1-1 Introduction

a. This document is the principal instrument that defines and supports the BHI, SMS. It serves as a resource manual that defines how health and safety is to be managed at BHI. The document does not establish new policy, but rather sets criteria in support of existing policy to protect the occupational health, safety and well-being of each employee as well as the conservation of property from incidental loss. The SMS requires unconditional commitment to maintain a safe and healthful work environment in accordance with sound industry practices, governmental requirements and company standards.

1-2 Purpose

a. The fundamental purpose of the Safety Management System (SMS) is to facilitate continuous improvement in health and safety performance. The SMS is designed to control or eliminate incidental losses that may affect our employees, vendors, suppliers, visitors or the general public. This Organization and Arrangements Document defines health and safety roles and responsibilities of employees and documents various performance components of the SMS and the logic and the methodology for implementation of those components.

b. This SMS is intended to assist in the accomplishment of five primary tasks.

(1) To establish the roles, responsibilities and expectations of employees to promote consistent effective health and safety management practices.

(2) To achieve optimal performance in eliminating incidents thereby reducing personal injuries and occupational illness.

(3) To protect business assets from fire, explosion, property damage, theft or other similar incident losses.

(4) To improve business efficiency through the systematic elimination of unscheduled downtime and avoidable production loss resulting from incident causes.

(5) To increase compliance with existing laws, regulations and rules to eliminate citations and other enforcement actions.

Policy Statement

A quality Health and Safety Program is vital to the success of BHI; therefore, working safely for BHI is a condition of employment. The rules listed below are an integral part of BHI’s Health and Safety Program and failure to comply with them could lead to disciplinary action, up to and including discharge. Employees must know and follow these Health and Safety Rules and all supervisory and management personnel shall enforce them.

EHS PROGRAMS

Current EHS Program List (Alphabetical)

(1) Abrasive Blasting

(2) Access to Employee Medical & Exposure Records

(3) Aerial Lifts (MEWP)

(4) Asbestos Awareness

(5) Assembly/Disassembly Cranes

(6) Assured Equipment Grounding Conductors

(7) Behavior Based Safety Management

(8) Benzene Awareness

(9) Blood Borne Pathogens

(10) Cell Phone/Distracted Driving

(11) Cold Weather Safety

(12) Compressed Gas Cylinders

(13) Confined Space Entry

(14) Drops Management

(15) Drug & Alcohol Policy

(16) Electrical Safety

(17) Emergency Response Plan

(18) Excavations

(19) Fall Protection

(20) Fatigue Management

(21) Fire Protection, Fire Watch and Extinguishers

(22) First Aid and CPR

(23) Flammable Liquids

(24) Forklifts

(25) Gas Monitors and Hazards Awareness

(26) General Waste Management

(27) Hand and Power Tools

(28) Handling of Accidents and Incidents

(29) Hazard Communication

(30) Hazardous Waste Operations and Emergency Response

(31) Hearing Conservation

(32) Heat Stress Management

(33) Hot Work

(34) Housekeeping

(35) Hydro Blasting

(36) Hydrogen Sulfide (H2S) Awareness

(37) Job Safety Analysis (JSA)

(38) Jobsite Security

(39) Journey Management

(40) Ladder Safety

(41) Lead Awareness

(42) Lightning Procedures

(43) Lockout Tag-out

(44) Manual Lifting and Handling

(45) Material Handling and Rigging

(46) Mechanical Equipment Operations Near Energized Lines

(47) Mobile Cranes

(48) Mobile Equipment

(49) Natural Occurring Radioactive Materials

(50) Near Miss

(51) NFPA 70 E Arc Flash

(52) Office Safety

(53) Pandemic Preparedness

(54) Personal Protective Equipment

(55) Process Safety Management/Highly Hazardous Chemicals

(56) Progressive Discipline

(57) Respiratory Protection

(58) Safe Return to Work

(59) Safety Meetings

(60) Scaffolding

(61) Short Service Employee

(62) Signaling Cranes

(63) Silica Control

(64) Spill Prevention and Response

(65) Site Safety Assessment

(66) Subcontractor Safety Management Plan

(67) Vacuum Trucks

(68) Work Performed on Overhead Lines (High Voltage)

Physical hazards are inherent in our industry. This chapter details the key strategies employed in BHI to systematically identify, assess, mitigate and control risk. A strong safety culture that strives for and believes that deliberate effort can result in Zero accidents or incidents is the foundation of good risk management.

