1) Ensuring that a BHI health and safety policy is in place and reviewed at least annually.

(2) Issuing and communicating a corporate health and safety policy statement.

(3) Insisting that all activities are expected to be unconditionally carried out safely and in accordance with the health and safety policy.

(4) Demonstrating a high personal example of health and safety standards.

(5) Reinforcing the importance of positive health and safety behavior at all levels of the organization.

(1) Overall health and safety performance of BHI operations under his authority.

(2) Ensuring that a BHI health and safety policy is in place and reviewed at least annually.

(3) Issuing and communicating a corporate health and safety policy statement.

(4) Providing adequate financial resources for the effective management of health and safety.

(5) Insisting that all activities are expected to be unconditionally carried out safely and in accordance with the health and safety policy.

(6) The establishment of clear and measurable safety objectives and to periodically review and report progress toward meeting those objectives.

(7) Ensuring that senior managers are aware of and expected to meet their health and safety responsibilities, targets and objectives.

(8) Ensuring that a process is in place to implement and monitor the effectiveness of the SMS.

(9) Taking prompt action to correct unsafe behaviors and conditions.

(10) Demonstrating a high personal example of health and safety standards.

(11) Reinforcing the importance of positive health and safety behavior at all levels of the organization.

(1) Consulting with the Chief Operating Officer on matters concerning health and safety.

(2) Providing health and safety management advice and assistance for all divisions.

(3) Developing and implementing the health and safety policy.

(4) Defining specific roles and responsibilities to effectively manage health and safety for all divisions. e. Assisting in the establishment of clear, measurable safety goals for all divisions and for periodically reviewing and reporting progress towards these goals.

(5) Developing and implementing a comprehensive SMS.

(6) Coordinating and implementing audits for compliance with the BHI, SMS.

(7) Coordinating and implementing health, safety, security, and loss control policies and practices for all divisions.

(8) Coordinating the health and safety objectives of each division and to incorporate relevant health and safety performance targets into the operating plans.

(9) Keeping up-to-date with and providing advice on governmental regulations, statutory issues, professional/technical developments and best industry practices associated with health and safety.

(10) Being familiar with the provisions of the OSHA and MSHA Health and Safety Acts, federal mining and state mining regulations, and BHI policies and procedures. Review at least annually new OSHA & MSHA regulations that pertain to our industry.

(11) Assisting as necessary all investigations of accidents, incidents, near misses and property damage that occur at our operation and on client properties.

(12) Assisting as necessary to incorporate health and safety considerations during the specification, design and procurement of equipment and materials.

(13) Assisting as necessary to ensure that hazards and risks are systematically identified, assessed and controlled in accordance with the SMS.

(14) Coordinating the safety recognition program to encourage consistency throughout the operation.

(15) Interacting with governmental agencies to coordinate activities that promote best interests in relation to health and safety issues.

(16) Taking prompt action to correct unsafe behaviors and conditions.

(17) Demonstrating a high personal example of health and safety standards.

(18) Reinforcing the importance of positive health and safety behavior at all levels of the organization.

(1) Overall health and safety performance for the divisions under his / her authority.

(2) Ensuring the implementation, communication, and endorsement of the health and safety policy.

(3) Issuing and communicating the safety policy statement.

(4) Providing adequate financial resources for the effective management of health and safety.

(5) Ensuring that all activities are expected to be unconditionally carried out safely and in accordance with the health and safety policy.

(6) Developing roles and responsibilities and clear measurable safety objectives and to periodically review and report progress toward meeting those objectives.

(7) Ensuring that a process is in place to implement and monitor the effectiveness of the SMS.

(8) Ensuring that all managers are aware of and expected to meet their responsibilities, targets and objectives.

(9) Taking prompt action to correct unsafe behaviors and conditions.

(10) Demonstrating a high personal example of health and safety standards.

(11) Reinforcing the importance of positive health and safety behavior at all levels of the organization.

(1) Consulting with the Vice Presidents & Area Managers in matters concerning health and safety.

(2) Providing health and safety management advise.

(3) Maintaining communication with the managers, employees and VP of EHS on health and safety issues.

(4) Endorsing and communicating the BHI health and safety policy.

(5) Fulfilling roles and responsibilities and meeting safety objectives for their area of responsibility and to periodically review and report progress toward meeting those objectives.

(6) Ensuring that their direct reports are aware of and expected to meet their responsibilities, targets and objectives.

