High visibility apparel meeting, at minimum, ANSI/ISEA Performance Class 2 requirements, shall be worn by workers (such as, but not limited to, signal persons, spotters, survey crews and inspectors) whenever: Workers are exposed to vehicular or equipment traffic at speeds up to 45 mph (72.4 kph); There is limited visibility of workers exposed to mobile/heavy equipment operations, vehicles, load handling, or other hazardous activities; Reduced visibility conditions exist due to weather conditions, illumination, or visually complex backgrounds where ambient visibility is at least 50 ft (15.2 m); OR Workers are involved in activities in close proximity to vehicular traffic with no protective barriers. If any or all of the following conditions exist, a determination shall be made by the SSHO, based on a risk assessment, as to whether Performance Class 3 high visibility apparel is needed for higher visibility of workers. If so, they shall be worn by workers.

67 Page 67 a. Workers are exposed to vehicular or equipment traffic in excess of 45 mph (72.4 kph); b. Reduced visibility conditions exist due to weather conditions, illumination, or visually complex backgrounds where ambient visibility is less than 50 ft (15.2 m); OR c. Workers are performing tasks which divert attention from approaching vehicular traffic, traveling in excess of 45 mph (72.4 kph), as posted. The apparel background material color shall be either fluorescent yellow green, fluorescent orange red, or fluorescent red (see ANSI/ISEA 107). When choosing color, optimization of color conspicuity between the wearer and work environment shall be considered. RESPIRATORS General. The use of respirators is required when occupational exposure levels exceed OSHA Permissible Exposure Limits (PELs) or American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs), and engineering or administrative exposure controls are not feasible to implement. The voluntary use of dust masks (filtering face piece respirators) is permissible in atmospheres that are not hazardous. Prior to use of the voluntary respirators (including filtering face pieces), they must be evaluated and approved by the respiratory program administrator to ensure that the respirator use will in itself not create a hazard. If filtering face piece respirators are used, the employer shall provide the respirator users with the information contained in Appendix D of OSHA Standard 29 CFR Written respiratory protection program. A written respiratory protection program shall be developed and implemented when respirators are used. a. All employees using respirators, with the exception of employees voluntarily using only filtering face pieces (NIOSH approved dust masks), shall be included in the respiratory protection program. b. A respiratory protection program administrator with the technical qualifications (training and experience) and administrative authority to develop, implement and update (as necessary) the respiratory protection program shall be identified and so designated in the program.

68 Page 68 The program administrator shall ensure that all respirator users (voluntary users included) comply with the requirements of the program. Program Administrator Qualifications. The program administrator shall have the documented knowledge and experience to understand OSHA s respiratory protection standard (29 CFR ), evaluate respiratory hazards at the facility/project, select appropriate respirators based on facility/project hazards or potential hazard, and train employees on the use of selected respirators. c. Respiratory protection programs shall address each of the following topics: Methods used to identify and evaluate workplace respiratory hazards; Procedures for selecting respirators for use in the workplace; Medical evaluations of employees required to use respirators; Fit testing procedures for tight fitting respirators; Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations; Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators; Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere supplying respirators; Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations; Training of employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance; and Procedures for regularly evaluating the effectiveness of the program. Project/facility specific voluntary use guidelines and a requirement for voluntary users to learn and understand the contents of 29 CFR Appendix D, Information for Employees Using Respirators When Not Required Under the Standard.

69 Page 69 Medical evaluation. All employees, with the exception of employees voluntarily using filtering face pieces, shall be medically evaluated to ensure they are fit enough to wear the selected respirators. Evaluation options for respirator use are as follows: a. Physical Examination. A physical examination for the purpose of clearing an employee to wear a selected respirator, supervised by a Board Certified Occupational Medicine Physician. Medical clearances to wear respirators shall include the following: Telephone, e mail, and physical address of the medical facility/provider; Printed name of the licensed, certified health care provider along with his/her signature; The statement of clearances or respiratory limitations only (no personal medical information shall be included. Employee identification shall not include the full social security number); Date of examination and date that clearance expires. b. Respirator Medical Evaluation Service. An on line, mail in or in person evaluation service for the purpose of clearing an employee to wear selected respirators may be used provided it is supervised by a Board Certified Occupational Medicine Physician and based upon Appendix C to 29 CFR , OSHA Respirator Medical Evaluation Questionnaire. Medical clearances to wear respirators shall include the information in (1) (4) above. c. Additional Medical Evaluations shall be provided when: An employee reports medical signs or symptoms that are related to the ability to use a respirator; A supervisor or the respirator program administrator informs the employer that an employee needs to be reevaluated; Information from the respiratory protection program, including observations made during fit testing and program evaluation, indicates a need for employee reevaluation;

70 Page 70 A change occurs in workplace conditions (e.g., physical work effort, protective clothing, temperature) that may result in a substantial increase in the physiological burden placed on an employee, OR It has been two years since the last medical evaluation. Fit testing. Employees wearing respirators with tight fitting face pieces [Supplied Air Respirators (SARs) and Self Contained Breathing Apparatus (SCBAs) included] shall be fit tested to ensure that selected respirators achieve a proper face to face piece seal. Fit testing shall be performed before initial use of the selected respirator, whenever respirator size, make or model is changed, and at least annually thereafter. Fit testing requirements shall comply with respiratory protection program requirements. Training and information. The program administrator or his designee shall provide respirator user training annually (or when requirements change significantly due to process changes or changes in site specific operations) to personnel using respirators at the facility or project. Annual training shall ensure that each employee using a respirator can demonstrate knowledge of the following topics: Why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator; Limitations and capabilities of the respirator; How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions; How to Inspect, put on and remove, use, and check the seals of the respirator; Procedures for maintenance and storage of the respirator; How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators; and g. The general requirements of the OSHA respirator standard at 29 CFR Recordkeeping. Establish and retain written information regarding medical evaluations, fit testing, and the respirator program. The following shall be made available upon request:

71 Page 71 a. Records of medical evaluations must be retained and made available, as needed; b. Fit test records must be maintained for respirator users until the next fit test is administered. Establish a record of the Qualitative Fit Test (QLFT) and Quantitative Fit Test (QNFT) administered to an employee including: The name or identification of the employee tested; Type of fit test performed and name of the test administrator; Specific make, model, style, and size of respirator tested; Date of test; and The pass/fail results for QLFTs or the fit factor and strip chart recording or other recording of the test results for QNFTs. c. Retain a written copy of the current respirator program. FULL BODY HARNESSES, LANYARDS, AND LIFELINES Full body harnesses, lanyards and lifelines are considered components of personal fall protection systems. Requirements for these components can be found in Section 21.H.05. Lineman s equipment (electrically rated harnesses). The full body harness used around high voltage equipment or structures shall be an industry designed "Linemen's FP Harness" that will resist arc flashing. See 21.H.05.d.(2). ELECTRICAL PROTECTIVE EQUIPMENT Persons working on electrical distribution systems shall be provided with the appropriate electrical protective equipment. This equipment shall be inspected, tested, and maintained in safe conditions in accordance with Table 5 5. Employees shall use rubber gloves, sleeves, blankets, covers, and line hoses as required by special conditions for work on energized facilities. Rubber goods provided to protect employees who work on energized facilities must meet ASTM F18 standards. Electrical workers' rubber insulating protective equipment shall be visually inspected for damage and defects prior to each use.

72 Revised Safety Plan Ray Roberts Dam Page 72 Rubber protective equipment must be subjected to periodic electrical tests. Rubber nsulating gloves shall be inspected before firstt issue and every 6 months thereafter; rubber insulating blankets and sleeves shall bee inspected before their first issue and every 12 months thereafter. Rubber insulating coverss shall be inspected upon indication that insulating value is suspect (per ). TABLE 5 5 STANDARDS S FOR ELECTRICAL PROTECTIVE EQUIPMENT

73 Page 73 Electric arc flash protection shall be provided for any person who enters the flash protection zone. They must wear flame resistant clothing and PPE, based on the incident exposure associated with the specific task. Refer to NFPA 70E for specific Hazard Risk Classifications and clothing/equipment requirements. > Synthetic clothing such as acetate, nylon, polyester, rayon, either alone or in blends with cotton, may not be worn while in the flash protection zone. a. Employees must wear protective eye equipment whenever there is a danger from electric arcs, flashes, flying objects, or electrical explosion. b. Employees must wear flame resistant clothing whenever they may be exposed to an arc flash. If used, flash suits and their closure design must permit easy and rapid removal. The entire flash suit, including the window, must have energy absorbing characteristics suitable for arc flash exposure. Use clothing and equipment to maximize worker protection. Clothing and equipment required by the degree of electrical hazard exposure can be worn alone or be integrated with normal apparel. Protective clothing and equipment must cover associated parts of the body and all normal apparel that is not flame resistant, while allowing movement and visibility. > Synthetic materials that can melt next to skin shall not be worn. c. Employees must wear rubber insulating gloves where there is a danger of hand or arm injury from electric shock or arc flash burns due to contact with energized parts. Gloves made from layers of flame resistant material provide the highest level of protection. Leather glove protectors should be worn over voltage rated rubber gloves. d. Dielectric overshoes are required where electrically insulated footwear is used for protection against step and touch potential. An air test shall be performed on electrical workers' rubber insulating gloves before each use.

