The personal safety and health of each employee is the highest concern.

Kamehameha Schools, Maui 1. Safety Philosophy PURPOSE: POLICY: To clarify the organization philosophy and policy with respect to student, faculty, staff, and employee safety and health, and loss prevention activities. All employees are required, as a condition of employment, to exercise due care in the course of their work to prevent injuries to themselves, to other employees and the public. It is essential that each team leader, principal, supervisor and employee take a renewed interest in the prevention of accidents and provide the leadership which will inspire their employees and/or peers to work in a safe manner each day. Each of us is expected to extend full cooperation to safety efforts and programs. The personal safety and health of each employee is the highest concern. The prevention of work-related injuries and illnesses is of such consequence that, whenever possible, it will be given precedence over operating productivity, expediency, restoration of service or short cuts. KSM intends to comply with all Safety Laws and Ordinances. Every employee must give serious attention to making safety an integral part of their day-to-day activities. OBJECTIVE: SCOPE: To conduct all operations as safely and efficiently as possible, to prevent accidents and comply with all safety laws and ordinances. All KSM students, faculty, staff and employees. RESPONSIBILITIES: A. Supervisors 1. Institute KSM Safety Program and ongoing activities that will assist in the prevention of accidents and property losses. 2. Ensure that faculty, staff and employees are fully trained and informed concerning safe work practices. 3. Ensure that all employees comply with established KSM Safety, procedures, work rules and regulations. B. Employees 1. Exercise due care in their work to prevent accidents and injuries. 2. Follow all established KSM safety procedures, work rules and regulations. 1

Kamehameha Schools, Maui C. Staff 3. Actively attend and participate in scheduled safety meetings and training activities. 1. Develop, update and distribute policies, procedures and materials as they effect corporate philosophy related to safety and loss prevention activities. 2. Take all actions deemed necessary to produce a positive reduction in accidents and their causes. 3. Coordinate the use of safety consulting services to assist and augment KSM Safety Program activities. 4. Conduct annual reviews audits of the KSM Safety Program and activities. 2

Kamehameha Schools, Maui 2. Organization PURPOSE: POLICY: OBJECTIVE: SCOPE: To outline the organization and administration of KSM Safety Program. KSM will operate and maintain a safety program organization with responsibilities defined for the Headmaster, Principals, Faculty, Staff, Employees and Students. To prevent accidents that may result in injuries to students, faculty, staff, employees, the public, and damage to KSM property. All KSM students, faculty, staff and employees. I. INTRODUCTION Employees from all levels within KSM must have clearly defined safety duties, responsibilities and standards of performance to ensure that the communication of safety awareness is provided at all levels. There must be free and clear communication between KSM Headmaster, Principals, Faculty, Staff, Employees and Students. This effective communication is important to administer our operations efficiently and safely. Management and employees are equally encouraged to identify and report potential hazards, discuss hazard abatement solutions, and take actions to prevent accidents or further loss. II. SAFETY PROGRAM ELEMENTS KSM Safety Program includes a number of elements that must be incorporated into our day-today activities. These elements are addressed specifically in the Safety & Health Program sections of this manual and include the following: Safety Committee Meetings Accident Reporting & Investigation Hazard Recognition & Control Program Safety Training Use of Personal Protective Equipment Hazard Communication Program Lock Out/Tag Out Program Confined Space Entry Program Hearing Conservation Program Bloodborne Pathogen Standard Respiratory Protection Program Motor Vehicles Forklift Trucks/Tractors General Safety Rules Emergency Response 3

Kamehameha Schools, Maui III. RESPONSIBILITIES A. Headmaster, Principals and Director of Operations Shall: 1. Provide economic and administrative support to maintain an effective Safety Program at all KSM locations. 2. Assist Managers and Supervisors with safety and health issues when outside consultation is needed. 3. Review the safety performance of all KSM locations annually and issue recommendations and goals for improvement. 4. Ensure that all Team Leaders and Supervisors provide a leadership role to motivate associates, peers and subordinates to work in a safe and healthy manner. 5. Establish disciplinary guidelines to assist in the enforcement of rules and procedures for the safety and health of all employees. 6. Coordinate insurance loss prevention services to maximize efforts and ensure a productive working relationship. 7. Establish and conduct Campus Safety Meetings. B. The Director of Operations Shall: 1. Ensure facilities, operations and equipment are in compliance with federal and state laws and standards. 2. Ensure the Safety Program is implemented. 3. Encourage and support employee participating in safety program activities. 4. Review accidents and assist in taking remedial action. 5. Ensure remedial action is accomplished on a timely basis. 6. Evaluate safety performance of department heads and supervisors. 7. Review annual safety and health budget. 8. Ensure supervisors and committees hold periodic safety meetings. C. The Safety Coordinator Shall: 1. Develop and implement a safety program. 4

