J.F.BRENNAN CO. INC.

HEALTH & SAFETY PLAN

This Health and Safety Plan (HASP) will be kept on the site during field activities and will be reviewed as
necessary. The plan will be amended or revised as project activities or conditions change or when
supplemental information becomes available. The plan adopts, by reference, Code of federal Regulations
29 CFR 1910 & 29 CFR 1926, the Standards of Practice (SOPs) in J.F. Brennan Health and Safety
Program as appropriate. In addition, this plan adopts procedures in the project Work Plan. The Site
Safety Representative (SSR) is to be familiar with these Federal Regulations, SOPs and the contents of
this plan. J.F. Brennan personnel and subcontractors must sign Attachment A-1.

Project Information and Description

PROJECT: MIDLAND, MI:
CLIENT: DOW
PROJECT/SITE NAME: DOW, SEDIMENT REMEDIATION, REACH “D”
SITE ADDRESS: , TITTABAWASSEE RIVER, MIDLAND, MI
J.F.BRENNAN PROJECT MANAGER: MATT BINSFELD
DATE HEALTH AND SAFETY PLAN: 2007
DATE OF SITE WORK: 5/07/2007 – 08/19/2007
SITE SIZE: 1200’ RIVER
SITE TOPOGRAPHY: RIVER BOTTOM,
DESCRIPTION OF SPECIFIC TASKS TO BE PERFORMED:

• Installation of sheet pile wall

• Removal of contaminated sediment through means of hydraulic dredging

Contents
A.1 TASKS TO BE PERFORMED UNDER THIS PLAN ............................................................................................. 4
A.1.1 DESCRIPTION OF TASKS ........................................................................................................................................ 4
A.1.1.1 Employee Orientation .................................................................................................................................. 4
A.1.1.2 Employee Training ....................................................................................................................................... 4
A.1.1.3 HAZWOPER-Regulated Tasks .................................................................................................................. 4
A.1.1.4 Non-HAZWOPER-Regulated Tasks.......................................................................................................... 4
A.1.2 TASK HAZARD ANALYSIS— DREDGING, SHEETING.............................................................................................. 4
A.2 HAZARD CONTROLS................................................................................................................................................ 5
A.2.1 PROJECT SPECIFIC HAZARDS ............................................................................................................................... 5
A.2.1.1 Boating/Barge Operations........................................................................................................................... 5
A.2.1.2 Working on or over Water ........................................................................................................................... 6
A.2.1.3 Cranes, Hoists, and Rigging ....................................................................................................................... 6
A.2.1.4 Rigging........................................................................................................................................................... 6
A.2.1.5 Energized Electrical ..................................................................................................................................... 6
A.2.1.6 Lockout/Tag-out............................................................................................................................................ 7
A.2.1.7 Welding and Cutting..................................................................................................................................... 7
A.2.1.8 Compressed Gas Cylinders........................................................................................................................ 7
A.2.1.9 Fall Protection ............................................................................................................................................... 8
A.2.1.10 Hand Tools .................................................................................................................................................... 8
A.2.1.11 Dioxin Waste Management......................................................................................................................... 9
A.2.2 GENERAL HAZARDS ............................................................................................................................................... 9
A.2.2.1 General Practices and Housekeeping....................................................................................................... 9
A.2.2.2 Hazard Communication............................................................................................................................... 9
A.2.2.3 Shipping and Transportation of Chemical Products................................................................................ 9
A.2.2.4 Lifting.............................................................................................................................................................. 9
A.2.2.5 Fire Prevention ........................................................................................................................................... 10
A.2.2.6 Electrical ...................................................................................................................................................... 10
A.2.2.7 Stairways and Ladders .............................................................................................................................. 10
A.2.2.8 Procedures for Locating Buried Utilities.................................................................................................. 11
A.2.2.9 Vehicle Safety—Operator Safety ............................................................................................................. 11
A.2.2.12 Pressure Washing Operations ................................................................................................................. 12
A.2.2.13 Inclement Weather ......................................................................................................................................... 12
A.2.3 BIOLOGICAL HAZARDS AND CONTROLS .............................................................................................................. 13
A.2.4 CONTAMINANTS OF CONCERN ............................................................................................................................ 13
A.2.5 POTENTIAL ROUTES OF EXPOSURE .................................................................................................................... 13
A.3 LOSS PREVENTION SYSTEM............................................................................................................................... 13
A.3.1 ACTIVITY HAZARD ANALYSIS ............................................................................................................................... 13
A.3.2 PRE-TASK SAFETY PLANS .................................................................................................................................. 14
A.3.3 INCIDENT INVESTIGATIONS .................................................................................................................................. 14
A.4 PROJECT ORGANIZATION AND PERSONNEL................................................................................................ 15
A.4.1 J.F. BRENNAN EMPLOYEE MEDICAL SURVEILLANCE AND TRAINING .............................................................. 15
A.4.1.1 J.F. BRENNAN Employee Responsibilities............................................................................................ 15
A.4.1.2 Progressive Discipline Policy.......................................................................................................................... 16
A.4.1.3 Drug-Free Workplace & Screening Program ...................................................................................................... 17
A.4.2 FIELD TEAM CHAIN OF COMMAND AND COMMUNICATION PROCEDURES .......................................................... 17
A.4.2.2 Health and Safety Director (HSD)............................................................................................................... 18
A.4.2.3 Site Safety Representative (SSR) .............................................................................................................. 18
A.4.2.4 J.F. BRENNAN Subcontractors .................................................................................................................. 19