BHI is committed to providing a safe and healthy workplace for all its employees. This Abrasive Blasting plan has been developed to aid our employees and subcontractors during Abrasive Blasting activities.

See GOM 100-5 Employee Files and Records paragraph 5-7

BHI is committed to providing a safe and healthy workplace for all of its employees. Asbestos awareness is essential to the safety of our employees. It is the policy of BHI to minimize the risks associated with asbestos exposure by utilizing industry best practices.

BHI is committed to providing our employees with a safe and healthy workplace. We recognize our employees may be exposed to the hazards associated with electrical cord sets and receptacles, which are not part of a structure or building.

BHI is committed to providing a safe and healthy workplace for all employees. We promote Behavior Based Safety practices which require safety considerations for each job task we perform. We believe in reinforcing safe behavior and in the elimination of root causes and undesirable behavior before they result in a near miss or accident.

BHI is committed to providing a safe and healthy workplace for all its employees. Benzene awareness is essential to the safety of our employees. It is the policy of BHI to minimize the risk associated with benzene exposure by utilizing industry best practices.

BHI believes that there are a number of good general principles that should be followed when there is a potential for exposure to blood borne pathogens. These principles include:

(1) The minimization of employee exposure to blood borne pathogens.

(2) Never underestimating the risk of exposure to blood borne pathogens.

(3) The implementation of as many safe work practices and engineering controls as possible to eliminate or minimize employee exposure to blood borne pathogens.

b. BHI has implemented this Health and Safety Policy to meet the letter and intent of the OSHA Blood Borne Pathogens Standard. This policy will form the basis of each Facility/Job Site Exposure Control Plan.

c. Affected company employees can reasonably be exposed in the workplace to include, but not limited to blood, mucus, and saliva. All our field leaders and other select employees receive first aid training; however, no one is specifically assigned responsibilities to render first aid.

This policy and its various provisions exist to safeguard and preserve the health and safety of our valued team members and to ensure that our vehicles are cared for and maintained in a manner that will both ensure their availability to support our mission and properly represent the professionalism of BHI.

This section covers BHI’s policy related to Cold Stress. The intent of this policy is to provide BHI employees with general knowledge and guidelines enabling employees to anticipate, recognize, evaluate, and control Cold Stress hazards in the workplace.

The purpose of this safety policy and procedure is to establish guidelines for the protection and safety of BHI employees who handle and use compressed gases.

BHI is committed to providing its employees a safe and healthy work place. BHI establishes these requirements for identifying and entering confined spaces that may be found in the workplace. Entering a confined space can be hazardous. These procedures are intended to eliminate, or reduce the dangers of entry to an acceptable level. These procedures serve as BHI written Confined Space Program, as required by 29 CFR 1926.1201.

BHI is committed to providing a safe working environment for our employees and subcontractors. Therefore, we have established requirements for the use of assembly/disassembly (A/D) of cranes based upon the OSHA regulations and industry best practices.

BHI is committed to providing a safe working environment for our employees and subcontractors. Therefore, we have established requirements for the use of mobile cranes based upon the OSHA regulations and industry best practices.

BHI is committed to providing a safe working environment for our employees and subcontractors. Therefore, we have established requirements for the use of signaling during mobile crane use based upon the OSHA regulations and industry best practices.

A majority of BHI projects require work from elevated positions and transporting materials that require load securement. The purpose of this policy is for the control and prevention of dropped objects and to prevent personal injury and illness to our employees and subcontractors.

See GOM 100-6 Drug and Alcohol

We recognize our employees may be exposed to the hazards associated with electricity. It is our policy to eliminate these hazards before work begins.