Kamehameha Schools, Maui 2. Provide technical assistance in developing, modifying, and improving standard operating procedures to include safety and health procedures. 3. Perform job hazard analysis and inform supervisors of hazardous conditions or materials. 4. Investigate accidents and assist responsible department in accomplishing remedial action. 5. Inspect facilities, equipment and operations semi-annually. 6. Advise appropriate corrective action and follow up. 7. Coordinate training programs for supervisors and employees. 8. Keep apprised of changes in laws and standards. 9. Be the resource for interpretation of standards. 10. Monitor all safety activities. 11. Implement an emergency plan. 12. Coordinate with the supervisor in the development and implementation of new standards. D. Team Leaders and Supervisors Shall: 1. Conduct hazard evaluations and modify work practices and procedures as needed. 2. Survey job sites prior to work start up. 3. Inspect facilities, operations and equipment monthly. 4. Ensure that tools and equipment are inspected regularly and are in safe operating condition. 5. Train employees on safe work practices and procedures and on the use and maintenance of protective equipment. 6. Ensure personal protective equipment and safeguards are utilized and maintained properly. 7. Investigate and take appropriate action on any condition or procedure reported as being unsafe. 8. Review Material Safety Data Sheets (MSDS) and inform employees of precautions when working with hazardous conditions or materials. 5

Kamehameha Schools, Maui 9. Orient new employees on their safety and health responsibilities. 10. Ensure employees are aware of hazard reporting procedures and the safety suggestions system. 11. Evaluate suggestions, implement if immediately feasible, or submit to management for further consideration. 12. Ensure injured persons receive prompt and appropriate medical treatment. 13. Report, investigate and record all employee accidents and incidents. E. Faculty, Staff and Employees Shall: 1. Follow prescribed work policies, procedures and rules. 2. Report all accidents, injuries, near accidents, and unsafe conditions to your supervisor, and get prompt first aid for all injuries no matter how minor. 3. Exercise due care in the performance of your duties to prevent accident and injury to yourself, fellow employees, customers, the public and KSM property. 4. Use and properly maintain the personal protective equipment provided to reduce or eliminate the probability of accidents and injuries. 5. Make safety a priority in the work environment. 6. Actively participate in KSM Safety & Health Program by participating in safety activities (when requested) such as attending safety meetings and training sessions. F. Safety Committees Shall: 1. Analyze employee accident reports and make recommendations for corrective action. 2. Conduct inspections. 3. Identify unsafe conditions, practices, and make recommendations for correction. 4. Review employee suggestions. 5. Keep minutes and compile activity reports. 6

Kamehameha Schools, Maui 3. Safety Committee PURPOSE: POLICY: OBJECTIVE: SCOPE: To establish KSM Safety Committees and meetings, their organizational structure, functions, standard business operations and responsibilities. KSM will maintain safety communication activities through the development of organized Safety Committees (where practical), safety training meetings and through discussion of safety issues. To provide a means for effectively communicating safety-related matters throughout KSM. All faculty, staff and employees of KSM. I. INTRODUCTION A. Organized Structure The KSM Safety Committee is designed to be structured around current organizational format. The Safety Committee will meet monthly to identify and resolve safety problems and reduce hazards. Communication and coordination of safety related activities throughout all levels of are the immediate goals of this committee. The Safety Coordinator will chair the KSM Safety Committee. Members of the Committee shall include the following: Representative from Elementary, Middle, & High School Representative from Athletics Operations Team Leaders Safety Coordinator Director of Campus Operations Recorder The overall purpose of this structure is to: 1. Maintain the interest of campus leadership, management and non-management personnel and assist all employees in understanding that safety, accident and loss prevention is everyone s responsibility and a priority at KSM. 2. Maintain and promote safety awareness among all employees. This forum will enable employee participation and share in the responsibilities of the Safety Program. 3. Communicate safety activities to employees so safety becomes an integral part of the total operating policies and procedures of KSM. 4. Provide an opportunity for open discussion of hazards and to formulate preventive measures for the elimination of these hazards. 7

Kamehameha Schools, Maui B. SAFETY COMMITTEE DUTIES & RESPONSIBILITIES 1. Duties & Responsibilities The Committee has the responsibility to ensure that all safety and loss prevention activities and programs are developed, implemented and maintained. C. Safety Committee Function and Operating Guidelines The basic function and guidelines for the Safety Committee include: 1. Conduct monthly Safety Committee Meetings. 2. Recordkeeping agendas, minutes, and program information must be documented, distributed, and retained in the Safety Committee file. 3. Introduction of new training programs, procedures and policies as necessary by KSM policy or regulatory requirement. 4. Review and discuss accidents/incidents, loss trends, loss to property, and areas of responsibilities. This includes faculty, staff, employees, and the general public. 5. Reports on special safety projects/activities. 6. Reports on safety inspections/audits and corrective actions. 7. Formulate ideas, goals, and objectives to prevent accidents and loses to employees, customers and the public. 8. An agenda will be developed and published for each meeting. Safety Committee members may submit topics for discussion. 9. The Recorder will record the meeting and publish the minutes. 10. Action persons will be identified, assigned projects and report to the committee with a comprehensive report. II. APPENDIX: Included in this section are forms for documenting KSM Safety meetings and other information to assist in the operation of the Safety Committees and Safety Meetings. 8

Kamehameha Schools, Maui SAFETY COMMITTEE PROTOCOL 1. CALL TO ORDER The chairperson calls the meeting to order. Indicate date and time. 2. ROLL CALL Pass sign in sheet around. 3. INTRODUCTION OF VISITORS OR NEW MEMBERS 4. READ PREVIOUS MINUTES Previous minutes should be discussed, corrected, and/or approved. 5. UNFINISHED BUSINESS All matters held over should be discussed, and all recommendations not acted on since the last meeting should be listed. 6. NEW BUSINESS Review all subcommittee reports, injury reports, and safety inspection reports. Inspection reports would include self-inspections by supervisors, outside safety consultant reports, and regulatory agency inspection. 7. SAFETY EDUCATION Review new employee, group, or departmental training features. 8. ANNOUNCEMENTS The date and time of the next meeting, training session, or other important dates should be announced. 9. ADJOURNMENT 9