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 A.4.2.5 Other Contractors.......................................................................................................................................... 19
A.5 PERSONAL PROTECTIVE EQUIPMENT (PPE) ................................................................................................. 21
A.6 AIR MONITORING/SAMPLING .............................................................................................................................. 21
A.6.1 AIR MONITORING SPECIFICATIONS ..................................................................................................................... 21
A.6.2 AIR SAMPLING ..................................................................................................................................................... 22
A.7.1 DECONTAMINATION SPECIFICATIONS ....................................................................................................................... 22
A.7.2 SPILL-CONTAINMENT AND REPORTING PROCEDURES............................................................................................. 22
A.8 SITE-CONTROL PLAN................................................................................................................................................ 23
A.8.1 SITE-CONTROL PROCEDURES .................................................................................................................................. 23
A.8.2 HAZWOPER COMPLIANCE PLAN............................................................................................................................ 23
A.9 CONTINGENCY PLAN ................................................................................................................................................ 24
A.9.1 PRE-EMERGENCY PLANNING .................................................................................................................................... 24
A.9.2 ..................................................................................................................................................................................... 24
EMERGENCY EQUIPMENT AND SUPPLIES ............................................................................................................................. 24
A.9.3 INCIDENT RESPONSE ................................................................................................................................................ 25
A.9.4 EMERGENCY MEDICAL TREATMENT .......................................................................................................................... 25
A.9.5 EVACUATION.............................................................................................................................................................. 26
A.6.3 A.9.6 INCIDENT NOTIFICATION AND REPORTING .............................................................................................. 26
A.10 APPROVAL ................................................................................................................................................................. 26
A.10.1 ORIGINAL PLAN ....................................................................................................................................................... 26
A.11 ATTACHMENTS ......................................................................................................................................................... 27
A.11.1 EMPLOYEE SIGNOFF FORM ...................................................................................................................................... 27
A.11.2 STATEMENT OF POLICY ON DRUG AND ALCOHOL ABUSE ....................................................................................... 28
A.11.3 PROJECT-SPECIFIC CHEMICAL PRODUCT HAZARD COMMUNICATION FORM ......................................................... 31
A.11.4 APPLICABLE MATERIAL SAFETY DATA SHEETS ....................................................................................................... 32
A.11.5 CHEMICAL SPECIFIC TRAINING FORM ...................................................................................................................... 32
A.11.6 ACTIVITY HAZARD ANALYSIS .................................................................................................................................... 34
A.11.6.1 AHA Deployment of Turbidity Curtain ......................................................................................................... 37
A.11.6.2 AHA River Flash ............................................................................................................................................. 38
A.11.6.3 AHA Bag Roll out ........................................................................................................................................... 39
A11.6.4 AHA Clearing and Grubbing Barge Mounted Hoe...................................................................................... 40
A.11.6.5 AHA Booster Pump Operation ..................................................................................................................... 41
A.11.6.7 Driving Sheet Piling........................................................................................................................................ 43
A.11.6.8 AHA Fuel Transfers ....................................................................................................................................... 44
A.11.6.9 AHA General Site Hazards ........................................................................................................................... 45
A.11.6.10 AHA Marine Equipment Operations .......................................................................................................... 46
A.11.6.11 AHA MOB/Demobilization........................................................................................................................... 47
A.11.6.12 AHA Mobile Equipment on Barges............................................................................................................ 48
A.11.6.13 AHA River Access/Transportation ............................................................................................................. 49
A.11.6.14 AHA Welding and Cutting ........................................................................................................................... 50
A.11.6.15 AHA Working from Mobile Work Platforms .............................................................................................. 51
A.11.6.16 AHA Working from Small Boats ................................................................................................................. 52
A.12. INCIDENT REPORT ............................................................................................................................................... 37
A.13. EMERGENCY CONTACTS............................................................................................................................................. 38
A.14 LOCK OUT/TAG OUT ..................................................................................................................................................... 38
LOCKOUT /TAGOUT POLICY ............................................................................................................................................ 38

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 A.1 Tasks to be performed under this Plan
0B

A.1.1 Description of Tasks

1B

Refer to project documents (i.e., Work Plan) for detailed task information. A health and safety risk
analysis (Sections A.1.2 and A.1.3) has been performed for each task and is incorporated in this plan
through task-specific hazard controls and requirements for monitoring and protection. Tasks other than
those listed below require an approved amendment or revision to this plan before tasks begin. Refer to
Section A.8.2 for procedures related to “clean” tasks that do not involve hazardous waste operations and
emergency response (HAZWOPER).

A.1.1.1 Employee Orientation

46B

Employees expecting to access the site are required to attend an employee orientation. The training
provided to the employees in the employee orientation needs to include:

• Review this Health and Safety Plan (HASP)

• Present an overall site safety briefing (general site safety),
• Review employee responsibilities including J.F. Brennan Drug Policy
• Review emergency procedures and evacuation plan
• Review injury and incident reporting procedures
• Review reporting procedures for hazardous conditions and/or hazardous activities
A.1.1.2 Employee Training
47B

Training documentation will be provided to the J.F. Brennan SSR prior to start of work operations. This
documentation/certification includes areas such as Great Lakes Safety Training Construction Initial,
HAZWOPER, HazCom, Crane, Heavy Equipment, Fall Protection, etc.

A.1.1.3 HAZWOPER-Regulated Tasks

48B

Dredging,
Driving sheet pile

A.1.1.4 Non-HAZWOPER-Regulated Tasks

49B

Under specific circumstances, the training and medical monitoring requirements of federal or state
HAZWOPER regulations are not applicable. It must be demonstrated that the tasks can be performed
without the possibility of exposure in order to use non-HAZWOPER-trained personnel. Prior approval
from the Health and Safety Director (HSD) is required before these tasks are conducted on
regulated hazardous waste sites.

A.1.2 Task Hazard Analysis— Dredging, Sheeting

12B

(Refer to Section A.2 for hazard controls)

POTENTIAL
HAZARDS Dredging Sheeting
Flying debris/objects X
Noise > 85dBA X X
Electrical X X
Suspended loads X X
Buried utilities, drums, X X

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 tanks
Slip, trip, fall X X
Back injury X X
Confined space entry X
Working from boat/barge X X
Visible lightning X X
Vehicle traffic X
Elevated work areas/falls X X
Fires X X
Entanglement X X
Heavy equipment X X
Working near water X X
Contact with boaters X X

A.2 Hazard Controls

1B

This section provides safe work practices and control measures used to reduce or eliminate potential
hazards. These practices and controls are to be implemented by the party in control of either the site or
the particular hazard. J.F. Brennan employees and subcontractors must remain aware of the hazards
affecting them regardless of who is responsible for controlling the hazards. J.F. Brennan employees and
subcontractors who do not understand any of these provisions should contact the SSO for clarification.

A.2.1 Project Specific Hazards

13B

Project specific hazards include the items listed below.

A.2.1.1 Boating/Barge Operations

50B

• Public exposure shall be minimized through the use of warning buoys, lights and signage.
• All operations involving boating will be directed by a qualified and experienced boater acting as the
team leader.
• All persons participating in boating operations will be directed by the SSR.
• All personnel shall wear their Personnel Floatation Devices Type III (PFD) at all times while they are
on the water. With the exception of the Hoe Operator while in the confines of the cab.
• All personnel shall wear bright colors (for example: Hi-Vis orange, green, etc.) to enhance their
visibility to one another.
• The Foreman has final authority on operations with regards to weather and water conditions
• To prevent slipping and/or falling, a platform will be provided for a safe means of boarding or leaving
any vessel.
• One ring buoy will be provided on the barge for emergency rescue.
• Employees should be instructed on the safe use and operation of the boat.
• The boat/barge must be operated according to U.S. Coast Guard regulations for:
− Speed
− Lighting
− Right-of-way, etc.
• Since conditions are generally wet and muddy, care will be taken to keep work area as clean as
possible to avoid slips, trips and falls.

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 A.2.1.2 Working on or over Water
51B

• Fall protection should be provided to prevent personnel from falling into water. Where fall protection
systems are not provided and the danger of drowning exists, U.S. Coast Guard-approved personal
flotation devices (PFDs), shall be worn.
• Inspect PFDs prior to use. Do not use defective PFDs.
• A life-saving skiff or life raft must be provided for emergency rescue.
• A minimum of one ring buoy with 70 feet of 3/8-inch solid-braid polypropylene (or equal) rope must be
provided for emergency rescue.
• Use sampling and other equipment according to the manufacturers' instructions and intentions.

A.2.1.3 Cranes, Hoists, and Rigging

52B

• Only qualified crane operators are permitted to operate cranes.