74 Page 74 Protective equipment of material other than rubber shall provide equal or better electrical and mechanical protection. Live Line (Hot Line) Tools must be manufactured to meet ASTM F18 series as appropriate to the device and material. The insulating tool portion shall be made of fiberglass reinforced plastic (FRP). Only live line tool poles having a manufacturer's certification to withstand at least the following test shall be used: 100 (kilo Volts) kv ac per ft (305 mm) of length for 5 minutes or 75 kv ac per ft (305 mm) for FRP tools. Records shall be maintained for all live line tools to demonstrate satisfactory accomplishment of laboratory and shop test. Wooden tools are not authorized for use. > All wooden tools shall be replaced with FRP tools within 2 years of date of this manual. When using live line tools, workers shall use voltage rated gloves and not place their hands closer than necessary to energized conductors or to the metal parts of the tool. Only tools and equipment intended for live line bare hand work should be used on transmission lines. The tools shall be kept dry and clean and shall be visually inspected before use each day. See Section 05.H for requirements on lineman's personal fall protection equipment. PERSONAL FLOTATION DEVICES Inherently buoyant Type III, Type V work vests, or better USCG approved personal flotation devices (PFDs) shall be provided and properly worn (zipped, tied, latched, etc., in closed fashion) by all persons in the following circumstances: > See 05.J.02; See Figure 5 1. a. On floating pipelines, pontoons, rafts, or stages; b. On structures or equipment extending over or next to water except where guardrails, personal fall protection system, or safety nets are provided for employees; c. Working alone at night where there are drowning hazards, regardless of other safeguards provided;

75 Page 75 d. In skiffs, small boats, or launches, unless in an enclosed cabin or cockpit; or e. Whenever there is a drowning hazard. Automatic Inflatable PFDs Type V or better, USCG approved for Commercial Use, may be worn by workers in lieu of inherently buoyant PFDs (See conditions a e above), provided the following criteria are met: a. PFDs are worn only by workers over 16 years of age and those who weigh 90 lb (40.8 kg) or more; b. An AHA must be performed for this activity; c. PFDs must be inspected, maintained, stowed and used only in accordance with the manufacturer s instructions (currently not intended to be used in areas of heavy construction or maintenance or where hot work (welding, brazing, cutting, soldering, etc.) is to be performed; d. PFDs shall provide a 30 pound minimum buoyancy post deployment; e. USACE employees shall comply with USACE s Auto Inflatable Personal Flotation Device, Standards of Use Procedures, dated 1 July f. The USCG approval for auto inflatable PFD s is contingent upon the PFD being worn, not stowed. All auto inflatable PFDs must be worn at all times drowning hazard exists. All wearable PFDs shall be of a highly visible orange/reddish color. Each PFD shall have at least 31 in 2 (200 cm 2) of retro reflective material attached to its front side and at least 31 in 2 (200 cm 2) on its back side, per USCG requirements (46 CFR Part ). Each PFD shall be equipped with a USCG approved automatically activated light. Lights are not required for PFDs on projects performed exclusively during daylight hours. Before and after each use, the PFD shall be inspected for defects that would alter its strength or buoyancy. Throwable devices (Type IV PFD). a. On USCG inspected vessels, ring buoys are required to have automatic floating electric water lights (46 CFR 160).

76 Revised Safety Plan Ray Roberts Dam Page 76 b. On all other floating plant and shore installations, lights on life rings are required only in locations where adequate general lighting (e.g., floodlights, light stanchions) is not provided. For these plants and installations, at least one life ring, and every third one thereafter, shall have automatic floating electric water lights attached. c. All PFDs shall be requirements. equipped with retro reflective tape in accordance with USCG FIGURE 5 1 PERSONAL FLOTATION DEVICES d. Life rings (rope attachment not required) and ring buoys (rope attachment required) shall be USCG approved; shall have at least 70 ft (21.3 m) of 3/8 in (0.9 cm) of attached solid braid polypropyle ne, or equivalent. Throw bags may be used in addition to life rings or ring buoys. Life rings or ring buoys shall be readily available and shall be provided at the following places: (1) At in least one not less than 20 in (51 cm) on each safety skiff up to 26 ft (7.9 m) length (46 CFR )..;

77 Page 77 (2) At least one (1) 24 in (61 cm) in diameter on all motor boats longer than 26 ft (7.9 m) in length up to 65 ft (19.8 m) in length and for motor boats 65 ft (19.8 m) in length or longer, a minimum 3 life buoys of not less than 24 in (61 cm) and one additional for each increase in length of 100 ft (30.4 m) or fraction thereof; and (3) At least one (1) at intervals of not more than 200 ft (60.9 m) on pipelines, walkways, wharves, piers, bulkheads, lock walls, scaffolds, platforms, and similar structures extending over or immediately next to water, unless the fall distance to the water is more than 45 ft (13.7 m), in which case a life ring shall be used. (The length of line for life rings at these locations shall be evaluated, but the length may not be less than 70 ft (21.3 m).) At navigation locks, an analysis of the benefits versus the hazards of using floating safety blocks (blocks that may be quickly pushed into the water to protect individuals who have fallen in the water from being crushed by vessels) shall be made. a. This analysis shall be documented as an AHA. b. If the use of blocks is found acceptable, consideration shall be given to the size and placement of the blocks, the appropriate means of securing and signing the blocks, etc. When the use of blocks is found unacceptable, alternative safety measures shall be developed. G. HEALTH HAZARD CONTROL PROGRAM (06.A) GENERAL Welders, cutters, and their supervisor shall be trained in the safe operation of their equipment, safe welding/cutting practices, and welding/cutting respiratory and fire protection. > AIHA publication "Welding Health and Safety: A Field Guide for OEHS Professionals" is recommended. All welding equipment shall be inspected before each use to ensure that all required safety devices and ancillary equipment are in place and properly functioning. Defective equipment shall be removed from service, replaced or repaired, and re inspected before again being placed in service. Electrical and pressurized system requirements. a. Welding cylinders and their use and maintenance shall meet the applicable requirements of Section 20.

78 Page 78 b. Arc welding and cutting systems and their use shall meet the applicable requirements of this section. Arc welding and cutting operations shall be shielded by noncombustible or flameproof screens that will protect employees and other persons working in the vicinity from the direct rays of the arc, sparks, molten metal, spatter, and chipped slag. Cable, hoses, and other equipment shall be kept clear of passageways, ladders, and stairways. Welding and cutting of hazardous materials. a. When welding, cutting, or heating on steel pipelines containing natural gas, 49 CFR 192 shall apply. b. Before welding, cutting, or heating is commenced on any surface covered by a preservative coating whose flammability is not known, a test shall be made to determine its flammability. Preservative coatings shall be considered highly flammable when scrapings burn with extreme rapidity. c. Preservative coatings shall be removed a sufficient distance from the area to be heated to ensure any temperature increase of the unstripped metal will not be appreciable; artificial cooling of the metal surrounding the heating area may be used to limit the area to be stripped. d. When welding, cutting, or heating toxic surface coatings (paints, preservatives, surface stripping chemicals, etc.) in enclosed spaces, all surfaces covered with the coatings shall be stripped of such for a distance of at least 4 in (10.1 cm) from the area of heat application or the employees shall be protected by airline respirators. All structural welding performed on critical items, such as scaffolding, shoring, forms, ladders, piling, etc., as well as other critical items as designated by the GDA, shall only be performed by welders certified in accordance with American Welding Society (AWS) standards using qualified and approved welding practices and procedures (AWS certification or approved equivalent organization which trains to AWS standards). Before heat is applied to a drum, container, or hollow structure, a vent or opening shall be provided for the release of any built up pressure generated during the application of heat.