Kamehameha Schools, Maui SAFETY MEETING MINUTES/REPORT Suggested Order of Business (check off each item when completed) 1. Date & Time of Meeting 8. Review Survey Reports & Results 2. Attendance/Members Absent 9. Progress of Past Recommendations 3. Introductions 10. Safety Education & Training 4. Corrections of Previous 11. New Business Special Minutes Projects 5. Review Unfinished Business 12. Next Meeting Date & Time 6. Review Sub-Committee 13. Meeting Adjourned Actions 7. Review Accidents 14. Signature of Recorder Provide notes or attach pertinent information. Use back of form for additional space. Department/Area: Date/Time Attendance: Members Absent: Correction of Previous Minutes: Unfinished Business: Sub-Committee Actions: Accident Review: Survey Reports & Results: 10

Kamehameha Schools, Maui Past Recommendations: Safety Education & Training: New Business Special Projects: Next Meeting: Adjourned (Time:) Recorder Signature: Disposition: Safety File, Safety Bulletin Board, Members, Risk Management 11

Kamehameha Schools, Maui SAFETY MEETING MINUTES Conducted By: Location: Date: Time: Topic Discussed: Comments: Participant s Name (Print) Participant s Signature Distribution: Original to Safety Training File Copy to Safety Office 12

Kamehameha Schools, Maui 4. Accident Reporting PURPOSE: POLICY: OBJECTIVE: SCOPE: To establish procedures and guidelines for prompt reporting of accidents and incidents at, and responsibilities for accident notification and investigation. Regards accident notification, reporting and investigation as essential to the effectiveness of the Safety Program. All accident notification will be prompt and accidents will be reported and investigated in accordance with these established procedures. To ensure prompt and proper notification and reporting of accidents and thorough investigation to comply with regulatory requirements, provide for compensation, minimize legal liability, mitigate adverse publicity, reduce unnecessary losses and prevent recurrence. This procedure applies to Kamehameha Schools, Maui. I. RESPONSIBILITIES A. Employees: 1. Notify their Supervisor or Team Leader when an accident, incident or illness occurs within 24 hours and cooperate in the investigation process. B. Supervisors: 1. Conduct and/or coordinate the notification and reporting process. 2. Summon necessary assistance and make appropriate (Nurse) and external notifications (fire/paramedic). 3. Notify the Safety Administrator when the accident involves or is serious enough to result in hospitalization or results in serious loss to property. 4. Complete an accident investigation. Submit to Safety Office and report on webforms on ksonline within 24 hours. 13

Kamehameha Schools, Maui C. Human Resources/Safety Coordinator: 1. Make appropriate OSHA, insurance and family member notifications if an accident results in employee hospitalization, amputation or fatality, and/or if substantial injury occurs to a customer or serious property damage occurs. 2. Provide assistance to Team Leaders and Supervisors as deemed necessary. 3. Audit the process to ensure quality and compliance, and follow up on corrective measures. II. NOTIFICATION, REPORTING & INVESTIGATION PROCEDURES There are essentially four different types of accident/incident scenarios that will require different reporting procedures. They are: Employee Injury/Illness Property Loss (excluding Vehicle Damage) fire, theft, flood, etc. General Liability customer injury or incident Vehicle Accident Each type of accident/incident is discussed below along with the appropriate forms to use which can be found in the Appendix of this Section. All accident/incident reporting and investigations are to be conducted by the Team Leader or Supervisor, or in the case of a vehicle accident, by the employee operating the vehicle. All copies of forms, correspondence, pictures, etc. will be maintained at the Safety Office. A. Employee Injury/Illness: 1. Determine seriousness of the injury/illness and make appropriate internal/external notifications immediately per published policies and procedures. Notify the Nurse. 2. If the employee seeks or needs medical treatment and send employee to an appropriate medical facility. If employee is transported via paramedics, obtain name of medical facility where employee will be transported. 3. Complete and forward an initial notification of injury or illness within 24 hours and submit as follows: Forward a copy to the Safety Office. 4. Conduct and complete the ACCIDENT/INCIDENT INVESTIGATION REPORT (see Appendices) within 24 hours. Follow up on investigation findings to determine causal factors and institute corrective control measures. 5. Enter any recordable employee injuries and illnesses on the LOG OF OCCUPATIONAL INJURIES AND ILLNESSES OSHA FORM. 6. If the accident also includes injury or damage to vehicle, Kamehameha Schools property, or the public/students, then refer to Sections B, C, & D below. 14

