Injury and Illness Prevention Program

PURPOSE

The purpose of this program is to ensure a safe and healthy environment within SkyVine ITAD’s facility.

RESPONSIBILITIES

The EH&S Manager has the authority and the responsibility for implementing and maintaining this Injury and Illness Prevention (IIP) Program at SkyVine ITAD.

Managers and supervisors are responsible for implementing and maintaining the IIP Program in their work areas and for answering worker questions about the IIP Program. A copy of this IIP Program is available from each manager and supervisor.

COMPLIANCE

All workers, including managers and supervisors, are responsible for complying with safe and healthful work practices. Our system of ensuring that all workers comply with these practices include:

• Informing workers of the provisions of our IIP Program.

• Evaluating the safety performance of all workers.

• Recognizing employees who perform safe and healthful work practices

• Providing training to workers whose safety performance is deficient.

• Disciplining workers for failure to comply with safe and healthful work practices.

COMMUNICATION

All managers and supervisors are responsible for communicating with all workers about occupational safety and health in a form readily understandable by all workers. Our communication system encourages all workers to inform their managers and supervisors about workplace hazards without fear of reprisal.

Our communication system includes:

• New worker orientation including a discussion of safety and health policies and procedures.

• Review of our IIP Program.

• Training programs.

• Regularly scheduled safety meetings.

• Posted or distributed safety information.

• A system for workers to anonymously inform management about workplace hazards.

HAZARD ASSESSMENT

Periodic inspections to identify and evaluate workplace hazards are performed by a competent observer in the following areas of our workplace:

Periodic inspections are performed according to the following schedule:

1. When we initially established our IIP Program.

2. When new substances, processes, procedures or equipment which present potential new hazards are introduced into our workplace;

3. When new, previously unidentified hazards are recognized;

4. When occupational injuries and illnesses occur; and

5. Whenever workplace conditions warrant an inspection.

ACCIDENT/EXPOSURE INVESTIGATIONS

Procedures for investigating workplace accidents and hazardous substance exposures include:

1. Interviewing injured workers and witnesses;

2. Examining the workplace for factors associated with the accident/exposure;

3. Determining the cause of the accident/exposure;

4. Taking corrective action to prevent the accident/exposure from reoccurring; and

5. Recording the findings and actions taken.

HAZARD CORRECTION

Unsafe or unhealthy work conditions, practices or procedures are corrected in a timely manner based on the severity of the hazards. Hazards are corrected according to the following procedures:

1. When observed or discovered; and

2. When an imminent hazard exists, which cannot be immediately abated without endangering employee(s) and/or property, we will remove all exposed workers from the area except those necessary to correct the existing condition. Workers who are required to correct the hazardous condition are provided with the necessary protection.

TRAINING AND INSTRUCTION

All workers, including managers and supervisors, have training and instruction on general and job-specific safety and health practices. Training and instruction is provided:

1. When the IIP Program is first established;

2. To all new workers,

3. To all workers given new job assignments for which training has not previously provided;

4. Whenever new substances, processes, procedures or equipment are introduced to the workplace and represent a new hazard;

5. Whenever the employer is made aware of a new or previously unrecognized hazard;

6. To supervisors to familiarize them with the safety and health hazards to which workers under their immediate direction and control may be exposed; and

7. To all workers with respect to hazards specific to each employee's job assignment.

General workplace safety and health practices include, but are not limited to, the following:

1. Implementation and maintenance of the IIP Program.

2. Emergency action and fire prevention plan.

3. Provisions for medical services and first aid including emergency procedures.

4. Prevention of musculoskeletal disorders, including proper lifting techniques.

5. Proper housekeeping, such as keeping stairways and aisles clear, work areas neat and orderly, and promptly cleaning up spills.

6. Prohibiting horseplay, scuffling, or other acts that tend to adversely influence safety.

7. Proper storage to prevent stacking goods in an unstable manner and storing goods against doors, exits, fire extinguishing equipment and electrical panels.

8. Proper reporting of hazards and accidents to supervisors.

9. Hazard communication, including worker awareness of potential chemical hazards, and proper labeling of containers.

10. Proper storage and handling of toxic and hazardous substances including prohibiting eating or storing food and beverages in areas where they can become contaminated.

RECORDKEEPING

Records of hazard assessment and employees training are kept for three years and are the responsibility of the QEH&S Manager.