• Maintain safe distance from operating cranes and stay alert of crane movement. Avoid positioning
between fixed objects, operating cranes and crane pinch points. Remain outside of the crane swing
and turning radius. Never turn your back on operating cranes.
• Approach cranes only after receiving the operator’s attention. The operator shall acknowledge your
presence and stop movement of the crane. Never approach operating cranes from the side or rear
where the operator’s vision is compromised.
• When required to work in proximity to operating cranes, wear high-visibility vests to increase visibility to
operators.
• Stay as clear as possible of all hoisting operations. Loads shall not be hoisted overhead of personnel.
• Cranes shall not be used to lift or lower personnel.
• If crane becomes electrically energized, personnel shall be instructed not to touch any part of the
crane or attempt to touch any person who may be in contact with the electrical current. The utility
company or appropriate party shall be contacted to have line de-energized prior to approaching the
crane.
• Do not exceed hoist load limits.
• Ensure load is level and stable before hoisting
• Inspect all rigging equipment prior to use. Do not use defective rigging for any reason.
• Only use rigging equipment for the purpose it was designed and intended.
• Critical lifts will be performed following DOW requirements.

A.2.1.4 Rigging
53B

• Stay as clear as possible of all hoisting operations. Loads shall not be hoisted overhead of personnel.
• Hoists shall not be used to lift or lower personnel.
• Do not exceed hoist load limits.
• Ensure load is level and stable before hoisting
• Inspect all rigging equipment prior to use. Do not use defective rigging for any reason.
• Only use rigging equipment for the purpose it was designed and intended.
•
A.2.1.5 Energized Electrical
54B

• All electrical power will be from portable generators except power to the bag field which will come
through DOW.
• Only qualified personnel are permitted to work on unprotected energized electrical systems.

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• Electrical wiring and equipment shall be de-energized prior to conducting work unless it can be
demonstrated that de-energizing introduces additional or increased hazards or is unfeasible due to
equipment design or operational limitations.
• All electrical systems shall be considered energized until lockout/tagout procedures are implemented.
• Follow all control measures and procedures identified on the Energized Electrical Work Permit.

A.2.1.6 Lockout/Tag-out
5B

• Lock out/Tag out will follow procceedures ( refer to attachment

• Do not work on equipment when the unexpected operation could result in injury, unless lockout/tagout
procedures are implemented.
• Staff working under a lockout/tag-out procedure must complete the J.F. Brennan Lockout/Tagout
training course. Project-specific training may also be required on site-specific lockout/tagout
procedures.
• Standard lockout/tag-out procedures include the following six steps:
− Notify all personnel in the affected area of the lockout/tag out,
− Shut down the equipment using normal operating controls,
− Isolate all energy sources,
− Apply individual lock and tag to each energy isolating device,
− Relieve or restrain all potentially hazardous stored or residual energy, and
− Verify that isolation and de-energization of the equipment has been accomplished. Once verified
that the equipment is at the zero energy state, work may begin.
• All safe guards must be put back in place, all affected personnel notified that lockout/tag out has been
removed and controls positioned in the safe mode prior to lockout/tag out removal.
• Do not remove another person’s lock or tag.

A.2.1.7 Welding and Cutting

56B

• Only authorized and trained personnel are permitted to operate welding/cutting equipment.
• Do not enter areas where welding/cutting operations are taking place unless completely necessary
and only after receiving permission from the welding/cutting operator.
• If you must be present in an area during welding/cutting operations, position yourself behind flash
screens or wear glasses/goggles with lenses of appropriate tint.
• Do not look directly at the welding/cutting flash or at reflective surfaces surrounding welding/cutting
operations.
• Avoid contacting compressed gas cylinders. Cylinders should be firmly secured in an upright position
at all times.
• Be aware of trip hazards created by welding hoses, power cables, leads and cords positioned on walking
surfaces.

A.2.1.8 Compressed Gas Cylinders

57B

• Valve caps must be in place when cylinders are transported, moved or stored.
• Cylinder valves must be closed when cylinders are not being used and when cylinders are being
moved.
• Cylinders must be secured in an upright position at all times.
• Cylinders must be shielded from welding and cutting operations. They must also be positioned to
avoid being struck or knocked over, contacting electrical circuits or exposed to extreme heat sources.
• Cylinders must be secured on a cradle, basket or pallet when hoisted; they may not be hoisted by
choker slings.

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 A.2.1.9 Fall Protection
58B

• Fall protection systems must be used to eliminate fall hazards when performing construction activities
at a height of 6 feet or greater and when performing general industry activities at a height of 4 feet or
greater.
• The SSR must complete the Project Fall Protection Evaluation Form and provide project-specific fall
protection training to all staff exposed to fall hazards. The Project Fall Protection Evaluation Form is
provided in Attachment A-5 of this plan.
• The SSR shall act as competent person and shall inspect and oversee the use of fall protection
systems. Follow all requirements established by the competent person for the use and limitation of fall
protection systems.
• A registered professional engineer shall oversee the use of horizontal lifelines.
• Only one person shall be simultaneously attached to a vertical lifeline.
• Remain within the guardrail system when provided. Leaning over or stepping across a guardrail system is
not permitted.
• Do not stand on objects (boxes, buckets, bricks, blocks, etc.) or ladders to increase working height on
top of platforms protected by guardrails.
• Inspect personal fall arrest systems prior to each use. Do not use damaged fall protection systems at
any time, or for any reason.
• Set-up personal fall arrest systems so that you can not free-fall more than 6 feet.
• Only attach personal fall arrest systems to anchor points capable of supporting at least 5,000 pounds.
• Use fall protection equipment for fall protection only. Never use fall protection equipment to hoist
materials. Do not use personal fall arrest systems that have been subjected to impact loading.

A.2.1.10 Hand Tools

59B

• Operate all tools according to the manufacturers’ instructions and within design limitations.
• All hand and power tools shall be maintained in a safe condition.
• Tools are to be inspected and tested before use. If a tool is found to be defective it is to be tagged
“Do Not Use” and removed from service until repaired.
• Personal protective equipment, such as gloves, safety glasses, earplugs and face shields are to be
used when exposed to a hazard from the tool.
• Power tools are not to be carried or lowered by the cord or hose.
• Disconnect tools from energy sources when not in use, before servicing and cleaning, and when
changing accessories such as blades, bits and cutters.
• Safety guards on tools are to remain installed while the tool is in use and promptly replaced after
repair or maintenance has been performed.
• Tools are to be stored properly where they will not be damaged or come in contact with hazardous
materials.
• If a cordless tool is connected to its recharge unit, both pieces of equipment must conform strictly with
electrical standards and manufacturer's specifications.
• Tools used in an explosive environment must be rated (i.e., intrinsically safe, spark proof, etc.) for
work in such an environment.
• Impact tools, such as drift pins, wedges and chisels shall be kept free of mushroomed heads.
• Manual and pistol-grip hand tools may involve work with highly repetitive movement, extended
elevation, constrained postures or positioning of body members (e.g., hand, wrist, arm, shoulder,
neck, etc.). Consider alternative tool design, improved posture, selection of appropriate materials,
work organization and sequencing to prevent muscular skeletal, repetitive motion and cumulative
trauma stressors.
• Tools shall be tested each day before use to insure that safety devices are in proper working
condition. The method of testing shall be in accordance with the manufacturer's recommended
procedure.