Kamehameha Schools, Maui 7. Institute control procedures and programs to maintain injured employee morale, reduce loss time, and return employee back to work. This should be coordinated with Human Resources and Safety. B. Property Loss (excluding vehicle damage) Fire, Theft, Flood, etc.: 1. Make appropriate notifications to the Safety Coordinator of the accident/loss. 2. Complete and forward a Incident Report to the Safety Coordinator within 24 hours. 3. Conduct and complete the ACCIDENT/INCIDENT INVESTIGATION REPORT within 24 hours and submit copy to Safety. Determine causal factors and follow up on controls necessary to prevent recurrence. 4. Communicate with Operations Department (when necessary) regarding repair work, clean-up, and progress of activities and completion. C. General Liability Customer Injury or Incident: 1. Attend to injured person(s), provide first aid if requested and make appropriate internal notifications. 2. Determine if injured person needs medical aid. If so, offer to call 911. Note: Do not move an injured person unless there is an imminent danger of further injury. First-aid treatment is to be rendered only when specifically requested by the injured person and then only by qualified personnel. If it is determined by qualified personnel that 911 should be notified, this should be done regardless of the wishes of the injured person. 3. Complete an INCIDENT REPORT Form (see Appendices) within 24 hours and forward to Safety. This report notification should be immediate if the accident/incident is serious. Attach any supporting documents and information. 4. Conduct and complete the ACCIDENT/INCIDENT INVESTIGATION REPORT within 24 hours and submit copy to Safety. Follow up on investigation findings to determine causal factors and institute corrective control measures. D. Vehicle Accident: 1. Call 911 to obtain emergency assistance, if needed. 2. Attend to injured and secure the accident scene to prevent further danger to yourself and others, and preserve any evidence, if possible. 3. Notify your supervisor as soon as possible. 4. The driver must complete the an ACCIDENT REPORT (see Appendices) located in the vehicle glove box, and it must be submitted to the Department Manager immediately and Safety within 24 hours. If the accident also involves employee injury, then refer to Section A. 5. Cooperate with investigating authorities, but never admit liability/fault for an accident that you have been involved in. Do not discuss the accident with other involved parties. 15

Kamehameha Schools, Maui 6. The driver s Manager must conduct and complete the ACCIDENT/INCIDENT INVESTIGATION REPORT within 24 hours and submit to Safety. 7. Disciplinary action, if applicable, will be administered per established policy. An investigation may be prompted by an injury to a staff member or an exposure to a blood borne pathogen as defined below. How to Complete a Supervisor s Investigation Report 1. Use the questions in the report to interview the injured/exposed staff member and record the facts/information on the report. If necessary, call the staff member at home. 2. Particular attention should be addressed to the following: a. Date and Time of incident b. Time Lost - indicate the time and date(s) the staff member is off work as a result of the injury/illness/exposure. c. Name of Physician - If known, identify the physician or medical facility the staff member visited for this injury/illness/exposure. If the physician is unknown, process the form without this information. d. What happened? Where did it happen? describe the incident as related by the staff member describe the workplace environment identify the area/building describe the activity the staff member was engaged in when the incident occurred. e. Why did it happen? did a pre-existing, hazardous or uncorrected work/equipment condition contribute to the incident? was the staff member properly trained to perform the assigned job duty/responsibility? did the staff member fail to follow established procedures? f. What should be done? - Suggestions/recommendations to prevent a repeat occurrence, e.g., additional job training, safety training, corrections of the identified hazards/deficiencies in the work environment/tools/equipment, use of proper clothing/work accessories designed to prevent workplace hazards. Distribute this form following instructions on the front of the form. DO NOT FAX. Mark all envelopes Confidential. Definitions related to Blood borne Pathogens: Blood borne pathogens means pathogenic microorganisms that are present in human blood. These pathogens include, but are not limited to, hepatitis B virus ( HPV ) and human immunodeficiency virus ( HIV ). For a complete description, contact the Medical Director. 16

Kamehameha Schools, Maui Exposure Incident means a specific eye, mouth or other mucous membrane, non-intact skin or parental (puncture or intravenous) contact with blood or other potentially infectious materials that results from the performance of a staff member s duty. III. APPENDICES A. Accident/Incident Investigation Report B. Supervisor s Safety Inspection Sheet Instructions for Completing Supervisor s Investigation Form An investigation may be prompted by an injury to a staff member or an exposure to a bloodborne pathogen as defined below. It is VERY IMPORTANT that this information reach Human Resources IMMEDIATELY. DO NOT HOLD THE FORM even if you are not able to get all the information needed to complete the form. CALL Human Resources with the information available so that required actions can begin in a timely fashion. How to Complete a Supervisor s Investigation Report (PERS-22) 1. Use the questions in the report to interview the injured/exposed staff member and record the facts/information on the report. If necessary, call the staff member at borne. 2. Particular attention should be addressed to the following: a. Date and Time of incident b. Time Lost indicate the time and date(s) the staff member is off work as a result of the injury/illness/exposure. c. Name of Physician If known, identify the physician or medical facility the staff member visited for this injury/illness/exposure. lithe physician is unknown, process the form without this information. d. What happened? Where did it happen? describe the incident as related by the staff member describe the workplace environment identify the area/building describe the activity the staff member was engaged in when the incident occurred. e. Why did it happen? did a pre-existing, hazardous or uncorrected work/equipment condition contribute to the incident? was the staff member properly trained to perform the assigned job duty/responsibility? did the staff member fail to follow established procedures? f. What should he done? Suggestions/recommendations to prevent a repeat occurrence, e.g., additional job training, safety training, corrections of the identified hazards/deficiencies in the work 17

Kamehameha Schools, Maui environment/tools/equipment, use of proper clothing/work accessories designed to prevent workplace hazards. Distribute this form following instructions on the front of the form. DO NOT FAX. Mark all envelopes "Confidential" Definitions related to Blood borne Pathogens: "Blood borne pathogens" means pathogenic microorganisms that are present in human blood. These pathogens include, but are not limited to, hepatitis B virus ("HPV") and human immunodeficiency virus ("HIV ). For a complete description, contact the Medical Director. Exposure incident means a specific eye, mouth or other mucous membrane, non-intact skin or parental (puncture or intravenous) contact with blood or other potentially infectious materials that results from the performance of a staff member s duty. 18