(7) Assisting in the establishment of clear, measurable health and safety objectives for the operation and periodically reviewing and reporting on progress towards those objectives.

(8) Coordinating and implementing health and safety, security and loss control policies and practices at the operation.

(9) Being familiar with the provisions of the OSHA and MSHA Health and Safety Acts, federal mining and state mining regulations, and BHI policies and procedures. Review at least annually new OSHA & MSHA regulations that pertain to our industry.

(10) Monitoring compliance with rules and regulations.

(11) Developing and implementing training programs for OSHA/MSHA compliance and other training to improve health and safety skills and competency of all employees at the operation.

(12) Keeping up-to-date with and providing advice on applicable governmental regulations, statutory issues, professional/technical developments and best industry practice associated with health and safety.

(13) Assisting as necessary in all investigations of accidents, incidents, near misses and property damage.

(14) Assisting as necessary in considering health and safety issues during the specification, design and procurement of equipment and materials.

(15) Assisting as necessary to ensure that hazards and risks are systematically identified, assessed and controlled in accordance with the SMS.

(16) Assisting with the safety recognition program.

(17) Taking prompt action to correct unsafe behaviors and conditions.

(18) Demonstrating a high personal example of health and safety standards.

(19) Reinforcing the importance of positive health and safety behavior at all levels of the organization.

(1) Ensuring the implementation, communication, and endorsement of the health and safety policy.

(2) Being familiar with the provisions of the OSHA and MSHA Health and Safety Acts, federal and state regulations as they apply to work areas under their control.

(3) Ensuring that all activities are expected to be unconditionally carried out safely and in accordance with the health and safety policy.

(4) Fulfilling roles and responsibilities and meeting safety objectives for the area of their responsibility and to periodically review and report progress toward meeting those objectives.

(5) Ensuring that their direct reports are aware of and expected to meet their responsibilities and to periodically review and report progress toward meeting those objectives.

(6) Conducting activities to fulfill requirements of the SMS in their areas of responsibility.

(7) Encouraging employees to report unsafe or unhealthful actions or behaviors.

(8) Seeking suggestions from employees for improvement in workplace health and safety conditions.

(9) Taking prompt action to correct unsafe or unhealthful actions or behaviors.

(10) Demonstrating a high personal example of health and safety standards.

(11) Reinforcing the importance of positive health and safety behavior at all levels of the organization.

(1) Ensuring the work areas and equipment do not expose employees or members of the public to risks to their health and safety.

2) Being familiar with the provisions of the OSHA and MSHA Health and Safety Acts, and federal and state regulations as they apply to work areas under their control.

(3) Ensuring that all activities are expected to be unconditionally carried out safely and in accordance with the health and safety policy.

(4) Fulfilling roles and responsibilities and meeting safety objectives for the area of their responsibility and to periodically review and report progress toward meeting those objectives.

(5) Conducting activities in the areas of their responsibility to fulfill requirements of the SMS.

(6) Encouraging employees to report unsafe or unhealthful conditions.

(7) Seeking suggestions from employees for improvement in workplace health and safety conditions.

(8) Ensuring that all accidents, incidents, near miss incidents and dangerous occurrences are properly investigated and reported in accordance with plant procedures.

(9) Ensuring that all assigned duties are conducted in compliance with all relevant internal safety work rules and all external safety and health laws and regulations.

(10) Ensuring that all employees receive adequate health and safety training and that training is recorded.

(11) Taking prompt action to correct unsafe or unhealthful actions or behaviors.

(12) Demonstrating a high personal example of health and safety standards.

(13) Reinforcing the importance of positive health and safety behavior at all levels of the organization.

(1) Ensuring the work areas and equipment do not expose employees, client employees or members of the public to risks to their health and safety.

(2) Following all provisions of the BHI, SMS and health and safety policy.

(3) Cooperating with others so that duties are fulfilled in a safe manner.

(4) Complying with safety rules and procedures and taking positive steps to understand the risks in the workplace.

(5) Performing only the tasks that they have the necessary authority and competency to carry out.

(6) Complying with all provisions of the BHI, health and safety work rules and other applicable health and safety regulations.

(7) Using PPE and other equipment properly when provided for the purpose of enhancing health and safety in the workplace.

(8) Reporting any accident, incident, near miss or damage to property as soon thereafter as is reasonably practicable.