8
• Belts, gears, shafts, pulleys, sprockets, spindles, drums, fly wheels, chains or other reciprocating,
rotating or moving parts of equipment shall be guarded if such parts are exposed to contact by
employees or otherwise create a hazard.
• All liquid fuel-powered tools shall be stopped while being refueled, serviced or maintained.

A.2.1.11 Dioxin Waste Management

60B

Contaminated solid material removed will be placed in containers and on-site location for proper
treatment.

A.2.2 General Hazards

14B

A.2.2.1 General Practices and Housekeeping

61B

• Site work should be performed during daylight hours whenever possible. Work conducted during
hours of darkness requires enough illumination intensity to read a newspaper without difficulty.
• Good housekeeping must be maintained at all times in all project work areas.
• Common paths of travel should be established and kept free from the accumulation of materials.
• Keep access to aisles, exits, ladders, stairways, scaffolding and emergency equipment free from
obstructions.
• Provide slip-resistant surfaces, ropes and/or other devices to be used.
• Specific areas should be designated for the proper storage of materials. Sheeting laydown area will
be established.
• Tools, equipment, materials and supplies shall be stored in an orderly manner.
• As work progresses, scrap and unessential materials must be neatly stored or removed from the work
area.
• Containers should be provided for collecting trash and other debris and shall be removed at regular
intervals.
• All spills shall be quickly cleaned up. Oil and grease shall be cleaned from walking and working
surfaces.

A.2.2.2 Hazard Communication

62B

The SSR is to perform the following:

• Complete an inventory of chemicals brought onsite by J.F. Brennan using Attachment A-5.
• Request or confirm locations of Material Safety Data Sheets (MSDS’s) from the client, and
contractors, for chemicals to which J.F. Brennan employees potentially are exposed.
• Before chemicals arrive onsite, obtain an MSDS for each hazardous chemical and retain a copy with
the HASP onsite.
• Label chemical containers with the identity of the chemical, hazard warnings and store properly.
• Administer required chemical-specific HAZCOM training to employees using Attachment A-5.
• Store all materials properly, giving consideration to compatibility, quantity limits, secondary
containment, fire prevention and environmental conditions.

A.2.2.3 Shipping and Transportation of Chemical Products

63B

Chemicals brought to the site might be defined as hazardous materials by the U.S. Department of
Transportation (DOT). All staff who ship the materials or transport them by road must receive J.F.
Brennan training in shipping dangerous goods. All hazardous materials that are shipped (e.g., via Federal
Express) or are transported by road must be properly identified, labeled, packed and documented by
trained staff. Contact the HSD or the Equipment Coordinator for additional information.

A.2.2.4 Lifting
64B

• Proper lifting techniques must be used when lifting any object.

− Plan storage and staging to minimize lifting or carrying distances.

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 − Split heavy loads into smaller loads.
− Use mechanical lifting aids whenever possible.
− Have someone assist with the lift—especially for heavy or awkward loads.
− Make sure the path of travel is clear prior to the lift.

A.2.2.5 Fire Prevention

65B

• Fire extinguishers shall be provided so that the travel distance from any work area to the nearest
extinguisher is less than 100 feet. Extinguishers must:
− be maintained in a fully charged and operable condition,
− be visually inspected each month, and
− undergo a maintenance check each year.
• The area in front of extinguishers must be kept clear.
• Combustible materials stored outside should be at least 10 feet from any building.
• Solvent waste and oily rags must be kept in a fire resistant covered container until removed from the
site.
• Flammable/combustible liquids must be kept in approved containers and must be stored in an approved
storage cabinet.

A.2.2.6 Electrical
6B

• Only qualified personnel are permitted to work on unprotected energized electrical systems.
• Only authorized personnel are permitted to enter high-voltage areas.
• Do not tamper with electrical wiring and equipment unless qualified to do so. All electrical wiring and
equipment must be considered energized until lockout/tag-out procedures are implemented.
• Inspect electrical equipment, power tools and extension cords for damage prior to use. Do not use
defective electrical equipment. All defective equipment shall be removed from service.
• All temporary wiring, including extension cords and electrical power tools, must have ground fault
circuit interrupters (GFCIs) installed.
• Extension cords must be:
− Equipped with third-wire grounding.
− Covered, elevated or protected from damage when passing through work areas.
− Protected from pinching if routed through doorways.
− Not fastened with staples, hung from nails or suspended with wire.
• Electrical power tools and equipment must be effectively grounded or double-insulated UL approved.
• Operate and maintain electric power tools and equipment according to manufacturers' instructions.
• Maintain safe clearance distances between overhead power lines and any electrical conducting
material unless the power lines have been de-energized and grounded, or where insulating barriers
have been installed to prevent physical contact. Maintain at least 10 feet from overhead power lines
for voltages of 50 kV or less, and 10 feet plus ½ inch for every 1 kV over 50 kV.
• Temporary lights shall not be suspended by their electric cord unless designed for suspension. Lights
shall be protected from accidental contact or breakage.
• Protect all electrical equipment, tools, switches and outlets from environmental elements.

A.2.2.7 Stairways and Ladders

67B

• A stairway, ramp or ladder is generally required when a break in elevation of 19 inches or greater
exists.
• Personnel should avoid using both hands to carry objects while on stairways; if unavoidable, use
extra precautions.
• Personnel must not use pan and skeleton metal stairs until permanent or temporary treads and
landings are provided the full width and depth of each step and landing.
• Ladders must be inspected by a competent person for visible defects prior to each day’s use.
Defective ladders must be tagged and removed from service.

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• Ladders must be used only for the purpose for which they were designed and shall not be loaded beyond
their rated capacity.
• Only one person at a time shall climb on or work from an individual ladder.
• User must face the ladder when climbing, keeping the belt buckle between side rails.
• Ladders shall not be moved, shifted or extended while in use.
• User must use both hands to climb. Materials and equipment should be raised and lowered using
rope..
• Straight and extension ladders must be tied off to prevent displacement.
• Ladders that may be displaced by work activities or traffic must be secured or barricaded.
• Portable ladders must extend at least 3 feet above landing surface.
• Straight and extension ladders must be positioned at such an angle that the ladder base to the wall is
one-fourth of the working length of the ladder.
• Stepladders are to be used in the fully opened and locked position.
• Users are not to stand on the top two steps of a stepladder; nor are users to sit on top or straddle a
stepladder.
• Fixed ladders > 24 feet in height must be provided with fall protection devices.
U U

• Fall protection should be considered when working from extension, straight, or fixed ladders greater than
six feet from lower levels and both hands are needed to perform the work, or when reaching or working
outside of the plane of ladder side rails.