Kamehameha Schools, Maui PURPOSE: POLICY: OBJECTIVE: SCOPE: To establish procedures and guidelines for reporting unsafe acts, conditions and near accidents and to identify hazards that may cause accidents and injuries to employees and the public, or damages to KSM property. All employees are encouraged to report unsafe acts, conditions and near accidents when observed or when they occur so actions can be taken to prevent potential future accidents and losses. To identify potential safety hazards, reduce costs, inefficiency, and provide a safe working environment for KSM employees and a safe teaching environment for KSM students. All KSM employees and locations. I. INTRODUCTION KSM has instituted a Hazard Recognition & Control Program to identify hazardous conditions and operations at KS owned facilities and to implement control strategies to eliminate or reduce the recognized hazards. All employees are members of the Hazard Recognition & Control Program team and are encouraged to be aware of and report hazardous situations. A. Hazard Recognition The KSM program consists of the following elements: 1. Incident Report for Near Accident & Safety Suggestions Form 2. Verbal Communication at Safety Meetings 3. In-House Walk Through Safety Inspections 4. Insurance Safety Inspections/Audits 5. Regulatory Agency Inspections 6. Post Accident/Incident Investigations B. Hazard Control The control techniques and elements of the KSM program include: 1. Implementing Accident Investigation Control Strategies 2. Follow-Up on Incident Report for Near Accident & Safety Suggestion Forms Submitted by Employees 3. Follow-Up Actions on Items Discussed at the Safety Meetings 4. Reviews of Inspection/Audit Reports and Implementation of Recommended Controls Provided in the Reports 5. Immediate Reporting and/or Correction of Daily Observed Hazards II. RESPONSIBILITIES & PROCEDURES A. Employees: When you see or receive information relating to unsafe acts, conditions or incidents, the following procedures should be used as a guide. 1. The first person who sees the problem should correct minor conditions and their cause where possible to prevent an accident to KSM students and /or employees. 2. Notify your Supervisor or Team Leader of the problem and disclose whether the condition has been corrected or if additional measures are needed. 19

Kamehameha Schools, Maui 3. Fill out the INCIDENT REPORT Form to report a safety hazard, incident or to make a suggestion and forward to your Supervisor or Manager. B. Team Leaders and Supervisors: 1. Take remedial action to prevent recurrence of incidents or to eliminate observed hazards. It often takes several follow-up checks to ensure the condition gets corrected. 2. Follow up with employees on actions taken, document the incident, and retain forms and follow-up actions in a file. 3. Review outcomes of incidents and inspections at the Safety Meetings. 4. Conduct regular in-house inspections, submit report and follow up on corrective actions. 5. Accompany regulatory agencies and non-regulatory consultants on inspections/audits and take notes. 6. Submit a written response to Safety and/or Human Resources on regulatory/nonregulatory inspection results and recommendations. The response should clearly indicate the KSM position with regard to each specific recommendation, cost factors and time estimates to comply or institute control measures. 7. Ensure that safety policies, compliance procedures, and inspection report recommendations and evaluations are issued and followed to prevent recurrence of the same hazards. C. Senior Management: 1. Provide assistance, as deemed necessary, regarding compliance and liaison for inspections/audits conducted HIOSH, fire department, County of Maui, the State of Hawaii, Federal Government. 2. Follow up on any citations received by a regulatory agency to ensure compliance with the agency s regulations. III. INSPECTION GUIDELINES A. In-House Inspections: Self-inspections by Safety Officers, Team Leaders, Supervisors and staff will be conducted on the following schedule: 1. Monthly by location Safety Officer. A list of hazards will be provided to the Safety Director for follow-up corrective action within five (5) working days. See sample checklist in the Appendices of this section. 2. Semi-Annually by Safety Coordinator. 3. The Safety Director will instruct Safety Officers who will participate in the inspection. 4. The Safety Director will follow up to ensure that control strategies are implemented to eliminate hazards. 5. This process should be ongoing throughout the day because of the ever-changing conditions and hazardous situations that may arise. 20

Kamehameha Schools, Maui B. Non-Regulatory Inspections: Inspections/audits by insurance company representatives or safety consultants. 1. The Manager is required to accompany the representative on the inspection/audit, ask questions and take notes. 2. Recommendations for correction of observed hazards should be coordinated between the Safety Director and Risk Management. 3. A formal report will be submitted by the representative at a later date which will require your attention and follow up. 4. Copies of notes, actions and report follow up should be retained in the inspection file at the Safety Director s office. C. Regulatory Inspections: Inspections by government agencies such as OSHA, fire department, etc. 1. Inspections will be allowed without requiring a warrant. Risk Management, Safety Director will be notified of the inspection and intent. Inspections will generally fall into three categories: An Employee Complaint Government agency standards compliance visit, or Accident resulting in a severe injury or fatality 2. An opening conference is required to agree on the scope of the visit. Obtain a business card and check the inspector(s) credentials. 3. The Safety Director will accompany the inspector(s) to the department or areas, take notes, and when possible, photos of possible citable items. 4. The Manager should hold a closing conference with inspector(s) to discuss findings and immediate recommendations. Show employer good faith by resolving issues during the inspection, where feasible. 5. Send a report/memo to Facilities, Safety Coordinator and/or Human Resources of your findings/impressions of the inspection along with any copies of citations. 6. If an OSHA citation is received, ensure that the citation is posted at the specific location for the specified period, that hazards are abated and that a response is submitted back to the agency in the required time frame. This response should be coordinated with the Safety Coordinator. 7. Appeals to OSHA citations are possible if we agree that the citations are not valid. We generally have 15 days to file an appeal, therefore, contact the Safety Director immediately if a citation is received. 21

