PURPOSE

The SIMMCO Safety Program utilizes a basic safety plan, which provides guidelines for setting up appropriate accident prevention at the jobsite and plant.  The plan is designed to ensure regulatory compliance, cost containment, and to fulfill our obligation to protect the employees against injury or impairment of health.

INTENT

This document is intended for use as an outline for the SIMMCO Safety Program Safety Process.  Detailed information on any item can be found in the SIMMCO Safety Manual.

COMMITMENT STATEMENT

• SIMMCO is committed to ensuring a safe, injury- and incident-free, healthy, environmentally sound work environment for all employees.
• SIMMCO will continuously improve our safety process by continuous quality improvement through training, safety review, project, and plant involvement.
• SIMMCO will work professionally and ethically as a team to resolve any barriers through communication and quality improvement ideas, which will allow us to achieve the project goals.
• SIMMCO will provide incentives (in the form of rewards and bonuses) as recognition of employee participation and involvement in attaining our safety goals.  The project manager will discuss the implementation of programs and record keeping during weekly safety meetings.

OBJECTIVES AND GOALS

SIMMCOshall strive to improve the Safety and Health programs of all areas and projects on which we are involved. By partnering, open communications, and effective cooperation, we will work together as a team for the achievement of excellence in safety performance.  By sharing information and building a base of knowledge, we can identify and eliminate common exposures.  By our efforts, we will improve the working environment of all our personnel.

Our goal is to have no lost workdays resulting from unsafe practices on any of our jobsites.  We wish to insure the well being of all of our employees, and by constant awareness and enforcement of all safety procedures we can make this goal a reality.

SAFETY PROCESS COMPONENTS

1. Training

Any mandatory training such as hazard communication, hearing conservation, respiratory protection, forklift safety, etc. is given as required by the applicable standards.  Depending on circumstances, training may be given by company safety personnel or by jobsite supervision.

Employee Orientation. 

Prior to beginning all work, all employees should attend a Safety Orientation program. Individual responsibilities and safety regulations and practices should be discussed with each employee.  In addition, each employee shall be required to read the safety regulations and certify their understanding of it by signing the document prior to beginning work.

Chemicals and Hazards. 

In addition to recognizing the normal hazards associated with our work, SIMMCO Contractor Safety Program has developed specific procedures to handle any special chemical hazards that may be encountered.  Personnel are required to review the appropriate Material Safety Data Sheets to ensure that proper protective equipment is available when handling such equipment.

Visitor Training. 

Everyone who performs any work on any site must be properly indoctrinated in our safety goals and policies.  This is accomplished by separate and concise orientation for design people, subcontractors, and other personnel who must enter the site.  The orientation ranges from general site safety for design visitors to more detailed and lengthy orientation for confined space entry or special work requiring specific safety training.

Quality. 

"Doing it right the first time" is ingrained into every employee every day.  This is accomplished by proper planning, proper direction, and proper execution. Safety must be an accepted part of the preparation.

2. Safety Audits

We will perform scheduled and unscheduled safety audits using a combination of safety, craft and management personnel to establish compliance with safety procedures and to gauge progress in our total safety effort.  We must identify negative trends before they become major problems.

3. Accident Investigation

The best way to prevent future incidents is to determine the conditions and events which lead to an incident.  By thoroughly investigating each incident, we can avoid reoccurrence.  Information obtained from these investigations can be distributed to other supervisors and job sites to aid in accident prevention.

4. Safety Topics

We will provide employees with relevant safety materials for Tailgate Safety Meetings, and assure the topics are in line with current safety concerns.  We will make these sessions a learning process.

5. Statistical Analysis

Injuries, incidents, audits, etc. all yield statistical information which, when evaluated, can predict trends that contribute to accidents.  We will continue to ccumulate, use and distribute these numbers to support the safety effort.

6. S.O.S. (Safety Off Site)

An injury is just as devastating whether it occurs at home or on the work site.  Many weekly safety meetings address off the job safety.  The same good habits that apply at work apply everywhere.  Hazards have no boundaries.  Electrical hazards, material handling problems, defective hand tools, and others are confronted  at home as often as on the work site. The same positive safety attitude must apply

POLICY AND SAFETY TOOLS

1.Tennessee Drug-Free Workplace Program

SIMMCO is a certified member of the Tennessee Drug-Free Workplace Program and has adopted a comprehensive drug/alcohol testing program (Pursuant to T.C.A. 50-6-101, et seq.).  This program incorporates various aspects of education, drug and substance abuse awareness, substance detection and employee assistance. The integration of these systems has the goal of eliminating the effects of substance abuse from the work place and providing high quality professional assistance for those employees who may have a problem with drug or substance abuse.

For the purpose of assuring compliance with the Drug/Alcohol Testing Program, employees and applicants for employment are subject to substance screening under the circumstances described below.

Pre-Employment. 

Prior to being placed on the payroll, each applicant will undergo substance screening as part of the pre-employment process.  Refusal to submit to such screening, or a positive screening, will result in termination of the employment process.

Post Accident/Incident. 

Any employee involved in either a job-related accident or a job-related incident, due to an action or lack of action by an employee(s) which did or could have resulted in serious injury or property damage will undergo substance screening.

Random Screening. 

All employees are subject to random and group drug testing for the intent of enforcing the company's Drug/Alcohol Testing Policy.

Search. 