A.2.2.8 Procedures for Locating Buried Utilities

68B

Local Utility Mark-Out Service

Name: DOW Contact
Phone:
• Where available, obtain utility diagrams for the facility.
• Review locations of sanitary and storm sewers, electrical conduits, fuel tanks and lines, water supply
lines and natural gas lines.
• Review proposed locations of intrusive work with facility personnel knowledgeable of locations of
utilities. Check locations against information from utility mark-out service.
• Where necessary (e.g., uncertainty about utility locations), excavation or drilling of the upper depth
interval should be performed manually.
• Monitor for signs of utilities during advancement of intrusive work (e.g., sudden change in
advancement of auger or split spoon).
• When the client or other onsite party is responsible for determining the presence and locations of
buried utilities, the SSR should confirm that arrangement.

A.2.2.9 Vehicle Safety—Operator Safety

69B

• Operate vehicle only when in possession of valid driver’s license.

• Employees shall not operate vehicles while under the influence of drugs or alcohol. Consumption of
drugs or alcoholic beverages before or during work shift/driving is prohibited, as is possession of
them within vehicle.
• All vehicle occupants must use seat belts at all times. Familiarize yourself with rental vehicle features
(e.g., mirror & seat adjustments).
• Always drive within the speed limit.
• Do not drive if you are fatigued.
• Use tie-downs to secure equipment in large-cab vehicles such as vans.
• Exercise caution when entering or exiting a traveled way or parking along street—avoid sudden
stops, use hazard lights when locating or stopping at work areas.

11
• Park in a manner that will allow for safe exit from vehicle, and if possible, park vehicle so that it can serve as
a barrier.
• Before talking on a mobile phone, pull off of the roadway and park. Utilize hazard lights to make traffic
aware.
• Park vehicles in a location where it can be accessed easily in the event of an emergency.

A.2.2.11 Vehicles Entering/Exiting Site

• A flagman must be used when backing heavy equipment onto the jobsite.
• If the vehicle will impede the normal flow of traffic when pulling into/out of the site, a flagman must also be
used. Once the vehicle is on the road way, a field vehicle equipped with flashing lights will follow the
heavy equipment vehicle. It is imperative that truck operations do not pose a traffic hazard to pedestrians
and normal road traffic.
A.2.2.12
70B Pressure Washing Operations
• Wear appropriate personal protective equipment when operating a pressure washer that includes a
face shield, hearing protection and protective clothing.
• Follow manufacturer’s safety and operating instructions.
• Use extended pressure wash wands to minimize contact with overspray.
• Inspect pressure washer before use and confirm the “dead man” switch is fully operational.

A.2.2.13 Inclement Weather

71B

Adverse weather conditions requiring immediate suspension of field work activities are defined as the
following:
• Thunder or lightning. Thunderstorm watches or warning as the situation warrants, will be used as an alert
to potential electric activity. Typically, a 15-minute stand-down occurs to allow the storm cell to pass the
area. If lightning or thunder is observed within the stand down period, the 15-minute time frame is
extended until electrical activity ceases.
• The SSR can monitor multiple sources to track developing potential for lightning. These are the
following:
− Doppler radar reports from the Internet
− National Weather Service radio reports
• Field crews shall report any observations of lightning or thunder in their area to the SSR.
• Non-critical operations: Stop work in during any observable lightning or thunder.
• Critical operations: when a protective mesh is present and bonded to equipment, or equivalent protective
systems are installed: observable lightning or thunder—increased caution/use of iso-potential area,
increased monitoring/observation, minimize personnel, ready for shut-down, etc. When flash-to-bang is,
15 seconds (about 3 miles) and with consideration to subjective observations (frequency, intensity,
weather forecast, etc.), then stop operations. All personnel are to be informed and understand that they
have the option to stop/evacuate at any time. This is important in both allowing personnel to have control
of their safety and in having a check-and-balance between crew and supervisor.
• A tornado/hurricane warning for the general area or county will suffice in requiring a general work
stoppage.
• If you are inadvertently caught outside in a thunder/lightning storm, take the following precautions:
− Seek shelter among densely wooded areas.
− Avoid lone trees as shelter.
− Avoid open, bare areas.
− Do not cross water bodies.

12
• If caught in open area, place feet close together and crouch down as small as possible, without lying
on the ground.

• Work stoppage due to Heavy rain or high wind will be at the discretion of the SSR and
superintendent.

A.2.3 Biological Hazards and Controls

15B

Will be addressed during orientation

A.2.4 Contaminants of Concern

16B

(Refer to Project Files for more detailed contaminant information)

A.2.5 Potential Routes of Exposure

17B

A.3 LOSS PREVENTION SYSTEM

2B

A.3.1 Activity Hazard Analysis

18B

An Activity Hazard Analysis (AHA) defines the activity being performed, the hazards posed and control
measures required to perform the work safely. Workers are briefed on the AHA before doing the work and
their input is solicited prior, during and after the performance of work to further identify the hazards posed
and control measures required.
Activity Hazard Analysis will be prepared before beginning each project activity posing H&S hazards to
project personnel using the AHA form provided in Attachment A-6. The AHA shall identify the work tasks
required to perform each activity, along with potential H&S hazards and recommended control measures
for each work task. In addition, a listing of the equipment to be used to perform the activity, inspection
requirements and training requirements for the safe operation of the equipment listed must be identified.
An AHA shall be prepared for all field activities performed by J.F. Brennan and subcontractor during the
course of the project by the Site Safety Rep. SSR. The Project-Specific and General Hazards (Sections
A.2.1 and A.2.2, respectively) of the HSCP, the Hazard Analysis Table (Sections A.1.2 and A.1.3), and
applicable J.F. Brennan Standards of Practice (SOPs) should be used as a basis for preparing these
AHAs.
J.F. Brennan subcontractors will be required to provide AHAs specific to their scope of work on the project
for acceptance by J.F. Brennan. Each subcontractor shall submit AHAs for their field activities, as defined in
their work plan/scope of work, along with their project-specific HASP. Additions or changes in J.F. Brennan
or subcontractor field activities, equipment, tools or material to perform work or additional/different hazard
encountered that require additional/different hazard control measures requires either a new AHA to be

13
prepared or an existing AHA to be revised. All AHAs must be approved by J.F. Brennan prior to work
commencement.

A.3.2 Pre-Task Safety Plans

19B

Daily safety meetings are held with all project personnel in attendance to review the hazards posed and
required H&S procedures/AHAs, which apply for each day’s project activities. The PTSPs serve the same
purpose as these general assembly safety meetings, but the PTSPs are held between the crew
supervisor and their work crews to focus on those hazards posed to individual work crews. At the start of
each day’s activities, the crew supervisor completes the PTSP, with input from the work crew, during their
daily safety meeting. The day’s tasks, personnel, tools and equipment that will be used to perform these
tasks are listed, along with the hazards posed and required H&S procedures, as identified in the AHA.
The use of PTSPs, better promotes worker participation in the hazard recognition and control process,
while reinforcing the task-specific hazard and required H&S procedures with the crew each day. The use
of PTSPs is a common safety practice in the construction industry.
STAC cards will be completed by all crew members on a daily basis and turned in the following day.