(9) Reporting to their immediate supervisor any hazardous condition or work activity that presents potential of danger to themselves or others.

(10) Participating in safety and health training courses and applying knowledge, skills and techniques acquired in such courses.

(11) Taking an active and personal interest in promoting health and safety while at work.

(12) Taking prompt action to correct unsafe behaviors and conditions.

Safety excellence begins with the commitment and leadership of management. This commitment must be demonstrated through high visibility, participation in daily safety activities and encouragement of employee participation in health and safety endeavors. In addition, managers must personally demonstrate all desired health and safety behaviors. Managers are the leaders of health and safety and are responsible for meeting high performance standards as well as equally high standards for health and safety excellence. Managers must regard the health and safety of employees as a fundamental value of the organization and apply its commitment to health and safety equally with other organizational drivers.

(1) Actions and Objectives.

• Establish and communicate a health and safety policy statement that sets clear expectations regarding safe and healthful work practices and conditions.

• Regard the occupational health and safety of employees as the priority of the organization.

• Ensure that nothing supersedes safe work practices even when responding in a crisis situation.

• Require that managers encourage active participation of employees in the SMS.

• Require managers and supervisors to demonstrate their commitment to health and safety by unconditionally meeting daily health and safety obligations.

• Ensure that positive health and safety behaviors are recognized, acknowledged and praised at all levels.

• Require that Vice Presidents be visible to employees by being present in work areas on a regular basis.

• Require Vice Presidents to participate regularly in safety meetings and to conduct one on one safety contacts with employees.

• Ensure that all management actions demonstrate commitment to integrate the provisions and requirements of the SMS into the business processes and activities

Clear health and safety performance goals must be established so all members of the organization understand the program objectives. Safety performance indicators must be monitored, and the outcome communicated frequently to all employees involved. Personal activity-based goals should be used to the widest extent possible to maximize effort and minimize loss. Performance appraisal systems must measure and hold all managers and supervisors accountable for the safety performance of their divisions. Responsibility for all aspects of the safety program must be assigned and communicated so that managers and supervisors fully understand what is expected of them, as well as the results expected from their work groups.

(1) Actions and Objectives.

• Ensure that roles and responsibilities for health and safety are clearly defined and communicated for all positions in the organization.

• Establish an accountability system to hold employees accountable at all levels of the organization accountable for performance of health and safety responsibilities.

• Establish goals and objectivities that are aligned throughout the organization to drive step change improvements in health and safety performance.

• Ensure that key performance indicators, OSHA/MSHA reportable incident rates and lost time frequency rates are closely monitored, reported and communicated on a regular basis.

• Require that objectives for managers include personal upstream performance-oriented activities that encourage improved health and safety performance in their area of responsibility.

• Require that a performance appraisal process be in place that includes periodic reviews to measure performance against stated objectives.

Successful health and safety measurement programs require the placement of enough professional personnel to serve as program catalysts to control accidents, injuries, occupational disease and property damage. Sufficient numbers of professional safety personnel must be employed to provide services and technical support necessary for effective administration of the health and safety program.

(1) Actions and Objectives.

• Ensure that adequate professional health and safety staffing exists to support the management of the health and safety program.

• Provide and encourage sufficient time for health and safety professionals to effectively execute their health and safety responsibilities.

• Provide resources necessary to ensure that health and safety professionals are qualified and adequately trained to successfully perform their health and safety roles and responsibilities.

(1) It is critically important that BHI strive to comply with all regulatory health and safety requirements. A program must be in place that provides for well managed regulatory agency inspections. This program must create a cooperative relationship with agency personnel, provide for a careful overview of inspection activities and insure that the company has the necessary information to effectively exercise its right to appeal. Trained on-site personnel must be available to interface with compliance officers throughout the inspection process.

(2) A system must also be in place to develop health and safety rules and procedures to protect against hazards and risks that must be controlled. Employees must be trained on and expected to comply with the rules and procedures. It is essential that managers, supervisors and employees understand and enforce compliance with rules and procedures at all times.

(3) Actions and Objectives.

• Encourage compliance specialists to conduct a pre-inspection meeting that includes safety personnel, senior managers and hourly employees. This meeting should be held prior to the beginning of each regulatory inspection. Discussion items should include current plant issues, previous inspection results, incident data, current regulatory agency issues and expectations.

• Require that all regulatory health and safety inspections involve a BHI representative.