Kamehameha Schools, Maui 6. Safety Training PURPOSE: POLICY: OBJECTIVE: SCOPE: To establish guidelines for providing safety training to employees. All KSM faculty, staff and employees will receive ongoing basic safety training and specific training with respect to hazards unique to the employee s job assignments. Training will be scheduled as needed and will be documented as part of the employee s training file. To ensure employees are familiar with hazards associated with their jobs and to reduce the potential for accidents that may cause injury or illness to employees and the public, and to prevent loss to KSM property. All KSM employees. I. RESPONSIBILITIES A. Managers and Supervisors: 1. Ensure each new employee receives Safety Orientation Training. 2. Provide employee safety training unique to his/her job assignment. 3. Conduct ongoing training activities for review or to address new issues. 4. Maintain records of employee training. 5. Maintain a safety training library. 6. Review and evaluate training programs in order to maintain a high level of effectiveness and interest in safety subjects. B. Employees: 1. Attend and participate in all safety training classes. 2. Provide feedback to Supervisors and Managers on the effectiveness of training classes for improvement or indicate additional subjects of interest. 3. Study all materials provided and apply the knowledge to your job tasks. 22

Kamehameha Schools, Maui C. Operations Management: 1. Provide economic assistance to establish training programs. 2. Act as a source of reference and obtain, develop and distribute safety training materials, as needed. 3. Review KSM training programs and audit compliance to establish training requirements. II. GENERAL REQUIREMENTS Safety education is important for several reasons. A task completed safely will also be completed correctly and efficiently, with a high degree of satisfaction. Additionally, OSHA requires employers to follow established safe work procedures. This requirement assumes that employees have been instructed. KSM will meet raise the level of safety awareness through a comprehensive safety training program. A. New Employee Safety Training: 1. Before employees may begin to perform the specific duties for which they were hired, they must receive orientation training from their supervisor. The orientation should be done no later than ten days after the employee start date. 2. The EMPLOYEE SAFETY ORIENTATION CHECKLIST should be used as a guide for training and must be signed by the employee and supervisor and kept with the employee s file (see Appendices of this section). B. Ongoing Safety Training for All Employees: The following training is recommended: 1. Periodically by Departments as part of safety meetings or on topical issues (fire protection, electrical safety, slips and falls, etc.) 2. Before a new process or equipment is put into operation. 3. Annual refresher to maintain certifications or competence (first aid/cpr, forklift, etc.) 4. Pre-operation training to ensure safe operation of equipment. C. Training Records: 5. OSHA mandated training (Right-to-Know, forklift, etc.) 1. All training activities should be documented and maintained in a Safety Training File. This documentation should include the name of the trainer, the name(s) of the employee(s) trained, the subject of the training and the date and duration of the training (see EMPLOYEE SAFETY TRAINING Form in the Appendices of this section). 2. Records should be retained and distributed as follows: Copy to Employee (when indicated) Original to Safety Director 23

Kamehameha Schools, Maui D. Training Resources Training resources are available from a number of sources: 1. Safety Director 2. Risk Management 3. Insurance Broker and Carrier 4. Local Fire Department & Emergency Services Office 5. Safety Policies, Rules, and Topics included in this Manual 6. In-House Experts 7. Safety Associations 8. Safety Councils 9. Vendors 24

Kamehameha Schools, Maui 7. Personal Protective Equipment PURPOSE: POLICY: OBJECTIVE: SCOPE: To establish policy with respect to providing and using Personal Protective Equipment (PPE) for employee safety. KSM employees will be provided with and required to use and maintain PPE to improve their safety when engineering controls are not adequate and feasible to eliminate exposures. Maintain employee safety and health, and assure compliance with regulatory requirements. All employees. I. REQUIREMENTS Most PPE must meet the requirements of the Occupational Safety and Health Act (OSHA). Respiratory protection standards are governed by the American National Standards Institute (ANSI). Approved respiratory protection equipment must meet the requirements of the National Institute for Occupational Safety and Health (NIOSH) and the Mine Safety and Health Administration (MSHA). When selecting or buying any type of safety equipment, you must insist on the best equipment, deal only with reputable firms, and specify the required approvals (ANSI). If guidance is necessary for the selection and purchasing of PPE, consult with the Safety Coordinator. II. RESPONSIBILITIES A. Team Leaders and Supervisors shall: 1. Perform a survey of jobs to identify potential exposures and the appropriate PE that should be used. This survey should be documented. 2. Identify the types of PPE needed in specific areas. Assistance can be obtained from insurance representatives/consultants and vendors knowledgeable in safety and health issues. 3. Ensure employees are provided with the necessary PPE and are properly trained in its use and care. 4. Ensure employees wear the PPE provided. Conduct periodic inspections to determine compliance with KSM policy. B. Employees shall: 1. Wear the PPE issued, when and where required. 2. Maintain their PPE. Employees may be held responsible for the replacement cost if their PPE is lost or neglected. 3. Attend and participate in required training activities. 25