A Chat card

A.3.3 Incident Investigations

20B

Incident Investigations shall be performed for the all J.F. Brennan and subcontractor incidents involving:
• Person injuries/illnesses and near miss injuries
• Equipment/property damage
• Spills, leaks, regulatory violations
• Motor vehicle accidents
Identifying and correcting the causes of the incident prevent future incidents. The following is the Incident
Investigation Process:

• Gather all relevant facts, focusing on fact-finding, not fault-finding, while answering the, who, what,
when, where and how questions.
• Draw conclusions, pitting facts together into a probable scenario.
• Determine incident root cause(s), which are basic causes on why an unsafe act/condition existed.
• Develop and implement solutions, matching all identified root causes with solutions.
• Communicate incident as a Lesson Learned to all project personnel.
• File a follow-up on implemented corrective active action form to confirm solution is appropriate.
Site Supervisors (SS) shall perform an incident investigation, as soon as practical after incident
occurrence during the day of the incident, for all incidents that occur on the project. The Incident
Investigation Report must be filled out and submitted to the (SSR).
All incidents involving personal injury, property damage in excess of $1,000 or near loss incidents that
could have resulted in serious consequences shall be investigated by completing the incident
investigation forms and submitting them to the PM and HSD within 24 hours of incident occurrence. A
preliminary Incident Investigation and Root Cause Analysis shall be submitted to the Project Manager and
HSD within 24 hours of incident occurs. Subcontractor Health and Safety Tracking Form

14
 A.4 Project Organization and Personnel
3B

A.4.1 J.F. BRENNAN Employee Medical Surveillance and

21B

Training
(The employees listed below are enrolled in the J.F. Brennan Comprehensive Health and Safety Program
and meet state and federal hazardous waste operations requirements for 40-hour initial training, 3-day
on-the-job experience, and 8-hour annual refresher training. Employees designated “FA-CPR” are
currently certified by the American Red Cross, or equivalent, in First Aid and CPR. At least one FA-CPR
designated employee must be present during all tasks performed in exclusion or decontamination zones.
The employees listed below are currently active in a medical surveillance program that meets state and
federal regulatory requirements for hazardous waste operations. Certain tasks (e.g., confined-space
entry) and contaminants (e.g., lead) may require additional training and medical monitoring.

Employee Name Office Responsibility SSC/FA-

CPR
Matt Binsfeld JFB Project Manager Yes
Project Engineer

Steve Stroschein JFB Health and Safety Director Yes

Jim O’neill JFB Superintendent Yes

J.D. Dohrn JFB Site Safety Coordinator Yes

A.4.1.1 J.F. BRENNAN Employee Responsibilities

72B

All personnel are assigned responsibility for safe and healthy operations. This concept is the foundation
for involving all employees in identifying hazards and providing solutions. For any operation, individuals
have full authority to stop work and initiate immediate corrective action or control. In addition, each worker
has a right and responsibility to report unsafe conditions/practices. This right represents a significant facet
of worker empowerment and program ownership. Our employees accept personal responsibility for
working safely through shared values and a belief that all accidents are preventable.
Each project team member is responsible for the following performance objectives:

• All employees are required to value safety. During any task, employees must consider the possible
effects of their actions on themselves and others and take appropriate protective measures.
• All personnel are charged with aiding in the protection of the public. As your job description dictates,
installation and maintenance of signs, signals, buoys, lights, fences, guardrails, ramps, temporary
sidewalks, barricades, and overhead protection, may be necessary.
• Security fencing protects employees, the company and the general public. All fencing must be
maintained by all employees to the extent of their job description. Report to your supervisor defects
beyond your ability to repair.
• Complete an orientation prior to being authorized to enter the project work areas
• Employees are required to review, be familiar with, and adhere to site-specific jobsite health and
safety plans, procedures, practices, precautions and permits.
• Use only safe means of access to and from work areas.
• Perform work in a safe manner and produce quality results. Complete work without injury, illness or
property damage.

15
• Perform work in accordance with company policies and report injuries, illnesses, and unsafe
conditions
• Use the right tool or equipment for the task at hand.
• All disruptive activities, such as horseplay, are forbidden. Practical jokes or fights are prohibited.
• Follow proper housekeeping practices. At the end of each phase of work, return all tools and excess
material to proper storage areas. Clean up all debris as work progresses. Each employee is
responsible for keeping their work areas clean.
• The employee is responsible for wearing appropriate personal protective equipment in operations
where there is exposure to hazardous conditions, or where need is indicated to reduce hazards. Hard
hats and safety glasses will be worn at all times on construction sites.
• Hearing protection will be worn in areas where sound levels may exceed (85) decibels.

A.4.1.2 Progressive Discipline Policy

73B

All J.F. Brennan and contractor individuals associated with this project must work injury-free, drug-free
and must comply with the project Health and Safety and Contingency Plan (HASP), J.F. Brennan Health,
Safety and Environment (HS&E) procedures, any project-specific safety requirements and this policy.

Safety Infractions
U

Any non-compliance with the project HASP, J.F. Brennan HS&E procedures, and other project-specific
safety requirements will be considered safety infractions. These will include, but will not be limited to:
• Violation of established safety rules, regulations, codes or other requirements
• Poor housekeeping
• Failure to report on-the-job injuries or unsafe conditions
• Failure to wear the appropriate personal protective equipment
Intolerable Offenses
U

Intolerable offenses and actions will include, but will not be limited to, the following:
• Any manager, supervisor, foreman or other person in charge of the work being performed who
requires, requests, asks, threatens with their job, allows or condones employees to work in or around
unsafe acts or conditions
• Any employee, supervisor, or manager who knowingly falsifies any investigative documents or
testimony involving an investigation
• Any employee, supervisor, or manager who openly exhibits disregard, defiance or disrespect for the
safety program
• Any employee who violates established safety rules, regulations or codes that endanger themselves or
other employees
• Any employee, supervisor or manager failing to comply with the project HASP, or any and all federal,
state or local safety laws and regulations that create the potential for serious or costly consequences
• Any employee who commits repeated minor offenses and shows a lack of responsible effort to correct
these offenses
Enforcement and Discipline
U

This policy will be thoroughly reviewed with each employee during the employee health and safety
orientation.

Safety Infractions
U

This procedure will be followed in the event that any employee violates safety rules:

16
 a. The employee will be given a verbal warning of the violation of company safety policy.
b. The second violation of a company safety policy, will result in a documented warning.
c. The third violation of a company safety policy will result in a 3-day suspension without pay.
d. Four violations of a company safety policy may result in termination of employment.
e. If a violation is deemed to be of obvious nature and posses eminent danger this could result in
immediate termination.