BHI is committed to providing a safe and healthy workplace for all its employees. This Emergency Response Plan has been developed to ensure that procedures are in place for the proper disposition of man-made or natural emergencies. The Emergency Response Plan is intended to reduce personal injury, protect company property, client property, minimize production losses, and protect the environment.

All BHI employees working for specific clients are expected to know and follow their emergency response plan as well as participate in their emergency response drills.

Site specific emergency response plans are reflected in the project execution plan.

A majority of BHI projects require excavations and the purpose of this policy is to prevent personal injury and illness to our employees and subcontractors. All excavations will be performed in accordance with the current OSHA regulations and industry best practices. All employees that are required to work around excavations will receive the proper initial training and annual training thereafter. The requirements in this Appendix will be satisfied before an employee is allowed to enter an excavation, for any reason, or at any time

BHI is committed to providing a safe and healthy workplace. Workers exposed to fall hazards must be provided with adequate fall protection. This policy states our requirements for workers who are exposed to this risk.

BHI is committed to providing a safe and healthy environment for all employees. Well rested employees with adequate balance between work and personal life are safer, healthier, and enjoy a higher quality of life. In order to provide a safe work environment, employees must be able to perform their job tasks in a safe, productive and effective manner, and remain able to do so for their scheduled work shift.

Shift work beyond 14 hours increases safety risk, decreases production capacity, and decreases assurance of quality – decreasing probability we will achieve our KPIs and therefore should be avoided.

Any employee working 13 days in a row, regardless of average hours per day, will be required to take a day off.

All employees shall meet the following requirements for managing the risks associated with fatigue.

All clients’ job site safety requirements will be followed unless they do not meet the safety requirements of BHI, in which case, the most stringent guidelines will be followed.

BHI is committed to providing a safe and healthy work place for all its employees. When an employee is injured, his/her immediate well-being is top priority. Providing first aid supplies, personnel training in First Aid/CPR, and having access to medical care are necessary to protect the health and well-being of the injured employee.

All employees must successfully complete a training program, and receive certification prior to the operation of any forklift (powered industrial truck). Forklifts shall be operated, maintained, and controlled in a safe manner.

BHI is committed to providing a safe and healthy workplace for all its employees. Gas monitoring instruments are designed to protect personnel from unseen hazards that may exist in workplace environments. It is vital to worker safety that these instruments are maintained and properly calibrated. It is essential that all employees are aware of Gas Hazards they could encounter in the industries that we serve.

BHI is committed to providing a safe and healthy work environment for all employees. In pursuit of this goal, BHI will comply with all applicable legislation and other relevant requirements associated with our environmental aspects and impacts. The company is committed to the continual improvement of all environmental aspects and impacts associated with our operations.

BHI is committed to the prevention of pollution in all aspects of business activities, and a sustainable approach to the development and provision of services will be adopted where possible. BHI is dedicated to these high environmental standards and expect all employees to be familiar with and comply with the contents of this policy.

BHI is committed to providing a safe and healthy workplace. Hand and power tools are very important in our day to day work and it is imperative that all tools are used properly, safely and in accordance with all manufacturers’ guidelines.

All and any type of injury/incident/near misses shall be reported immediately to supervisor and under no circumstances to exceed the end of the shift in which he/she is working.

Supervisor investigates and determines the severity of the injury/incident immediately.

Supervisor reports injury/incident to on-site management, on-site management reports to client per their reporting criteria.

On-site management reports injury/incident to the Director of EHS.

Director of EHS determines if incident requires Axiom Medical for management of case. If Axiom is needed the employee and his supervisor are to contact Axiom at 1-877-502-9466.

Employee and Supervisor to complete incident report by the end of the shift.

All incidents, regardless of size and impact including fatalities, injuries, illness, and near misses, shall be investigated to the appropriate level with regards to the incident severity. All recordable incidents shall be investigated using the tap root process.

BHI is committed to providing a safe and healthy work place for all employees. BHI realizes that hazardous materials used in the work place create an additional risk to workers. Hazardous waste is exempt from the requirements of the OSHA Hazard Communication Rule. However, BHI believes all employees have the right to know about the dangers associated with hazardous materials or wastes they might encounter.