79 Page 79 Employees performing welding, cutting, and heating workshall be protected by PPE appropriate for the hazards that they may encounter and based upon the results of an AHA conducted specifically for the welding, cutting, or heating operation that they will be performing. All required respiratory, eye and face, noise, head, foot, and skin protection equipment shall be selected and used in accordance with Section 5. All welding and cutting equipment and operations shall be in accordance with standards and recommended practices of American National Standards Institute (ANSI)/American Welding Society (AWS) Z49.1. RESPIRATORY PROTECTION All welding, cutting, and heating operations shall be ventilated (natural or mechanical) such that personnel exposures to hazardous concentrations of airborne contaminants are within acceptable limits. Welding, cutting, and heating not involving conditions or materials described in this Section may normally be done without mechanical ventilation or respiratory protective equipment. Either general mechanical or local exhaust ventilation shall be provided whenever welding, cutting, or heating is performed in a confined space. Materials of toxic significance. Welding, cutting, or heating operations that involve or generate any of the substances listed below shall be performed in accordance with the following subparagraphs: Antimony, Arsenic, Barium, Beryllium, Cadmium, Chromium, Chromium (VI), Cobalt, Copper, Lead, Manganese, Mercury, Nickel, Ozone, Selenium, Silver, or Vanadium. a. Whenever these materials are encountered in confined spaces, local mechanical exhaust ventilation and personal respiratory protective equipment shall be used. The use of local mechanical exhaust ventilation systems that permit the re entry of exhaust air back into the work area, or local exhaust which incorporate a system for the filtration and recirculation of exhaust air back into the work area shall not be permitted. b. Whenever these materials, except beryllium and chromium (VI), are encountered in indoor operations, local mechanical exhaust ventilation systems that are sufficient to reduce and maintain personal exposures to within acceptable limits shall be used. The use of local mechanical exhaust systems that permit the re entry of exhaust air back into the work area, or that include a system for the filtration and the recirculation of exhaust air back into the work area are not permitted. When either beryllium or chromium (VI) is encountered

80 Page 80 in indoor operations, approved local mechanical exhaust ventilation systems and personal respiratory protection shall be used. c. Whenever these materials, except beryllium and chromium (VI), are encountered in outdoor operations, and local mechanical exhaust ventilation systems sufficient to reduce and maintain personal exposures to within acceptable limits are not provided, then appropriate respiratory protective equipment shall be used. d. Whenever beryllium and chromium (VI), are encountered in outdoor operations, the need for and type of engineering and work practice controls to be implemented, as well as the need for and type of respiratory protection to be provided shall be based upon the results of an initial worker exposure assessment and exposure determination with regards to these substances. e. Workers may be exposed to hazardous concentrations of chromium (VI) while welding, cutting or performing hot work on stainless steel, high chrome alloys or chrome coated metal, or during the application and removal of chromatecontaining paints and other surface coatings. > See OSHA s Standard for Hexavalent Chromium (Chromium (VI), 29 CFR Welding, cutting, or heating operations that involve or generate fluorine or zinc compounds shall be performed in accordance with the following: a. In confined spaces, local mechanical exhaust ventilation and personal respiratory protection sufficient to maintain exposures to within acceptable limits shall be used. b. In open spaces, sampling shall be performed to determine concentrations of fluorides or zinc compounds and the need for local exhaust ventilation and personal respiratory protection sufficient to maintain exposures to within acceptable limits. Arc and gas cutting. Oxygen cutting using either an iron powder or chemical flux, gasshielded arc cutting, and plasma cutting shall employ local mechanical exhaust ventilation or other means adequate to remove the fumes generated. Other persons exposed to the same atmosphere as welders or cutters shall be protected in the same manner as welders or cutters.

81 Page 81 FIRE PROTECTION Suitable fire extinguishing equipment of sufficient capacity shall be provided in the immediate vicinity of welding or cutting operations and maintained in a state of constant readiness for immediate use. Hot work permits shall be required on Government installations when welding, cutting, or heating operations are performed unless otherwise indicated by the GDA. Before conducting welding or cutting operations, the area shall be surveyed to ensure it is free of the following hazards: a. Proximate combustible materials, b. The presence or possible generation of potentially explosive atmospheres (flammable gases, vapors, liquids, or dusts); and c. The presence or nature of an oxygen enriched atmosphere. Hierarchy of fire control. Objects to be welded, cut, or heated shall be: a. Moved to a location free of dangerous combustibles; b. If the work cannot be moved, all moveable fire hazards in the vicinity shall be taken to a safe place (moved at least 35 ft (10.6 m) horizontally from the welding or cutting area) or the combustible material and construction shall be protected from the heat, sparks, and slag of welding; c. When welding or cutting must be done in a location where combustible or flammable materials are located, inspection and authorization by the GDA shall be required before such operations are begun (the location shall be checked for latent fires by qualified fire watch personnel after the work is completed). When a welding, cutting, or heating operation is such that normal fire prevention precautions are not sufficient, additional qualified fire watch personnel shall be assigned to guard against fire and shall be instructed in anticipated fire hazards and how firefighting equipment is to be used. > See 09.J.03, When welding or cutting is to be done over combustible flooring, the flooring shall be protected by fire resistant shielding, covered with damp sand, or kept wet. Where flooring is wet or damp, personnel operating arc welding or cutting equipment shall be protected from potential shock hazards.

82 Page 82 Noncombustible barriers shall be installed below welding or burning operations in a shaft or raise. Openings or cracks in walls, floors, or ducts within 35 ft (10.6 m) of the site of welding or cutting operations shall be tightly covered to prevent the passage of sparks to adjacent areas. Where welding or cutting is to be done near walls, partitions, ceilings, or roofs of combustible construction, fire resistant guards shall be provided to prevent ignition. Where welding or cutting is to be done on a metal wall, partition, ceiling, or roof, precautions shall be taken to prevent ignition, due to heat conduction or radiation, of combustibles on the other side. Welding or cutting shall not be done on a metal partition, wall, ceiling, or roof with a combustible covering nor on walls or partitions of combustible sandwich type panel construction. Before welding or cutting drums, tanks, or other containers and equipment that have contained hazardous materials, the containers shall be thoroughly cleaned in accordance with NFPA 326 and ANSI/AWS F4.1. Hot tapping or other welding or cutting on a flammable gas or liquid transmission or distribution pipeline shall be performed only by personnel qualified to make hot taps and only with the permission of the GDA. When welding or cutting is to be conducted near a sprinkler head, a wet cloth or equivalent protection shall be used to cover the sprinkler head and then removed at the completion of the welding or cutting operation. When welding or cutting in areas protected by fire detection and suppression systems, precautions shall be taken to avoid accidental initiation of these systems. OXYFUEL GAS WELDING AND CUTTING Oxyfuel gas welding and cutting equipment shall be listed by a nationally recognized testing laboratory. Oxygen cylinders and apparatus. a. Oxygen cylinders and apparatus shall be kept free from oil, grease, and other flammable or explosive substances and shall not be handled with oily hands or gloves.

83 Page 83 b. Oxygen cylinders and apparatus shall not be used interchangeably with any other gas. Hose and hose connections. a. Fuel gas hose and oxygen hose shall be readily distinguishable from each other. b. Oxygen and fuel gas hoses shall not be interchangeable. A single hose having more than one gas passage shall not be used. c. Hose couplings of the type that can be unlocked or disconnected without a rotary motion are prohibited. d. Hose that has been subject to flashback or that shows evidence of severe wear or damage shall be tested to twice the normal pressure to which it is subjected, and in no case less than 300 psi ( kpa) gauge. Damaged hose and hose connectors, or hose and hose connectors in questionable condition, shall not be used. e. When parallel runs of oxygen and fuel gas hose are taped together, not more than 4 out of every 12 in (10 out of every 30.4 cm) shall be covered by tape. f. Boxes used for the storage of gas hose shall be ventilated. g. Hose connections shall be clamped or otherwise securely fastened in a manner that will withstand, without leakage, twice the pressure to which they are normally subjected in service, but not less than 300 psi (2,068 kpa) gauge. Torches. a. Torches shall be inspected before each use for leaking shutoff valves, hose couplings, and tip connections. Defective torches shall not be used. b. Hoses shall be purged individually before lighting the torch for the first time each day. Hoses shall not be purged into confined spaces or near ignition sources. c. Clogged torch tip openings shall be cleaned with suitable cleaning wires, drills, or other devices designed for such purposes. d. Torches shall be lighted by friction lighters or other approved devices, not by matches or from hot work.