Kamehameha Schools, Maui III. TYPES OF PERSONAL PROTECTIVE EQUIPMENT There are nine categories of PPE that might be used in our operations. A. Eye: Guard against flying objects, glare, liquids, dust, etc. Must meet ANSI Z87.1 standards. B. Face: Shield the face (and often the head and neck as well) from chemical or hot metal splashes, flying chips/sparks, heat and other hazards (ANSI Z87.1). C. Hearing: Protects against harmful effects of sound levels that exceed permissible levels established by OSHA (see Hearing Conservation Program). D. Head: Shields against impact from falling, moving, flying, and knock-against objects, rain and others (ANSI Z89.1). E. Hand: Guard fingers and hands from exposures to cuts, scratches, bruises, burns and absorption of chemicals or agents. There are many types available and the types used must be made to protect against the specific exposure. F. Foot: There are two categories safety shoes and foot guards. Both are designed to protect against impact, lacerations, crushing and punctures. Where acids, alkalis and water are encountered, natural/synthetic rubber or plastic, resistant to the specific exposure, should be used (ANSI Z41.4). G. Clothing: Designed to reduce injury from exposure to fire, heat, cuts, impact, water and hazardous chemicals. Many styles available which should be used for the specific exposure encountered. H. Respiratory: As with hearing protection, respiratory protection devices may be used only after it has been shown that feasible engineering controls have been put into effect to reduce exposures. Only NIOSH recommended respirators for the type of hazards encountered are to be used. Refer to the Respiratory Protection Program in Section 13. I. Fall: Approved fall protection designed to ANSI Z359.1 standards, must be used when employees are exposed to falls in excess of six (6) feet. 26

Kamehameha Schools, Maui 8. Hazard Communication PURPOSE: POLICY: OBJECTIVE: SCOPE: To establish KSM policy with respect to the control of hazardous materials used in the workplace. Employees will be made aware of and trained with respect to the hazards posed by those substances encountered in the workplace. Maintain employee safety and health, define responsibilities and requirements of the Hazard Communication Program, and assure compliance with regulatory requirements. All employees. I. INTRODUCTION KSM has developed this program to comply to OSHA s Hazard Communication standard and ensure that employees handling hazardous materials are trained in the proper storage, handling and use of hazardous materials they may encounter in the work environment. It is KSM s intent to provide information about chemical hazards and other hazardous substances, and the control of hazards via our comprehensive Hazard Communication Program, which includes the following components: 1. Responsibilities 2. Container Labeling 3. Material Safety Data Sheets (MSDS) 4. Information & Training Program 5. Inventory of Hazardous Substances 6. Hazardous Non-Routine Tasks 7. Hazardous Substances in Unlabeled Processes 8. Informing Contractors About the Program II. RESPONSIBILITIES The Safety Coordinator is the Hazard Communication Coordinator (HCC) at KSM. The responsibilities for administering our program are as follows: A. Safety Coordinator shall: 1. Ensure the program is organized, written, distributed and maintained. 2. Ensure master inventory and MSDS are available and current. 3. Ensure MSDS are distributed when requested. 4. Provide technical assistance to Principals, Supervisors and Employees when questions arise about elements of the program. 5. Act as the school liaison between safety consultants, OSHA compliance officers and/or regulatory agencies. 6. Develop effective training and retraining programs. 7. Conduct annual audit to ensure effectiveness of the program. 27

Kamehameha Schools, Maui B. Team Leaders and Supervisors: 1. Maintain the Hazard Communication Program and update items as they are distributed by the Safety Coordinator. 2. Maintain a current inventory list of hazardous substances at KSM locations along with the MSDS for those materials. 3. Provide training to all employees initially and/or when hired, when new materials are introduced, and once each year for refresher. 4. Provide the program information such as a copy of the regulation and MSDS for employee review when they request it. 5. Ensure employees are complying with requirements for the use of personal protective equipment (where needed) and that labels on products are properly maintained. 6. Maintain training records on all employees for compliance and reference. 7. Coordinate notification of outside contractors with respect to potential exposures to contract employees and to KSM employees. C. Headmaster &Director of Operations: 1. Provide financial support to develop and maintain a Hazard Communication Program and to provide training materials for employee instruction. 2. Audit the program at least annually to ensure compliance by Team Leaders and Supervisors and ensure employee training is adequate based on the hazardous materials involved. D. Employees: 1. Must participate in training. 2. Must follow all prescribed program rules and procedures. 3. Report concerns and hazards to their Team Leaders. 4. Must use, handle, store and dispose of hazardous materials in accordance with information provided on the MSDS and company procedures. III. CONTAINER LABELING The policy of KSM is that no container of hazardous substances will be released for use in the workplace until the following minimum label information is verified: Containers are clearly labeled as to the contents. Appropriate hazard warnings are noted on the container. The name and address of the manufacturer is listed on the container. To further ensure that employees are aware of the hazards of materials used in their work areas, it is our policy to label all secondary containers. 28