For purpose of assuring compliance with the prohibition of possession of drugs and controlled substances, employees are subject to inspection of the types described below under circumstances defined:

Ø An employee's locker, closet, work area, desk, files, all motor vehicle, and similar areas are subject to such inspection at any time, on a non-discriminating basis. Similarly, an employee's vehicle, lunch box, or other container is subject to such inspection when brought into any work site.

Ø Upon reasonable evidence to suspect a violation of the prohibition on use, possession, distribution, dispensation or manufacture, an employee's wallet, purse, outer clothing, vehicles, or any container, is subject to inspection when brought into any work site.

While focus is on prevention, management has expressly preserved confidentiality and the individual rights of its employees and applicants.  A long-standing employee assistance program is being used in conjunction with the drug and alcohol screening to provide employees with opportunity to volunteer for help.

SUBCONTRACTOR SAFETY

Goals and Expectations. 

Our goals are shared goals.  All subcontractors are expected to follow safety rules specified for their particular task and to strive for safety excellence.

Orientation/Training. 

Subcontract employees are orientated in safety requirements prior to beginning projects on any site.  They are also given safety handouts and alarm information and specialized instruction for confined space, etc., when this training is required to perform work.

Leadership. 

Each subcontractor organization is expected to be proactive in safety, health and environmental concerns with strong support from management.  Supervision that takes initiative to plan safety into projects is essential to a successful program.

Subcontractor Audit. 

In addition to preconstruction participation, rigging planning, or other requirements and procedures, subcontractors will be subject to periodic inspections or evaluations and are expected to cooperate in correcting deficiencies and complying with site, state, and federal regulations.

INSPECTIONS

Periodic Equipment Inspections

The following inspections are required at the specified intervals to ensure said equipment is safe to utilize on our jobsite.  A safety management system shall be developed to ensure timely inspections.  These inspections are to be made by competent persons designated in writing. Responsible persons will have ten days from the completion date of each respective month in which to document the inspection reports. After completing the documented inspection report, please issue a copy of each to the Safety Manager and to David Blurton.  Please review for comments:

Daily Visual Inspections (No records)

• Ladders
• Vehicles / Equipment
• Full Body Harness / Lanyards / Lifelines
• Rigging Equipment, Slings

Monthly Inspections (Written records required)

• Back Hoes
• Come-a-long & Chainfalls
• Drum Hoists (air tugger)
• Forklifts
• Hydraulic Cranes (Cherry Pickers, Drotts, etc.)
• Fire Extinguishers
• Emergency Respiratory Equipment
• Lifting Cranes (Lattice Boom, Cable Cranes)
• Dump Trucks
• Passenger Buses
• Overhead & Gantry Cranes
• Personnel Lifts (JLG, Manlifts, etc.)
• Rigging Equipment & Hardware
• Spyders & Ski-climbers
• Wire Rope & Slings
• Concrete Pump Trucks
• Retractable Reels
• Full Body Harness / Lanyards

Quarterly Inspections

•  Come-a-long / Chainfalls (load tests are required)
• Assured Grounding (all portable plug connected tools
• and extension cords or used/GFI's)
• Ladders

Annual Inspections

•  Fixed Electrical Equipment & Circuits
• Cranes

The Project Managers/Equipment Managers on the jobsite are responsible for ensuring the inspections noted above are performed and written records are prepared and kept on file. The Manager shall ensure that all discrepancies found during inspections are corrected and noted on the Inspection Record.

TRAINING

A. Project Managers/Supervisors shall assure that each of their employees has received training adequate to safely perform their jobs. Employees shall comply with all applicable work practices and all safety and health rules. Employees shall be trained on the specific safety and health hazards, procedures, and safe practices applicable to the employees' job task.

B. Before the start of each work day the foreman and/or supervisor should dedicate a minimum of five minutes reviewing safety issues specific to the job being performed.

C. SIMMCO's training documentation shall comply with the following requirements:

1. Training documentation shall include:

a.     Instructor's name and signature

b.     Instructor's qualifications

c.      Training date and length of training

d.     Employee names and signatures

e.      Course content and outline

2. A method shall be used to document that employees have comprehended the training,
such as a test.

3. Training records shall be retained for a minimum of three years. A copy will be placed in each job file and the original in the Safety
Office file.

D. Supervisors shall train their employees on programs applicable to their job assignments. Training shall include, but not be limited to, the following programs as necessary for their job assignments:

1. Process Overview Training

2. Personal Protection Equipment

3. Injury/Illness Reporting – OSHA Log 200

4. Injury/Illness Prevention

5. Hazard Communication

6. Hearing Conservation

7. Respiratory Protection

8. Emergency Action Plan

9. Hazardous Waste Operation and Emergency Response

10. Lockout and Tagout

11. Confined Space

12. Portable Ladders

13. Portable Fire Extinguishers

14. Fire Prevention Plan

15. Fall Protection

16. Electrical Safety

17. Scaffolding

18. Excavation, Shoring and Trenching

19. Forklift Safety

20. Radiographics

21. Blood-Born Pathogens

22. Benzene

23. Air Contaminants

24. Asbestos

25. Lead

DOCUMENTATION AND REVIEW

Simmco will develop and maintain a formal written safety program with respect to work and / or services being performed that includes: safety, industrial hygiene, emergency situations, and environmental protection.  An annual review of the safety program will be completed and we will strive to maintain the compliance that is equal to or exceeds our customer and OSHA safety standards.