84 Page 84 Torch valves shall be closed and the gas supply shut off whenever work is suspended. The torch and hose shall be removed from confined spaces whenever work is suspended. Protective equipment a. Oxyfuel gas, and other oxygen fuel gas welding and cutting systems using cylinder regulator hose torch shall be equipped with both a reverse flow check valve and a flash arrestor, in each hose, at the torch handle or at the regulator. b. When oxygen fuel gas systems are manifolded together the provisions of NFPA 51 shall apply. Connection of multiple sets of oxyacetylene hoses to a single regulator on a single set of oxyacetylene tanks may only be accomplished by installing a commercially available fitting approved by Compressed Gas Association (CGA) standards and listed by a nationally recognized testing laboratory. The fitting shall be installed on the output side of the regulator and shall have a built in shut off valve and reverse flow check valve on each branch. Acetylene regulators shall not be adjusted to permit a discharge greater than 15 psi (103.4 kpa) gauge. ARC WELDING AND CUTTING Electric welding apparatus shall be installed, maintained, and operated in accordance with the NEC. Manual electrode holders. a. Only manual electrode holders specifically designed for arc welding and cutting of a capacity capable of safely handling the maximum rated current required by the electrodes shall be used. b. All current carrying parts passing through the portion of the holder that is gripped by the welder or cutter, and the outer surfaces of the jaws of the holder, shall be fully insulated against the maximum voltage encountered to ground.

85 Page 85 Welding cables and connectors. a. Cables shall be completely insulated, flexible, capable of handling the maximum current requirements of the work in progress, and in good repair. Cables in need of repair shall not be used. b. Welding cables shall be inspected for wear or damage before each use. Cables with damaged insulation or connectors shall be replaced or repaired to achieve the same mechanical strength, insulating quality, electrical conductivity, and water tightness of the original cable. Cables containing splices or repaired insulation within a minimum distance of 10 ft (3 m) from the end of the cable to which the electrode holder is connected shall not be used. c. Where it becomes necessary to connect or splice lengths of cable together, insulated connectors of a capacity at least equivalent to that of the cable shall be used. When connections are affected by cable lugs, they shall be securely fastened together to give good electrical contact and the exposed metal parts of the lugs shall be completely insulated. The joining of lengths of cable shall be accomplished by methods specifically intended for that purpose and connection methods shall provide insulation adequate for the service conditions. The frames of arc welding and cutting machines shall be grounded either by a third wire in the cable connecting the circuit conductor or by a separate wire that is grounded at the source of the current. Neither terminal of the welding generator shall be bonded to the frame of the welder. Pipelines containing gases or flammable liquids or conduits carrying electrical conductors shall not be used for a ground return circuit. Circuits from welding machines used for other than welding tools shall be grounded. Welding supply cables shall not be placed near power supply cables or other hightension wires. Welding leads shall not be permitted to contact metal parts supporting suspended scaffolds. Switching equipment for shutting down the welding machine shall be provided on or near the welding machine. Equipment shall be shut down when the leads are unattended.

86 Page 86 Arc welding and cutting operations shall be shielded by noncombustible or flameproof screens to protect employees and other visitors from the direct rays of the arc. Coiled welding cable shall be spread out before use. GAS METAL ARC WELDING Chlorinated solvents shall be kept at least 200 ft (61 m) away from the exposed arc, unless shielded. Surfaces prepared with chlorinated solvents shall be dry before welding is permitted on such surfaces. Persons in the area not protected from the arc by screening shall be protected by filter lenses. When two or more welders are exposed to each other's arc, filter lens goggles shall be worn under welding helmets. Hand shields shall be used to protect the welders against flashes and radiant energy when either the helmet is lifted or the shield is removed. Welders and other persons who are exposed to radiation shall be protected so that the skin is covered to prevent burns and other damage by ultraviolet rays. Welding helmets and hand shields shall be free of leaks, cracks, openings, and highly reflective surfaces. When gas metal arc welding is performed on stainless steel, chrome alloy steel, or chrome coated metal, personnel shall be protected against dangerous concentrations of nitrogen dioxide and other air contaminants such as chromium (VI), by means of an approved local exhaust ventilation system that is capable of reducing and maintaining personal exposures to within permissible limits, or by means of other effective work practice and engineering controls such as the use of an argon rich (> 75% argon) shielding gas for use in gas metal arc welding (GMAW) or flux cored arc welding (FCAW) operations. Wherever engineering and work practice controls are not sufficient to reduce employee exposures below permissible limits, the employer shall use them to reduce employee exposures to the lowest levels achievable, and shall supplement such methods by the use of respiratory protection that complies with the requirements of this Section and Section 05. H. HAZARD COMMUNICATION PROGRAM (06.B.01) The HHCP will work in conjunction with the Hazard Communication Program. (06.B.01) The evaluation of all operations, materials and equipment will be performed to determine if they show the presence of hazardous or toxic agents that could be released into the work environment.

87 Page 87 An Activity Hazard Analysis shall be used to identify all substance, agents and environments that present a hazard. The Activity Hazard Analysis will recommend hazard control measures usually by engineering or administrative measures, but if these measures are not adequate, the appropriate personnel protective equipment will be utilized. This analysis will serve as certification that the hazard assessment has been made of the workplace. If any hazardous substance is encountered and it cannot be determined if an appropriate assessment can be made, then a qualified industrial hygienist will be employed to formulate a hazard control program. This program to be accepted by Government Designated Authority. Hazard communication program. Provide the location of MSDS, records of Penna employee training, and inventory of hazardous materials (including approximate quantities and a site map) that will be brought onto Government project by Penna and subcontractor. A Hazard Communication Program will be implemented in accordance with 29 Code of Federal Regulation (CFR) or The program will address the following items: Training Personnel. Demonstrate the safety and health effects from exposure Make sure proper labeling is in place to denote contents of Containers. Keep a tracking log of all current inventories of chemicals, agents, and substance. Adjust the inventory as items are utilized so as to keep up with amount of chemical on hand at any given time. (Gallons, Barrels, liter, pounds). Advise the employees of the information contained in the MSDS Sheets so they will be informed as to the chemical they are being exposed. Copy of all MSDS sheets will be located at the project trailer or Superintendent will make them accessible for the employee. The government designated authority will be given copies of all MSDS S and also a copy of the inventory log, along with sitemap attached. Employees will be given the proper PPE equipment that is deemed appropriate to handle the hazardous substances as further discussed in Section 6. (06.A 04d) of EM

88 Page 88 This plan is to be revised immediately if it fails to meet the requirements set forth or if more stringent controls are to be implemented. I. PROCESS SAFETY MANAGEMENT PLAN (06.B.04) A process that involves highly hazardous chemicals. These chemicals are at or above the threshold quantities listed in Appendix A. Shown in 29 CFR or 29 CFR A process that involves a flammable liquid or gas on site in one location in a quantity of 10,000 lb (4,535.9 kg) or more as defined in 29 CFR (c), except: Hydrocarbon fuels used solely for workplace consumption as a fuel if such fuels are not part of a process containing another highly hazardous chemical covered by the standards cited above; or Flammable liquids stored in atmospheric tanks or transferred that are kept below their normal boiling point without benefit of chilling or refrigeration. J. LEAD ABATEMENT PLAN (06.B.05 & SPECIFICATIONS) a. General. All projects will be evaluated for the potential to contact asbestoscontaining material (ACM) and lead based paint (LBP). (1) If the evaluation shows the potential for activities to generate unacceptable occupational exposure to LBP, a written lead compliance plan shall be written. The lead compliance plan shall be in accordance with 29 CFR and 29 CRF (2) If the evaluation shows the potential for activities to disturb ACM, an asbestos abatement plan shall be developed. The asbestos abatement plan shall be in accordance with 29 CFR ; 29 CFR ; and 40 CFR 61, Subpart M. (3) These plan(s) shall be developed as an appendix to the contract APP or, for USACE operations, the Project Safety Plan. The written plan(s) shall be submitted for acceptance by the GDA before beginning work. b. Lead Compliance Plan. A lead compliance plan shall describe the procedures to be followed to protect employees from lead hazards while performing lead hazard control activities. The Plan shall address the following: (1) A description of each work activity in which lead is emitted, to include equipment and materials used, controls in place, crew size, job

89 Page 89 responsibilities, operating procedures, and maintenance practices, work activity locations and lead containing components keyed to the project drawings; (2) Description of means to be used to achieve exposure compliance, including any engineering controls; (3) Employee exposure assessment procedures to monitor and document employee lead exposure. Exposure monitoring shall include two types: (a) Initial determination (may be omitted if there is sufficient objective/historical data showing action level compliance according to the requirements); and (b) Continued exposure monitoring required as a result of initial exposure determinations. (4) Protective clothing, housekeeping procedures to prevent spread of lead contamination both in and beyond the lead hazard control area, and hygiene facilities and practices to prevent employees from inadvertent ingestion of lead; (5) Administrative controls to limit employee exposure to lead, including employee rotation schedule to be employed, if engineering controls or PPE fail to eliminate exposures exceeding the PEL; (6) Medical surveillance procedures to monitor employee exposures and ensure fitness for wearing respiratory protection; (7) Competent person and employee training required; (8) Detailed sketches identifying lead hazard control areas, including decontamination areas and facilities, critical barriers, and physical and air distribution boundaries; (9) Perimeter or other area air monitoring outside or adjacent to the regulated area; (10) Security required for each lead hazard control area; and (11) Waste generation, characterization, transportation, and disposal (including recordkeeping).