BHI is committed to providing a safe and healthy workplace for all its employees. Under the authority of Section 126 of the Superfund Amendments and Reauthorization Act of 1986 (SARA), the EPA and OSHA jointly established identical health and safety regulations to protect workers engaged in hazardous waste operations and emergency response operations without regard to location.

This policy is to establish a procedure for hearing conservation at BHI fixed facility sites. BHI is committed to providing its employees a safe and healthy workplace. The Hearing Conservation Program (HCP) is based upon employee’s noise exposure. OSHA has determined that if an employee’s exposure equals or exceeds the “Action Level” during any work shift, the employee must be enrolled in a HCP. The “Action Level” is defined as an 8-hour time-weighted average (TWA) sound level of 85 dBA integrating all sound levels from 80 dBA to at least 130 dBA. This Program is applicable only to employees enrolled in it.

This policy is to establish a procedure for heat stress management at BHI fixed facility sites. BHI is committed to providing its employees a safe and healthy workplace. Heat stress may occur when the body is exposed to high temperatures in the work environment and can result in a number of occupational illnesses. BHI is committed to provide training and resources to all employees in order to ensure that risk factors contributing to heat stress are recognized in the workplace and that those risk factors are mitigated.

This hot work policy and permit system has been developed in accordance with BHl's Health and Safety Policy. It is the policy of BHI to prevent accidents, fires and explosions that might result from tasks involving hot work. This policy applies to all BHI employees, its subcontractors and all job sites.

a. BHI's is committed to providing a safe and healthy workplace. Therefore, we have developed the following guidelines to minimize the potential for accidents. Keeping our work areas neat and clean is essential for running our day to day business.

BHI is committed to providing a safe and healthy workplace for all its employees. Hydrogen Sulfide (H2S) awareness is essential to the safety of our employees. It is the policy of BHI to minimize the risk associated with H2S exposure by following the regulations and utilizing industry best practices.

BHI is committed to providing a safe and healthy workplace. A job safety analysis (JSA) is to be conducted prior to each job. The JSA is a procedure which helps integrate accepted safety and health principles and practices into a particular task or job operation. In a JSA, each basic step of the job is to be identified, potential hazards identified and preventative measures identified to overcome these hazards prior to the commencement of work activities.

This policy is to establish a procedure to prevent security breaches/incidents at all BHI offices and Client job sites.

All of BHI’s projects require driving from point A to B and various places in between. The intent of this program is to monitor trips that are outside of our normal everyday scope to ensure our employees arrive and return safely from their scheduled destinations.

BHI is committed to providing a safe working environment for our employees and subcontractors. Therefore, we have established requirements for the use of ladders at our job sites. It is the intent of this policy to comply with all OSHA regulations that apply to the use of this equipment.

The purpose of this procedure is to identify the controls and actions necessary to prevent adverse health effects to employees from occupational exposure to lead, and to ensure that BHI lead exposure management practices meet regulatory requirements.

Due to the hazards associated with lighting, work activities on site will be adjusted per instructions below based on distance of lightning from the jobsite. All site personnel shall adhere to these instructions.

These requirements are established to prevent injuries to employees and/or damage to property resulting from accidental start- up, energy release, and material flow while servicing machinery, equipment or electrical circuits and components. The requirements listed within this document pertain to all employees, divisions, and departments that either apply individual personal locks/tags or as a group utilize a lock box.

BHI is committed to providing a safe and healthy workplace. We realize that improper handling of construction materials could result in accidents. We have developed the following guidelines to minimize the potential for accidents while handling materials manually.

BHI is committed to providing a safe and healthy workplace. We realize that improper handling of construction materials could result in accidents. We have developed the following guidelines to minimize the potential for accidents while handling materials.

BHI is committed to providing a safe working environment for our employees and subcontractors. Therefore, we have established requirements for operating mechanical equipment near overhead lines based upon the OSHA regulations and industry best practices.