Kamehameha Schools, Maui IV. MATERIAL SAFETY DATA SHEETS (MSDS) A master MSDS book will me maintained at the Safety Office. The Safety Coordinator will be responsible for obtaining and maintaining the data sheet system for KSM. The Safety Coordinator will review incoming data sheets for new and significant health/safety information. He/she will see that any new information is passed on to the appropriate campuses, Team Leaders and the affected employees. MSDS will be reviewed for completeness by the Safety Coordinator. If an MSDS is missing or obviously incomplete, a new MSDS will be requested from the manufacturer or distributor. OSHA will be notified if a complete MSDS is not received or the distributor fails to provide adequate information. MSDS are available to all employees for their work areas for review during each work shift. If MSDS are not available or new hazardous substance(s) in use do not have MSDS, please contact the Safety Coordinator immediately for the information. V. EMPLOYEE INFORMATION AND TRAINING Employees will attend a health and safety orientation session by their Team Leader prior to starting work: A. An overview of the requirements contained in the Hazard Communication Regulation, including their rights under the Regulation. The Hazard Communication Standard 29 CFR 1910.1200 can be found at www.osha.gov. B. Inform employees of any operations in their work area where hazardous substances are present. C. Location and availability of the written Hazard Communication Program. D. Physical and health effects of the hazardous substances and routes of entry into the human body (inhalation, ingestion, absorption). E. Methods and observation techniques used to determine the presence of or release of hazardous substances in the work area. F. How to lessen or prevent exposure to hazardous substances through the use of engineering controls, work practices, and/or the use of personal protective equipment. G. KSM has taken steps to lessen or prevent exposure to these substances. H. Emergency and first-aid procedures to follow if employees are exposed to hazardous substance(s) or spills occur. I. How to read labels and review MSDS to obtain appropriate hazard information. Note: It is important for all employees to understand the training. If you have any additional questions, please contact your Manager. When new hazardous substances are introduced, Managers will review the above items as they relate to the new materials in your work area. VI. LIST OF HAZARDOUS SUBSTANCES 29

Kamehameha Schools, Maui The list of all known hazardous substances used in the workplace is listed in the Master MSDS Book. Specific information on each noted hazardous substance(s) can be obtained by reviewing the Material Safety Data Sheets. VII. HAZARDOUS NON-ROUTINE TASKS Generally, most employees are not required to perform hazardous non-routine tasks. A non-routine task is one that is performed occasionally by employees, and in most cases requires a review of procedures prior to starting the work. Prior to starting work on such projects, each affected employee will be given specific information and procedures by their Manager about hazards to which they may be exposed during such an activity. This information will include: Specific hazards Protective/safety measures that must be utilized Measures KSM will take to reduce the hazards including ventilation, respirators, presence of another employee and emergency procedures VIII. HAZARDOUS SUBSTANCES IN UNLABELED PROCESSES Currently, we have no processes containing hazardous substances which necessitate labeling of process hazards. If this situation changes, Managers are to ensure that employees who work on unlabeled processes (pipes, tanks, chambers) are informed about the hazardous substances contained within by instituting the following policy. Prior to starting work on unlabeled processes, our employees are to contact their Manager for the following information: The hazardous substance in the pipe, vessel, tank or process equipment Potential hazards Safety precautions which shall be taken IX. INFORMING CONTRACTORS To ensure that outside contractors work safely in our facilities, it is the responsibility of the HCC to provide contractors with the following information: Hazardous substances to which they may be exposed while on the job site. Precautions their employees may take to reduce the possibility of exposure, such as using appropriate protective measures. Location of our Hazard Communication Program. Prior to contractors performing work, a determination must be made regarding the hazardous chemicals or substances that contractors might bring into the work environment. MSDS must be provided by the contractor for those substances and our employees must be notified as outlined in Section V, Employee Information and Training. 30

Kamehameha Schools, Maui 9. Lock Out, Tag Out PURPOSE: POLICY: OBJECTIVE: SCOPE: To establish the minimum requirements for locking and tagging out of energy sources. Before any employee performs any servicing or maintenance activities where unexpected start-up or release of stored energy could occur, and cause injury, all potentially hazardous energy sources shall be isolated and locked/tagged out. To ensure employee safety, prevent damage to equipment and property, and to comply with OSHA regulations. All KSM employees and contractors whose duties require them to work on systems, processes and/or machinery. I. INTRODUCTION Maintenance personnel, machine operators, and some production employees may be exposed to sources of energy that can be hazardous. Employees must follow established written procedures when performing tasks such as: routine maintenance; change-out of motors, controllers, conveyor belts and other machine parts; installing new or replacement processes; changing dies on presses; and unjamming equipment to name a few. Energy sources from electrical, mechanical, pneumatic and hydraulic systems must be isolated, discharged or released to avoid accidents. Each department should follow the procedures included in this program, and if needed, should create specific written procedures for unique processes and equipment. II. DEFINITIONS OF TERMS A. Affected Employee A person other than an authorized employee whose job include activities covered by this program (i.e. foremen, supervisors, machine operators, mechanics. B. Authorized Employee A qualified person who has been given authority and responsibility by the employer to perform a lockout/tagout assignment. C. Energy Isolating Device A device that physically prevents the transmission or release of energy. D. Lockout/Tagout The placement of a lock and/or tag on the energy isolating device. E. Qualified Person A person who demonstrates, by experience and training, the ability to recognize potentially hazardous energy sources and its potential impact on workplace conditions, and has the knowledge to implement adequate methods for controlling and isolating such energy. F. Supervisory Lock A lock with a different identifying color which is maintained with two keys for supervisor s use only. 31