90 K. ASBESTOS ABATEMENT PLAN (06.B.05 & SPECIFICATIONS) Not Applicable. L. RADIATION SAFETY PROGRAM (06.E.03.A) Not Applicable. M. ABRASIVE BLASTING (06.H.01) Not Applicable. N. HEAT/COLD STRESS MONITORING PLAN (06.I.02) Heat Stress Prevention Plan Revised Safety Plan Ray Roberts Dam Page 90 Scope: This Plan covers employees who are exposed to heat or hot conditions at or above the threshold levels for work areas and activities identified in the heat stress hazard assessment. Policy: This organization is committed to protecting employees from the hazards of hot conditions and to preventing heat related illnesses at the workplace. We will identify, evaluate, and control potential exposure of our employees to extreme temperature, humidity, and other heat related factors. PLAN ADMINISTRATION Plan Administrator. The Plan Administrator is responsible for implementing the Heat Stress Prevention Program, monitoring work area heat conditions and worker physiological parameters, and for ensuring that employees are trained to recognize the signs and symptoms of heat stress illnesses or injury and what to do if these occur. The Administrator may designate and authorize other personnel to implement specific components of the Plan. Supervisors. Supervisors are responsible for encouraging employees to frequently consume water or other acceptable beverages to ensure hydration. Employees. Employees are responsible for monitoring their own personal factors for heat related illness including consumption of water or other acceptable beverages to ensure hydration.

91 Page 91 Plan Review and Update This Plan will be periodically reviewed and updated when: New activities or equipment that creates heat stress are introduced into the workplace. Evaluations of heat stress hazards, injuries, and illnesses demonstrate that the current Plan is outdated or not effective. Regulatory or applicable national consensus standards change that require this Plan to be updated. DEFINITIONS Acclimatization or acclimate is the physiological (i.e., physical, mechanical, and biochemical) change that allows the human body to adapt or get used to the effects of a new physical environment or climate. After a period of acclimatization, the same physical activity will produce fewer cardiovascular demands. The worker will sweat more efficiently, causing better evaporative cooling, and thus will more easily be able to maintain normal body temperatures. Calorie is the amount of heat required to raise 1 gram of water 1 degrees Celcius (C) (based on a standard temperature of 16.5 to 17.5 degrees C). Conduction is the transfer of heat between materials that contact each other. Heat passes from the warmer material to the cooler material. For example, a worker's skin can transfer heat to a contacting surface if that surface is cooler, and vice versa. Convection is the transfer of heat in a moving fluid. Air flowing past the body can cool the body if the air temperature is cool. On the other hand, air that exceeds 35 degrees C (95 degrees Fahrenheit (F)) can increase the heat load on the body. Dry bulb (DB) temperature is the measurement of the heat content of freely exposed air measured by a thermal sensor that is shielded from direct radiant energy sources. Evaporative cooling takes place when sweat evaporates from the skin. High humidity reduces the rate of evaporation and thus reduces the effectiveness of the body's primary cooling mechanism. Globe temperature is the temperature inside a blackened, hollow, thin copper globe. Heat is a measure of energy that is transferred by a difference in temperature. Metabolic heat is a by product of the body's activity.

92 Page 92 Natural wet bulb (NWB) temperature is measured by exposing a wet sensor, such as a wet cotton wick fitted over the bulb of a thermometer, to the effects of evaporation and convection. The term "natural" refers to the movement of air around the sensor. Radiation is the transfer of heat energy through space. A worker whose body temperature is greater than the temperature of the surrounding surfaces radiates heat to these surfaces. Hot surfaces and infrared light sources radiate heat that can increase the body's heat load. Heat Related Illnesses Illness as defined by OSHA is generally not instantaneous and occurs some time (hours or days) after the initial exposure to an occupational hazard. For example, an instantaneous reaction such as a burn after touching a hot surface is considered an injury; whereas a delayed reaction to a hot environment such as heat exhaustion that occurs hours after the initial exposure is considered an illness. Heat collapse is a condition where the brain does not receive enough oxygen because blood pools in the extremities, resulting in a loss of consciousness (fainting or syncope). This reaction is similar to that of heat exhaustion and does not affect the body's heat balance. However, the onset of heat collapse is rapid and unpredictable. Heat syncope is a fainting episode or dizziness that usually occurs with prolonged standing or sudden rising from a sitting or lying position. Factors that may contribute to heat syncope include dehydration and lack of acclimatization. Heat cramps are usually caused by performing hard physical labor in a hot environment. These cramps have been attributed to an electrolyte imbalance caused by sweating. Cramps can be caused by both too much and too little salt. Cramps appear to be caused by the lack of water replenishment. Because sweat is a hypotonic solution (±0.3% sodium chloride), excess salt can build up in the body if the water lost through sweating is not replaced. Thirst cannot be relied on as a guide to the need for water; instead, water must be taken every 15 to 20 minutes in hot environments. Under extreme conditions, such as working for 6 to 8 hours in heavy protective gear, a loss of sodium may occur. Recent studies have shown that drinking commercially available carbohydrate electrolyte replacement liquids is effective in minimizing physiological disturbances during recovery. Heat exhaustion is a condition with symptoms of headache, nausea, vertigo, weakness, thirst, and giddiness. Fainting associated with heat exhaustion can be dangerous because the victim may be operating machinery or controlling an operation that should not be left unattended; moreover, the victim may be injured

93 Page 93 when he or she faints. Also, the signs and symptoms seen in heat exhaustion are similar to those of heat stroke, a medical emergency. Heat fatigue is a temporary state of discomfort and mental or psychological strain arising from prolonged heat exposure. It is generally caused by fluid loss. Workers unaccustomed to the heat are particularly susceptible and can suffer, to varying degrees, a decline in task performance, coordination, alertness, and vigilance. There is no treatment for heat fatigue except to remove the heat stress before a more serious heat related condition develops. The severity of transient heat fatigue will be lessened by a period of gradual adjustment to the hot environment (heat acclimatization). Heat rash is "prickly" heat manifested as red papules (i.e., small, inflammatory, irritated spots on skin) and usually appears in areas where the clothing is restrictive. It is the most common problem in hot work environments. As sweating increases, these papules give rise to a prickling sensation. Prickly heat occurs on skin that is persistently wetted by unevaporated sweat, and heat rash papules may become infected if they are not treated. In most cases, heat rashes will disappear when the affected individual returns to a cool environment. Heat stroke is a condition when the body's system of temperature regulation fails and body temperature rises to critical levels. This condition is caused by a combination of highly variable factors, and its occurrence is difficult to predict. Heat stroke is a medical emergency. The primary signs and symptoms of heat stroke are confusion, irrational behavior, loss of consciousness, convulsions, a lack of sweating (usually), hot and dry skin, and an abnormally high body temperature (e.g., a rectal temperature of 41 degrees C (105.8 degrees F)). If body temperature is too high, it causes death. The elevated metabolic temperatures caused by a combination of work load and environmental heat load, both of which contribute to heat stroke, are also highly variable and difficult to predict. HAZARD ASSESSMENT The Administrator or designee will conduct an initial inspection and hazard assessment of all work areas and environments where hot conditions are anticipated or may occur. He or she will periodically conduct follow up inspections to ensure compliance with this Plan and to evaluate the effectiveness of heat stress control measures. During the assessment the inspector will: Determine building and facility operating characteristics that may cause, contribute to, or alleviate hot conditions.