The purpose of this Policy is to ensure that BHI personnel who operate aerial or scissor lifts have the knowledge and tools to work safely. This policy applies to all B H, Inc owned or rented aerial lifts and scissor lifts designed to elevate personnel on a platform. These lifts are propelled by a powered lifting device, with the controls located on the platform itself. It applies to any department that owns or rents the equipment and the employees or students who use them. All employees must successfully complete a training program and receive certification prior to the operation of any aerial lift. Aerial lifts shall be operated, maintained, and controlled in a safe manner.

All employees must successfully complete a training program and receive certification prior to the operation of any mobile equipment. Mobile equipment shall be operated, maintained, and controlled in a safe manner.

BHI is committed to providing a safe and healthy workplace for all of its employees. This safety program concerning Natural Occurring Radioactive Material (NORM) has been developed to aid our employees and subcontractors that may be exposed to NORM.

BHI is committed to providing our employees with a safe and healthy workplace. These guidelines have been established to aid in preventing potential injuries to employees whenever work is to be performed on or near exposed energized parts. Safety-related work practices shall be employed to prevent electric shock or other injuries resulting from either direct or indirect electrical contact. The specific safety-related work practices must be consistent with the nature and extent of the associated electrical hazards. The guidelines listed within this document are considered to be the minimum guidelines to be followed.

BHI is committed to providing a safe and healthy workplace; therefore, we have developed the following guidelines to minimize the potential for accidents while working at our office buildings.

Appropriate Personal Protective Equipment (PPE) including clothing shall be worn as specified by compliance laws, rules, or regulations specific to job requirements. PPE is selected based upon specific hazards due to process and /or the environment to protect body parts from inhalation, absorption, or physical contact.

BHI recognizes working conditions may exist that potentially expose employees to respiratory hazards. It is the policy of SHI to comply with all OSHA regulations regarding the use of respirators.

In order to increase safety awareness and prevent accidents, all field employees will participate in a weekly safety meeting as a means to train on common or specific hazards, inform on current trends and prevent accidents. At a minimum the specific topic assigned by the EHS Department will be covered.

The meetings should be held in small groups and be led by the department head, appropriate supervisor, safety director, safety manager, hourly employee or combination of any or all.

Attendance will be documented via BHI Relay Application or Form 350-20 Safety Meeting Sign-in Sheet

BHI is committed to providing a safe working environment for our employees and subcontractors. We have established requirements for the use of scaffolding at our job sites. It is the intent of this policy to comply with industry best practices and OSHA regulations that apply to the use of this equipment.

Short Service Employee (SSE): a new hire who requires deliberate training, education, and coaching to learn our company culture and policies.

SSE Mentor: a supervisor who is assigned and responsible to orient, teach, coach, and evaluate an SSE.

SSE Administrative Tech: the individual(s) within HR internally tasked with official notifications and enrollments of SSEs and SSE Mentors into this program; entry of completion dates, and closing out the documentation required by this program.

BHI is committed to providing a safe and healthy workplace. This Written Exposure Policy applies to all BHI personnel who are potentially exposed to airborne concentrations of respirable crystalline silica due to their work activities or proximity to the work locations where the exposure to airborne concentrations of silica are at or above regulatory and industry levels and exposure limits

BHI is committed to providing a safe and healthy workplace for all employees. We promote Site Safety Assessment practices which are random surveys of the work environment and take a comprehensive look at the job sites and the ongoing tasks. We believe in the proactive verification that our safety policies, standards, and practices are being followed and in the searching for hazardous conditions to correct or eliminate them before they result in a near miss or accident.

BHI is committed to providing a safe and healthy workplace for all its employees. This spill prevention and response plan has been developed to aid our employees in the event of an accidental release of a hazardous substance.

BHI is committed to providing a safe and healthy workplace for all employees and subcontractors. In order to provide a safe work environment, subcontractors and sub-tier contractors must be preapproved to work for BHI. Their safety metrics must be acceptable and their EHS programs must align with that of BHI.

BHI is committed to providing a safe working environment for our employees and subcontractors. Therefore, we have established requirements for working on or near Vacuum trucks upon the OSHA regulations and industry best practices.