A.4.1.3 Drug-Free Workplace & Screening Program

74B

J.F. Brennan does not tolerate illegal drugs, or any use of drugs, controlled substances, or alcohol that
impairs an employees work performance or behavior. J.F. Brennan employees and subcontractors shall not
be involved in any manner with the unlawful manufacture, distribution, dispensation, possession, sale, or
use of illegal drugs in the workplace. The use or possession of alcohol in the workplace is also prohibited.
Any violation of these prohibitions may result in discipline or immediate discharge. All subcontractors and
employees working on this project are required to submit to a pre-assignment test for drugs. The test must
be taken within 30 days of the employee’s arrival date at the project. The SSR must verify that each
subcontractor employee have completed pre-assignment testing by obtaining written verification from the
employer (e.g., certificate of successful participation in testing for each person). Subcontractor employee’s
participation in a random testing program, which meets J.F. Brennan program requirements, since the
beginning of their employment can be used in lieu of the pre-assignment requirement. Being subject to only
post-incident testing will not be adequate to meet the random or pre-assignment requirements.

A.4.2 Field Team Chain of Command and Communication

2B

Procedures
Organizational Chart:

Division Manager & Project Coordinator: Ken Manning

Division Manager – Hydraulic Dredging: Vic Buhr
Asst. Division Manager - Construction: Jeana Gillaspie

Project Manager: Matt Binsfeld

Safety Manager: John Dohrn

QC / Survey Manager: Chris Bauer

QC / Survey Assistant: Scott Zietlow

Dewatering Manager: Tim LeBlanc

Bag Foreman: Michael Keifer
Booster Fm: Tim Tolvstad

Project General Superintendent: Jim O’Neill

Key JFB Personnel: Rick Tischer (Hoe Operator)

Rocco Marselles (Carpenter)

17
 Kevin Lee (Op / Welder)
Andy Vonarx
Tim Vonarx

A.4.2.1 Project Manager

The project manager (PM) is responsible for providing adequate resources (budget and staff) for project-
specific implementation of the HS&E management process. The PM has overall management
responsibility for the tasks listed below. The PM may explicitly delegate specific tasks to other staff, as
described in sections that follow, but retains ultimate responsibility for completion of the following in
accordance with this document:

• Incorporate standard terms and conditions, and contract-specific HS&E roles and responsibilities in
contract and subcontract agreements (including flow-down requirements to lower-tier subcontractors)
• Select safe and competent subcontractors
• Obtain, review, and accept or reject subcontractor pre-qualification questionnaires
• Ensure that acceptable certificates of insurance, including (JFB) as named additional insured, are
secured as a condition of subcontract award
• Incorporate HS&E information in subcontract agreements, and ensure that appropriate site-specific safety
procedures, training, and medical monitoring records are reviewed and accepted prior to the start of
subcontractor’s field operations
• Maintain copies of subcontracts and subcontractor certificates of insurance, bond, contractors
license, training and medical monitoring records, and site-specific safety procedures in the project file
accessible to site personnel
• Provide oversight of subcontractor HS&E practices per the site-specific safety plan
• Manage the site and interface with third parties in a manner consistent with our contract and
subcontract agreements and the applicable standard of reasonable care
• Ensure that the overall, job-specific, HS&E goals are fully and continuously implemented

A.4.2.2
75B Health and Safety Director (HSD)
Steve Stroschein Phone: 608-784-7173 x245 or cell 608-792-5819
The J.F. Brennan HSD is responsible for the following:

• Review and accept or reject subcontractor pre-qualification questionnaires with participation from
Contracts
• Review and accept or reject subcontractor training records and site-specific safety procedures prior to
start of subcontractor’s field operations
• Support the SSR’s oversight of subcontractor (and lower-tier subcontractors), HS&E practices and
interfaces with on-site third parties per the site-specific safety plan
• Assist with program implementation as needed
• Provide technical support
• Conduct H&S audits

A.4.2.3
76B Site Safety Representative (SSR)
J.D. Dohrn
Phone: 608-792-0031

The SSR is responsible for the following:

• Verify that the project is conducted in a safe manner
• Verify that the HASP is current and amended when project activities or conditions change

18
• Verify team members and subcontractors read the HASP and sign the Employee Signoff Form, prior
to commencing field activities
• Verify and document team members have completed any required specialty training (e.g., fall
protection, confined space entry) and medical surveillance
• Verify compliance with the requirements of the HASP and applicable subcontractor health and safety
plan(s)
• Act as the project “Hazard Communication Coordinator” and perform the responsibilities outlined in
the HASP
• Act as the project “Emergency Response Coordinator” and perform the responsibilities outlined in the
HASP
• Verify that safety meetings are conducted and documented in the project file as needed throughout
the course of the project (e.g., as tasks or hazards change)
• Verify that project health and safety forms and permits are being used as outlined in the HASP
• Perform assessments of contractor HS&E practices per the site-specific safety plan and verify that
project activity self-assessment checklists are being used by J.F. Brennan team members
• Conduct safety briefings weekly to Brennan team members and subcontractor supervisors. Require
subcontractors to lead their own safety briefings as appropriate.
• Implement the Drug-Free Workplace Policy
• Provide open communication with employees
• Ensure that programs are effectively functioning to prevent and control hazards on the project
• Provide opportunities for safety involvement to project employees

A.4.2.4
7B J.F. BRENNAN Subcontractors
• J.F. Brennan will use no subcontractors on this project.

A.4.2.5
78B Other Contractors
J.F. Brennan will not be using any other contractors
This plan does not cover contractors that are contracted directly to the client or the owner. J.F. Brennan is
not responsible for the health and safety or means and methods of the contractor’s work, and we must
never assume such responsibility through our actions (e.g., advising on H&S issues). In addition to this
plan, J.F. Brennan staff should review contractor safety plans so that we remain aware of appropriate
precautions that apply to us. Except in unusual situations when conducted by the HSD, J.F. Brennan
must never comment on or approve contractor safety procedures. Self-assessment checklists contained
in Attachment A-4 are to be used by the SSR to review the contractor’s performance ONLY as it pertains
to evaluating our exposure and safety.
Health and safety related communications with contractors should be conducted as follows:

• Request the contractor to brief J.F. Brennan employees and subcontractors on the precautions
related to the contractor’s work.
• When an apparent contractor non-compliance/unsafe condition or practice poses a risk to J.F.
Brennan employees or subcontractors:
− Notify the contractor safety representative
− Request that the contractor determine and implement corrective actions
− If needed, stop affected J.F. Brennan work until contractor corrects the condition or practice.
Notify the client, Project Manager, and HSD as appropriate.
• If apparent contractor non-compliance/unsafe conditions or practices are observed, inform the
contractor safety representative. Our obligation is limited strictly to informing the contractor of our
observation—the contractor is solely responsible for determining and implementing necessary
controls and corrective actions.

19
• If an apparent imminent danger is observed, immediately warn the contractor employee(s) in danger
and notify the contractor safety representative. Our obligation is limited strictly to immediately warning
the affected individual(s) and informing the contractor of our observation—the contractor is solely
responsible for determining and implementing necessary controls and corrective actions.
• Document all oral health and safety related communications in project field logbook, daily reports or
other records.