• Ensure that all deficiencies discovered during regulatory activities are corrected or addressed in an expedient manner.

• Employees must understand that working safely and in compliance with rules and procedures is a condition of employment, and that their actions must not create hazards or risks to themselves or their co-workers.

• Employees must have the responsibility to report deficiencies in rules and procedures as soon as these deficiencies become known to them.

• There must be a periodic review of rules and procedures. Deficiencies in such rules and procedures or necessary changes will be made when they become known.

The management of risk is one of the cornerstones of any health and safety management system. Procedures must be in place to continually and systematically assess new, existing and potential risk. In addition, identify, create and implement suitable control measures to effectively manage those risks.

(1) Actions and Objectives.

• Establish activities to encourage reporting of hazards by all employees as well as the identification of solutions to eliminate or control such hazards.

• Establish a system to insure timely correction and a means to track corrective actions to completion.

• Ensure that all mandatory inspections are conducted and results documented as required and that findings and recommendations are communicated to affected employees.

• Ensure that management and hourly employees involved in inspections are trained in hazard recognition and control techniques.

• Ensure that managers and supervisors are held accountable to insure that inspections are conducted properly and that corrective actions are completed in a timely manner.

• Provide for oversight by trained occupational health professionals to systematically evaluate employee exposures and control strategies.

• Ensure that exposures to chemical, physical and biological agents in excess of current recommended values are given high priority for corrective action using a hierarchy of engineering controls, administrative controls, and PPE.

Communication is an integral element of an effective SMS. Management is responsible to communicate expectations, provide general information regarding health and safety and provide guidance to its employees. Employees communicate to raise issues for review, make suggestions and provide feedback regarding clarity of management’s communication. This element of safety management must establish how management will communicate, how employee input will be obtained, and how the communication system will be enhanced to maximize the value and timeliness of information.

(1) Actions and Objectives.

• Require division managers to participate in processes at least quarterly to discuss health, safety and other issues with their employees.

• Procedures must be in place for employee reporting of safety issues and concerns without fear of reprisal and which also includes a process for management to respond and provide timely feedback about corrective actions.

• Procedures must be in place to communicate objectives, injury trends, incident prevention activities, opportunities for improvement, successes and other relevant health and safety information. This information must be shared between divisions to include all employees.

• Effective means to communicate must be used, such as employee safety meetings, newsletters, payroll stuffers, and one on one contacts. This information must include a wide variety of topics and formats to keep employees updated and interested in current safety issues.

• Information stating safe/healthful work practices such as safe job guidelines, employee health and safety manual must be openly communicated and actively monitored for compliance.

• Communications must include information to ensure that all employees understand the status of current employee work groups, such as safety committees/teams and others.

• Establish communications with similar industries to ensure that industry-wide issues are identified and, when necessary communicated to employees.

An effective SMS requires participation of employees at all levels of the organization. Employees must be encouraged to provide input into the administration of the health and safety program and the decisions that affect their health and safety. Management must consistently focus employee interest and attention on positive safety performance through employee involvement programs. Consistent management emphasis on employee involvement will encourage employees to develop and express their commitment. By providing for and encouraging employee involvement in the health and safety program, and in decisions that affect health and safety, a tremendous resource can be utilized to achieve program goals and objectives.

(1) Actions and Objectives.

• Employees must be encouraged not to participate in at-risk behavior or to shut down work activity or equipment, when appropriate, without fear of being criticized or disciplined.

• Employees must be actively involved in identifying solutions to health and safety concerns and problems.

• Employees must be encouraged to participate in pro-active activities to prevent accidents and improve health and safety performance. Activities include: Analyzing jobs to identify hazards and develop safe work procedures (JSA). Inspecting for hazards and at-risk behaviors and recommending corrective actions or controls. Training new employees in safe work practices Participation in accident investigation activities Active involvement in training processes. Active participation in ad-hoc problem solving processes such as safety committees/teams, safety task forces, etc. Participation in on-site and corporate inspections and audits. (Site Safety Inspection) Active involvement and participation in the safety meeting process. Active involvement on emergency response team (Tower Rescue).

Effective investigation of incidents is an integral component of a successful SMS. Investigation of incidents must be directed at identifying all root causes, causal factors and corrective measures to prevent recurrence. A team that includes relevant personnel, including the person(s) involved in the incident must conduct incident investigations. In addition, a corporate inquiry must be conducted when deemed necessary in the event of very serious incidents. Comprehensive procedures should include the investigation of “near miss” incidents to further reduce losses and improve overall health and safety performance.