94 Page 94 Determine whether engineering and administrative controls are functioning properly. Verify information obtained from employee interviews. Perform temperature measurements and make other determinations to identify potential sources of heat stress. Investigators will discuss any operations that have the potential to cause heat stress with engineers or other knowledgeable personnel. A walk around inspection will cover all affected areas. Heat sources such as furnaces, ovens, and boilers, and relative heat load per employee will be noted. Heat Stress Factors The following workplace factors will be considered in the assessment for heat stress: Air temperature Radiant heat sources Conductive heat sources Humidity Direct physical contact with hot objects Workload activity and duration Semipermeable or impermeable protective clothing The following worker heat sensitivity factors will also be considered in evaluating the potential for heat stress: Age Weight Degree of physical fitness Degree of acclimatization Metabolism Use of alcohol or drugs Medical conditions such as hypertension Prior heat injury (predisposes an individual to additional injury) Use the attached Heat Stress Assessment Form to conduct assessments. HEAT STRESS MONITORING Every worker who works in extraordinary conditions that increase the risk of heat stress will be personally monitored. Extraordinary conditions include wearing semipermeable or impermeable clothing when the temperature exceeds 21 degrees

95 Page 95 C (69.8 degrees F), and working at extreme metabolic loads greater than 500 kilocalories/hour. Personal heat stress monitoring techniques include physiological tests such as: Heart rate Recovery heart rate Oral temperature Extent of body water loss Monitoring Personal Heat Stress Personal monitoring of physiological stress will be conducted to alert employees and their supervisors to potential heat stress illness. Physical signs and symptoms of heat stress will be discussed with employees every Safety Meeting and reviewed as necessary. Employees will be trained and directed to monitor each other's actions, speech, and appearance for signs and symptoms of heat related illnesses. Heart rate. To check the heart rate, count the radial pulse for 30 seconds at the beginning of the rest period. If the heart rate exceeds 110 beats per minute, shorten the next work period by one third and maintain the same rest period. Recovery heart rate. The recovery heart rate can be checked by comparing the pulse rate (i.e., number of beats in 30 seconds x 2) taken at the beginning of the rest period (P1) with the pulse rate taken 3 minutes (P3) after the beginning of the rest period. The two pulse rates can be interpreted using the Heart Rate Recovery Table in this section. Oral temperature. Oral temperature can be checked with a clinical thermometer after work but before the employee drinks water. If the oral temperature taken under the tongue exceeds 37.6 degrees C (100 degrees F), shorten the next work cycle by one third. Body water loss. Body water loss can be measured by weighing the worker on a scale at the beginning and end of each work day. The worker's weight loss should not exceed 1.5% of total body weight in a work day. If a weight loss exceeding this amount is observed, fluid intake should be increased.

96 Page 96 Heart Rate Recovery Table Heart rate recovery pattern P3 Difference between P1 and P3 Satisfactory recovery High recovery (Conditions may require further study) No recovery (May indicate too much stress) Monitoring Hot Conditions Greater than 90 None Greater than 10 Portable heat stress meters will be used to measure heat conditions. These instruments will calculate both the indoor and outdoor Wet Bulb Globe Temperature (WBGT) index according to established American Conference of Industrial Hygienists (ACGIH) Threshold Limit Value (TLV) equations. The WBGT for continuous all day or several hour exposures will be averaged over a 60 minute period. Intermittent exposures are averaged over a 120 minute period. With this information and information on the type of work being performed, heat stress meters can determine how long a person can safely work or remain in a particular hot environment. HEAT STRESS PREVENTION PROGRAM This Heat Stress Prevention Program describes controls and work practices to protect employees from heat stress while working in hot conditions. Program Implementation Criteria The Administrator or designee will implement the Heat Stress Prevention Program when the action levels for hot conditions in the Personal Monitoring Table and/or the WBGT are exceeded. Heat Stress Engineering Controls The following engineering controls will be implemented before and in combination with work practices. Cool Room Cool rooms will be used as a recovery area near hot jobs.

97 Page 97 Heat Stress Prevention Work Practices Work practices will be implemented to reduce the risk of elevating an employee's core body temperature. Heat stress prevention practices that may be implemented individually or in combination include: Employee work and rest intervals. Continual personal monitoring of physiological signs of heat stress. Provide cool liquids. Establish and implement acclimatization schedules. Use warm weather cooling garments. Reduce the physical demands of work, e.g., excessive lifting or digging with heavy objects. Provide recovery areas such as air conditioned enclosures and rooms. Use shifts such as early morning, cool part of the day, or night work. Use intermittent rest periods with water breaks. Use relief workers. Use worker pacing. Assign extra workers and limit worker occupancy, or the number of workers present, especially in confined or enclosed spaces. Schedule work in hot conditions for the cooler part of the day. Schedule routine maintenance and repair work in hot areas for the cooler seasons of the year. Employee Work/Rest Intervals The Administrator or designee will determine the work/rest intervals and communicate them to employees by notifying all supervisors. Work/rest intervals are adjusted throughout the work shift as needed and communicated to each employee at the conclusion of an applicable rest period, prior to reentry into a work area. Guidelines for work/rest schedules for this site are provided in the Work/Rest Schedule for Heat Stress Table. Work/Rest Schedule for Heat Stress Table Work Area Air or Adjusted Temperature Range PPE Level Work Period (minutes) 90 to to and above Rest Period (minutes)

98 Page 98 Fluid Replacement Since dehydration is a primary cause of heat illness, employees on this site follow the regimen for liquid consumption detailed in the table Liquid Replacement Regimen. Liquid Replacement Regimen Work Area Air or Adjusted Temperature Range Work Period Between Drinks Minimum Quantity (Ounces (oz)) Liquid Type 85 to 90 As needed 8oz per hour Water 91 to minutes 16 oz Water 100 and above 20 minutes 8 oz Water Cool (50 degrees 60 degrees F) water or other cool liquid except alcoholic beverages will be made available to workers to encourage them to drink small amounts frequently. One cup (8 oz) every 20 minutes is recommended. Ample supplies of liquids will be placed close to the work area. Acclimatization Employees who are newly hired, have not worked under comparable hot conditions during the previous Number days, or have been away from work areas covered under this Plan for the same period of time will follow the acclimatization procedures identified in the Worker Acclimatization Procedures in this section. To prevent heat collapse, the worker will gradually become acclimatized to the hot conditions. Daily exposure time. The acclimatization program will expose employees to work in hot conditions for progressively longer periods. For workers who have had previous experience in jobs where heat levels are high enough to produce heat stress, the exposure time per day progression will be: 50% exposure on day one 60% on day two 80% on day three 100% on day four

99 Page 99 For new workers who will be similarly exposed, the exposure time per day progression will be: 20% on day one 20% increase in exposure each additional day Personal Protective Equipment The Administrator or designee will determine the types of PPE that may be used to minimize heat stress after engineering controls and work practices have been implemented and workers are still exposed to heat stress hazards. Such PPE will be provided as needed and where feasible and practical. Reflective Clothing Reflective clothing varies from aprons and jackets to suits that completely enclose the worker from neck to feet and can stop the skin from absorbing radiant heat. Because most reflective clothing does not allow air exchange through the garment, the reduction of radiant heat must more than offset the corresponding loss in evaporative cooling. For this reason, reflective clothing should be worn as loosely as possible. In situations where radiant heat is high, auxiliary cooling systems can be used under the reflective clothing. Water Cooled Garments Commercially available ice vests may accommodate as many as 72 ice packets which are usually filled with water. Carbon dioxide (dry ice) may also be used as a coolant. The cooling offered by ice packets lasts 2 to 4 hours at moderate to heavy heat loads, and frequent replacement will be necessary. Water cooled garments range from a hood, which cools only the head, to vests and "long johns," which offer partial or complete body cooling. Wetted Clothing Wetted clothing is effective when reflective or other impermeable protective clothing is worn. The clothing may be wetted terry cloth coveralls or wetted two piece, wholebody cotton suits. This approach is effective under conditions of high temperature and low humidity where evaporation from the wetted garment is not restricted. EMERGENCY RESPONSE The Administrator or designee will implement the following emergency response procedures for the type of heat stress indicated.

100 Page 100 Heat Stroke If a worker shows signs of possible heat stroke, professional medical treatment will be obtained immediately. The supervisor or co workers will take the following steps to treat a worker with heat stroke: 1. Call 911 and notify the supervisor. 2. Move the sick worker to a cool, shaded area. 3. Cool the worker using methods such as soaking his or her clothes with water, spraying, sponging, or showering him or her with water, and fanning his or her body. 4. The worker should be placed in a shady area and the outer clothing should be removed. The worker's skin should be wetted and air movement around the worker should be increased to improve evaporative cooling until professional methods of cooling are initiated and the seriousness of the condition can be assessed. Fluids should be replaced as soon as possible. The medical outcome of an episode of heat stroke depends on the victim's physical fitness and the timing and effectiveness of first aid treatment. Regardless of the worker's protests, no employee suspected of being ill from heat stroke should be sent home or left unattended unless a physician has specifically approved such an order. Heat Exhaustion Heat exhaustion responds readily to prompt treatment. A worker suffering from heat exhaustion should: Rest in a cool, shaded, or air conditioned area. Drink plenty of water or other cool, nonalcoholic beverages. Take a cool shower, bath, or sponge bath. Workers suffering from heat exhaustion will be removed from the hot environment and given fluid replacement. They will also be encouraged to get adequate rest. Heat Syncope (Fainting) Workers who exhibit signs of heat syncope will be instructed by a supervisor or coworkers to: Sit or lie down in a cool place when they begin to feel symptoms. Slowly drink water, clear juice, or a sports beverage.