(1) Actions and Objectives.

• Procedures for incident investigation and analysis must be well defined, followed consistently and understood by all employees.

• Investigation must be conducted to determine facts and not to find blame.

• The investigation process must be effective at identifying the root causes and appropriate preventive measures for all incidents including near miss occurrences.

• A system must be in place to ensure timely action and accountability and which tracks preventive actions to completion.

• Incident investigations must demonstrate actions that encourage employees to agree that the investigation process is effective in identifying root cause(s) and appropriate preventive measures.

• Findings and recommendations of all investigations must be well documented and shared with all affected employees.

• Managers and hourly personnel involved in incident investigations must be trained in the incident investigation techniques.

• Incident reports must be evaluated for accuracy, completeness, and quality prior to finalization.

• Employees must be educated in the importance of reporting near-miss and minor first-aid incidents.

To minimize employee injury and property damage, a written plan must be developed and implemented to ensure prompt and adequate response to site specific emergencies. Training and drills must be conducted to guarantee that proper employee response to emergencies will be second nature. Facilities must maintain adequate first aid supplies and other necessary first-response equipment. Qualified, trained first response personnel must be available to provide quality treatment of injuries.

(1) Actions and Objectives.

• Documented emergency response plans must be developed and implemented that address all necessary components of emergency preparedness.

• Drills must be conducted periodically to provide employees the opportunities to practice various components of the emergency response plan.

• A detailed medical assistance program must be developed that provides assurance that necessary personnel respond effectively to medical emergencies. The program must also provide assurance of the availability of necessary professional emergency response and medical care providers.

• Emergency response training must be made available on a regular basis for management and hourly personnel that have critical roles defined in the emergency response plan.

Quality reviews of health and safety programs and facilities must be conducted periodically to assure that operating practices continue to meet or exceed regulations, industry standards, corporate guidelines and company rules. Safety performance audits are an essential component of a successful safety program. Inspections by supervisors, safety committees/team and employees must be conducted to ensure that hazards are discovered and controlled in a timely manner. Audits and inspections serve to improve a company’s overall safety performance by identifying and eliminating potential hazards.

(1) Actions and Objectives.

• A comprehensive audit of the safety management process should be conducted annually under the direction of the corporate EHS director.

• Planned inspections involving systematic examinations of facilities, equipment, tools, materials and employee behaviors must be conducted on a regular basis.

• Issues and problems defined by inspections must be documented and corrective actions tracked to completion.

Processes must be in place to minimize risk to health of employees by identifying, evaluation and controlling potential health risks. Together with periodic exposure monitoring, health surveillance must be provided for employees who are potentially exposed to risk to ensure that controls are effective in mitigating the risk.

(1) Actions and Objectives.

• Employee health management will be carried out in compliance with applicable regulations.

• When potential health risks are identified, suitable control measures will be implemented. These will be in the form of engineering controls, administrative controls or by providing appropriate personal protective equipment (PPE). The effectiveness of control measures must be regularly evaluated.

• The level of risk and potential impact on employees will be evaluated by using a combination of industrial hygiene evaluation and medical screening techniques.

• A comprehensive Hazard Communication Program must be in place and followed .

• Return to work programs will be implemented to ensure that employees that become injured or ill on or off the job return as quickly as possible, in accordance with medical restrictions and job requirement.

Contractors working on BHI projects must operate within the boundaries of a comprehensive Contractor Safety Management Plan. The plan must be developed by the operator and used as the basis for an effective health and safety contractor management program. Contractor safety program components and verification requirements must be in writing and be proportional to the scope and duration of contractor operations.

(1) Actions and Objectives.

• Contractors working on BHI projects will be subject to stringent health and safety provisions as defined in the Contractor Health and Safety Program.

Performance measurement is an integral component in achieving health and safety excellence. The SMS must be continuously evaluated to ensure the system is improving. The SMS should be reviewed periodically to ensure its continuing suitability, adequacy and effectiveness.

(1) Actions and Objectives.

• A periodic review of the effectiveness of the SMS will be conducted tracking and evaluation of key performance indicators (trailing indicators) and selected relevant methods to measure safety activities (leading indicators). The information will be utilized to identify opportunities for improving the SMS.