101 Page 101 Heat Cramps Workers with heat cramps should: Stop all activity, and sit in a cool place. Drink clear juice or a sports beverage. Not return to strenuous work for a few hours after the cramps subside, because further exertion may lead to heat exhaustion or heat stroke. Seek medical attention if the worker has heart problems, the worker is on a low sodium diet, or the cramps do not subside within one hour. Heat Rash Workers experiencing heat rash will be treated according to the following procedures: Directed to work in a cooler, less humid environment when possible. Keep the affected area dry. Use dusting powder to help increase comfort. TRAINING All employees who are exposed or potentially exposed to heat stress will receive training regarding heat stress related injuries and illnesses and prevention measures at the time of assignment to work activities that involve hot conditions. The following topics will be covered during safety training for heat stress: Knowledge of the hazards of heat stress, including environmental factors that might contribute to the risk of heat related illness (temperature, humidity, radiant heat, air movement, conductive heat sources, workload activity and duration, and personal protective equipment). Recognition of predisposing factors, danger signs, and symptoms (e.g., age, degree acclimatization, medical conditions, consuming alcohol, caffeine use, nicotine use, and use of medications that affect the body's response to heat). The importance of frequent drinking of small quantities of water. Awareness of first aid procedures for heat stroke and other heat stressrelated illnesses. The procedure for reporting signs and symptoms of heat related illness in themselves and co workers. Employee responsibilities in avoiding heat stress. The importance of acclimatization. Dangers of using drugs, including therapeutic ones, and alcohol in hot work environments.

102 Page 102 Use of protective clothing and equipment, including the importance of removing heat retaining PPE, such as non breathable chemical resistant clothing, during breaks. First aid and other emergency response procedures [Distribute OSHA's Heat Stress Card when training employees. The card is available in English and Spanish.] Refresher Training Personnel covered by this Plan will receive refresher heat stress training at least once per year, and whenever there is a change in work assignment or hot conditions, or when a new heat source is introduced to a work area. RECORDKEEPING Heat stress related illnesses that are relieved by first aid and do not require additional medical treatment will not be recorded in injury and illness records. Heat stress related illnesses that require medical treatment beyond first aid will be recorded as an illness or injury and illness recordkeeping forms. For example, the administration of fluids by intravenous injections is recordable as medical treatment, and more serious cases of heat disorders involving such injections will be entered into the injury and illness records. In addition, any diagnosis by a physician or other licensed healthcare professional of heat syncope (fainting due to heat) will be recorded. O. CRYSTALLINE SILICA MONITORING PLAN (ASSESSMENT) (06.M) 06.M.01 Occupational Standards a. Employee airborne exposure to crystalline silica shall not exceed the 8 hour TWA limit as specified by the ACGIH in their Threshold Limit Values and Biological Exposure Indices or by OSHA, whichever is more stringent. Table 6 3 provides U.S. guidelines and limits for occupational exposure to crystalline silica established by NIOSH, OSHA, MSHA, and ACGIH as of the date of this manual. b. Mandatory requirements (1) Employee exposure shall be eliminated through the implementation of feasible engineering controls.

103 Page 103 (2) After all such controls are implemented and they do not control to the OEL, each employer must rotate its employees to the extent possible in order to reduce exposure. (3) When all engineering or administrative controls have been implemented, and the level of respirable silica still exceeds OEL, an employer relies on a respirator program pursuant to the mandatory requirements of Section 5 E. and 29 CFR Monitoring a. Each employer who has a place of employment in which silica is occupationally produced, reacted, released, transported, stored, handled, or used shall inspect each workplace and work operation to determine if any employee may be exposed to silica at or above the OEL. This evaluation shall be documented in the AHA for the job/task to be completed. b. Air monitoring and analysis. Sampling and analytical methods shall be in accordance with those specified in Section 6A. P. NIGHT OPERATIONS LIGHTING OLAN (07.A.08) Not Applicable. Q. FIRE PREVENTION PLAN (09.A) 1. The major fire hazards for this project are from cutting and burning if required to install rebar or metals during construction. 2. Prior to any cutting or burning: a. All equipment (i.e. Torches, gauges, etc.) to be utilized in the cutting and burning operation must be displayed for the inspectors view along with the appropriate fire extinguishers. b. Employee smoking will be in designated areas only. c. IN THE EVENT OF A DISASTER OR FIRE: i. First hand responders call 911 and notify the operator of the situation and tell the operator of the location. Immediately the first responder will utilize the available firefighting measure available on try to extinguish the fires. While others with assigned duties will warn others of the danger and

104 Page 104 evacuate if necessary and remove any other sources of a flammable nature.(i.e. Vehicles, fuel tanks, etc.) d. Portable generators i. While generators are in use a portable fire extinguisher will be ready and available class B. ii. Generator will be equipped with GFI or will be grounded in accordance with Section 11.C. EM e. Portable gas/diesel container (5 gal.) i. Containers shall meet requirements listed in EM , 09.B.15 ii. Even though these containers have flash strainers inside care should be made when pouring to avoid spills. f. Motorized vehicles i. All vehicles will be equipped with class B fire extinguishers ii. No smoking in vehicles while in work zone or within 50 ft. of flammable materials or inside hangar. R. WILD LAND FIRE MANAGEMENT PLAN (09.K) This procedure will be utilized if the need arises for a system to be shut down and an electrical tie is to be made. Pennas involved in working in the vicinity of the tie in will be alerted, a coordination meeting will be conducted to discuss the procedures and the responsibilities of each party involved. Steps will be implemented that places appropriate responsibility of installing and removing of lockout and tag out devices. A system will be implemented to test the system to insure that the lockout devices are performing as required and in accordance with EM and all applicable Electrical codes for this facility. No transfer of responsibility without proper written transfer of authority to a qualified individual will be allowed. Emergencies that may occur will be discussed in the Hazard Analysis and the procedures to be implemented in the event of an emergency. These lockout and tag out devices will be checked on a daily basis and anyone caught tampering with or removing without proper authority to do so is subject to immediate termination. S. HAZARDOUS ENERGY CONTROL PLAN (12.A.01) Not Applicable.

105 Page 105 T. CRITICAL LIFT PLAN (16.H) Not Applicable. U. CONTINGENCY PLAN FOR SEVERE WEATHER (19.A.03) Not Applicable. V. FLOAT PLAN (19.F.04) Not Applicable. W. SITE SPECIFIC FALL PROTECTION & PREVENTION PLAN (21.C) FALL HAZARD PROTECTION AND PREVENTION PROGRAM Establish a fall protection and prevention program, for the protection of all employees exposed to fall hazards. Within the program include company policy, identify responsibilities, education and training requirements, fall hazard identification, prevention and control measures, inspection, storage, care and maintenance of fall protection equipment and rescue and evacuation procedures. Training Institute a fall protection training program. As part of the Fall Hazard Protection and Prevention Program, provide training for each employee who might be exposed to fall hazards. Provide training by a competent person for fall protection in accordance with USACE EM , section 21.B.01. Fall Protection Equipment and Systems Enforce use of the fall protection equipment and systems designated for each specific work activity in the Fall Protection and Prevention Plan and/or AHA at all times when an employee is exposed to a fall hazard. Protect employees from fall hazards as specified in EM , section 21. In addition to the required fall protection systems, safety skiff, personal floatation devices, life rings etc., are required when working above or next to water in accordance with USACE EM , paragraphs 05.H. and 05.I. Personal fall arrest systems are required when working from an articulating or extendible boom, swing stages, or suspended platform. In addition, personal fall arrest systems are required when operating other equipment such as scissor lifts if the work platform is capable of being positioned outside the wheelbase. The need for tying off in such equipment is to prevent ejection of the employee from the equipment during raising, lowering, or travel. Fall protection must comply with 29 CFR , Subpart M, USACE EM and ASSE/SAFE A10.32.

106 Page 106 Personal Fall Arrest Equipment Personal fall arrest equipment, systems, subsystems, and components shall meet ASSE/SAFE Z Only a full body harness with a shock absorbing lanyard or selfretracting lanyard is an acceptable personal fall arrest body support device. Body belts may only be used as a positioning device system (for uses such as steel reinforcing assembly and in addition to an approved fall arrest system). Harnesses shall have a fall arrest attachment affixed to the body support (usually a Dorsal D ring) and specifically designated for attachment to the rest of the system. Only locking snap hooks and carabiners shall be used. Webbing, straps, and ropes shall be made of synthetic fiber. The maximum free fall distance when using fall arrest equipment shall not exceed 1.8 m (6 feet). The total fall distance and any swinging of the worker (pendulum like motion) that can occur during a fall shall always be taken into consideration when attaching a person to a fall arrest system. Rescue and Evacuation Procedures When personal fall arrest systems are used, Penna must ensure that the mishap victim can self rescue or can be rescued promptly should a fall occur. Prepare a Rescue and Evacuation Plan and include a detailed discussion of the following: methods of rescue; methods of self rescue; equipment used; training requirement; specialized training for the rescuers; procedures for requesting rescue and medical assistance; and transportation routes to a medical facility. Include the Rescue and Evacuation Plan within the Activity Hazard Analysis (AHA) for the phase of work, in the Fall Protection and Prevention (FP&P) Plan, and the Accident Prevention Plan (APP). The fall protection threshold height requirement is 6 ft (1.8 m) for ALL WORK covered by this Plan, unless specified differently below, whether performed by Government or Penna work forces, to include steel erection activities, systems engineered activities (prefabricated) metal buildings, residential (wood) construction and scaffolding work. > NOTE: Floating plant and vessels are excluded from these requirements except where specifically cited in Sections 19.D and 19.E. Workers exposed to fall hazards shall be protected from falling to a lower level by the use of standard guardrail as defined in 21.E.01.b, work platforms, temporary floors, safety nets, engineered fall protection systems, personal fall arrest systems, or the equivalent, in the following situations: a. On access ways (excluding ladders), work platforms, or walking/working surfaces from which workers may fall 6 ft (1.8 m) or more;

107 Page 107 b. For access ways or work platforms over water, machinery, or dangerous operations; c. When installing or removing sheet piles, h piles, cofferdams, or other interlocking materials from which workers may fall 6 ft (1.8 m) or more. > NOTE: The use of sheet pile stirrups as a fall protection method is prohibited; d. Whenever workers are exposed to falls from unprotected sides or edges; fixed ladders over 20 ft (6 m) in height; roof or floor openings; holes and skylights; unstable surfaces; leading edge work, excavations; scaffolds; formwork; work platforms, rebar assembly, steel erection and engineered metal buildings; > For Steel Erection activities, when connectors are working at same connecting point, they shall connect one end of the structural member before going out to connect the other end. Whenever possible, the connectors shall straddle the beam instead of walking along the top flange. Connectors shall remain 100% tied off. e. Where there is a possibility of a fall from any height onto dangerous equipment, into a hazardous environment, or onto an impalement hazard. f. For all USACE owned/operated permanent facilities with open sided floors or platforms 4 ft (1.2m) or more above adjacent floor or ground level, see Section 24.A.01.d. The order of control measures (the hierarchy of controls) to abate fall hazards or to select and use a fall protection method to protect workers performing work at heights shall be: a. Elimination: Remove the hazard from work areas or change task, process, controls or other means to eliminate the need to work at heights and subsequent exposure to fall hazards (i.e. build roof trusses on ground level and then lift into place or design change by lowering a meter or valve at high locations to a worker s level); b. Prevention (traditional or same level barrier): isolate and separate fall hazards from work areas by erecting same level barriers such as guardrails, walls, covers or parapets; c. Work platforms (movable or stationary): Use scaffolds, scissors lifts or aerial lift equipment to facilitate access to work location and to protect workers from falling when performing work at high locations;

108 Page 108 d. Personal Protective Systems and Equipment: Use of fall protection systems, including restraint, positioning or personal fall arrest, (i.e., requiring the use of full body harness, lanyard, and lifeline); e. Administrative Controls: Introduce new work practices that reduce the risk of falling from heights, or to warn a person to avoid approaching a fall hazard (i.e. warning systems, warning lines, audible alarms, signs or training of workers to recognize specific fall hazards). When using stilts, or raised platforms, workstands or floors above a walking/working surface that exposes workers to a fall of 6 ft (1.8 m) or more in areas protected by guardrails, the height of the guardrail must be raised accordingly to maintain a protective height of 42 in (107 cm) above the stilt, raised platform, workstand or floor height. When conducting inspection, investigation or assessment work during construction activities, fall protection is required for employees exposed to fall hazards. TRAINING Each worker who might be exposed to fall hazards from heights and using fall protection equipment shall be trained by a Competent Person for fall protection, who is qualified in delivering fall protection training to the workers in the safe use of fall protection systems/equipment and the recognition of fall hazards related to their use, including: a. The nature of fall hazards in the work area; b. The correct procedures for erecting, using, dismantling, maintaining, and storing fall protection equipment; c. The application limits, free fall distance, total fall distance and clearance requirements of fall protection systems and equipment; d. Rescue equipment and procedures; e. Hands on training and practical demonstrations; f. All applicable requirements from this Section. Retraining shall be provided, as necessary, for workers to maintain an understanding of these subjects.

109 Page 109 The employer shall verify worker training by a written certification record identifying the worker trained, the dates of the training, and the signature of the trainer and trainee. FALL PROTECTION PROGRAM If Penna has personnel working at heights, exposed to fall hazards and using fall protection equipment, he shall develop a Site Specific Fall Protection and Prevention Plan and submit it to the GDA for acceptance as part of their APP. The plan shall describe, in detail, the specific practices, equipment and methods used to protect workers from falling to lower level. This plan shall be updated as conditions change, at least every six months and shall include: a. Duties and responsibilities. Identify Competent and Qualified Persons for fall protection and their responsibilities and qualifications; b. Description of the project or task performed; c. Training requirements to include the safe use of fall protection equipment; d. Anticipated hazards and fall hazard prevention and control; e. Rescue plan and procedures; f. Design of anchorages/fall arrest and horizontal lifeline systems: (1) It is realized that the provision of fall protection for the first person up for establishing anchorages ONLY would be difficult. In this situation, fall protection may not be required. After anchorages are installed, fall protection is required. (2) Penna shall identify all locations where anchorages need to be established, and detail in the Plan/AHA how work will be performed safely. g. Inspection, maintenance and storage of fall protection equipment; h. Incident investigation procedures; i. Evaluation of program effectiveness and, j. Inspection and oversight methods employed. Each USACE owned facility shall develop a written fall protection program if they have personnel working at heights, exposed to fall hazards and using fall protection

110 Page 110 equipment. The facility shall conduct a fall hazard survey, prepare survey report at existing buildings or structures, and comply with the program elements and requirements as identified. CONTROLLED ACCESS ZONES. The use of Controlled Access Zone as a fall protection method is prohibited. COVERS Install covers on any hole 2 in (5.1cm) or more in its least dimension on walking/working surfaces such as floors, roofs or other openings. Covers shall be capable of supporting, without failure, at least twice the weight of the worker, equipment and material combined. Covers shall be secured when installed, clearly marked with the word HOLE, COVER or Danger, Roof Opening Do Not Remove or color coded or equivalent methods (e.g., red or orange X ). Workers must be made aware of the meaning for color coding and equivalent methods. SAFETY NET SYSTEM (for fall protection) > Debris nets are addressed in Section 14.C Housekeeping. Safety nets shall be installed as close under the work surfaces as practical but in no case more than 25 ft (7.6 m) below such work surface. Nets shall be hung with sufficient clearance to prevent contact with the surfaces or structures below. Such clearance shall be determined by impact load testing. When nets are used on bridges, multistory buildings or structures, the potential fall area from the walking/working surface to the net shall be unobstructed. a. The maximum size of the mesh openings shall not exceed 36 in 2 (230 cm 2), nor be longer than 6 in (15 cm) on any side. b. The border rope or webbing shall have a minimum breaking strength of 5,000 lb (22.2 kn). Nets shall extend outward from the outermost projection of the work surface as shown in Table 21 1:

111 Revised Safety Plan Ray Roberts Dam Page 111 TABLE 21 1 SAFETY NET DISTANCES Operations requiring safety net protection shall not be undertaken until the net(s) is in place and has been tested without failure. a. Safety nets and safety net installations shall be tested in the suspended position immediately after installationn under thee supervision of Qualified Person and in the presence of the GDA and before being used as a fall protection system; whenever relocated, after major repair; ; and when left at one location, at not more than 6 month intervals. b. The test shall consist of dropping into the net a 4000 lb (180 kg) bag of sand, not more than 30 in+ +/ 2 in (76.2 cm +/ 5 cm) in diameter, at least 42 in ( cm) above the highest working/walking surface at whichh workers are exposed to fall hazards. Means must be taken to ensuree the weight can be safely retrieved after the test is conducted. Shackles and hooks used in safety net installations shall be made of forged steel. When used with safety nets, debris nets shall be secured on top of the safety net but shall not compromise the design, construction, or performance of the safety nets. Materials, scrap pieces, equipment, and tools that have fallen into the safety net shall be removed as soon as possible and at least before the nextt work shift. Safety nets shall be protected from sparkss and hot slag resulting from welding and cutting operations.