20
 A.5 Personal Protective Equipment (PPE)
4B

PPE Specifications a
Task Level Body Head Respirator
b

General site entry D Work clothes – no shorts; ANSI ANSI Z89 -approved None
Surveying Z41–approved work boots; work Hardhat required
Observation of material glove, and high visibility reflective ANSI Z87 – approved
loading for offsite disposal work vests. Safety glasses
Oversight of remediation and Hearing protection
construction
Dredging D Body: ANSI Z41–approved Non- ANSI Z89 -approved None
Sediment sampling from slip protective footwear (steel Hardhat required
boat toe); Personal Flotation Device ANSI Z87 – approved
(PFD). Safety glasses
Gloves: Two layers surgical-style Hearing protection
nitrile gloves for sampling and for
dredging operations, pair of
surgical-style nitrile gloves under
leather work gloves.

Sediment processing Modified D Body: Tyvek® / Micro Max ANSI Z89 -approved None
Decontamination of coveralls & non-slip protective Hardhat required
equipment (steel toe) footwear or rubber ANSI Z87 – approved
steel-toe over-boots and high Safety glasses
visibility reflective work vests Face Shield – required
Gloves: Surgical-style nitrile for decontamination of
gloves. Leather gloves over equipment and any
nitrile surgical gloves for handling “aggressive” work
equipment. operations where
employee may be
splashed in the face
Hearing protection

Reasons for Upgrading or Downgrading Level of Protection

Upgrade Downgrade
• Request from individual performing tasks. • New information indicating that situation is less
• Change in work tasks that will increase contact or potential hazardous than originally thought.
contact with hazardous materials. • Change in site conditions that decrease the
• Occurrence or likely occurrence of gas or vapor emission. hazard.
• Known or suspected presence of dermal hazards. • Change in work task that will reduce contact with
• Action levels (Section B.6) are exceeded. hazardous materials.
a
Modifications are as indicated. J.F. Brennan will provide PPE only to J.F. Brennan employees.
b
No facial hair that would interfere with respirator fit is permitted.
c
Hardhat and splash-shield areas are to be determined by the SSR.
d
Ear protection should be worn when conversations cannot be held at distances of 3 feet or less without shouting.
e
Performing a task that requires an upgrade to a higher level of protection (e.g., Level D to Level C) is permitted only when the PPE
requirements have been approved by the HSD, and an SSR qualified at that level is present.

A.6 Air Monitoring/Sampling

5B

A.6.1 Air Monitoring Specifications

23B

Air monitoring during this project will be done by others.

21
Should visible levels of airborne dust be observed, dust suppression measures shall be instituted.

A.6.2 24B Air Sampling

Air sampling will be done by others.
The SSR must monitor the decontamination procedures and their effectiveness. Decontamination
procedures found to be ineffective will be modified by the SSR, with concurrence of the PM. The SSR
must ensure that procedures are established for disposing of materials generated on the site.
Decontamination will be required when contact with contaminated materials is made.
Proper removal and disposal of PPE will be followed by washing exposed body parts with soap solution
and rinse. All wash and rinse water will be collected and disposed of through DOW facilities.
All equipment found to be contaminated will be washed and rinsed and verified free from sediment.

A.7 Decontamination
A.7.1 Decontamination Specifications
25B

Decontamination specifications are listed in Table 7-1.

TABLE 7-1
Decontamination Specifications
Personnel Sample Equipment Heavy Equipment
• Boot wash/rinse • Wash/rinse equipment • Power wash
• Glove wash/rinse • Solvent-rinse equipment • Steam clean
• Outer-glove removal • Contain solvent waste for • Dispose of equipment rinse
• Body-suit removal offsite disposal water to facility or sanitary
• Inner-glove removal sewer, or contain for offsite
• Hand wash/rinse disposal
• Face wash/rinse
• Dispose of PPE in municipal
trash, or contain for disposal
• Dispose of personnel rinse
water to facility or contain for
onsite disposal

A.7.2 Spill-Containment and Reporting Procedures

26B

Absorbent material will be maintained on the dredge. Incidental spills will be contained with absorbent
material and disposed of properly.
Spills that are not completely contained or recovered and result in the discharge of a hazardous
substance to the environment will be reported to DOW. All hazardous spills will be reported to the SSR,
who in turn will report to the HSD

22
A.8 SITE-CONTROL PLAN
6B

A.8.1 Site-Control Procedures

27B

• The SSR will conduct a site safety briefing (see below) before starting field activities or as tasks and
site conditions change.
• Topics for briefing on site safety: general discussion of Health and Safety Plan, site-specific hazards,
locations of work zones, PPE requirements, equipment, special procedures and emergencies.
• The SSR records attendance at safety briefings in a logbook and documents the topics discussed.
• Establish support, decontamination and exclusion zones. Delineate, as appropriate, with flags or
cones.. Support zone should be upwind of the site. Use access control at entry and exit from each
work zone.
• Establish onsite communication consisting of the following:
− Line-of-sight and hand signals
− Air horn
− Two-way radio or cellular telephone if available
• Establish offsite communication.
• Establish and maintain the “buddy system.”
• Initial air monitoring is conducted by the SSR in appropriate level of protection.
• The SSR is to conduct periodic inspections of work practices to determine the effectiveness of this
plan—refer to Sections A.2 and A.3. Deficiencies are to be noted, reported to the HSD and corrected.

A.8.2 HAZWOPER Compliance Plan

28B

Certain parts of the site work are covered by state or federal HAZWOPER standards and therefore
require training and medical monitoring. Anticipated HAZWOPER tasks (Section A.1.1.3) might occur
consecutively or concurrently with respect to non-HAZWOPER tasks. This section outlines procedures to
be followed when approved activities specified in Section A.1.1.3 do not require 24- or 40-hour training.
Non-HAZWOPER-trained personnel also must be trained in accordance with all other state and federal
OSHA requirements.

• In many cases, air sampling, in addition to real-time monitoring, must confirm that there is no
exposure to gases or vapors before non-HAZWOPER-trained personnel are allowed on the site, or
while non-HAZWOPER-trained staff is working in proximity to HAZWOPER activities. Other data
(e.g., soil) also must document that there is no potential for exposure. The HSD must approve the
interpretation of these data. Refer to Sections A.2.4 and A.6 for contaminant data and air sampling
requirements, respectively.
• When non-HAZWOPER-trained personnel are at risk of exposure, the SSO must post the exclusion
zone and inform non-HAZWOPER-trained personnel of the following:
− Nature of the existing contamination and its locations
− Limitations of their access
− Emergency action plan for the site
• Periodic monitoring (see Section A.6) conducted during regulated tasks also should be used to
ensure that non-HAZWOPER-trained personnel (e.g., in an adjacent area) are not exposed to
airborne contaminants.
• When exposure is possible, non-HAZWOPER-trained personnel must be removed from the site until
it can be demonstrated that there is no longer a potential for exposure to health and safety hazards.

23
 A.9 Contingency Plan
7B

A.9.1 Pre-Emergency Planning

29B

The SSR performs the applicable pre-emergency planning tasks before starting field activities and
coordinates emergency response with J.F. Brennan onsite parties, the facility, and local emergency-
service providers as appropriate:

• Review the facility emergency and contingency plans where applicable.

• Determine what onsite communication equipment is available (e.g., two-way radio, air horn).
• Determine what offsite communication equipment is needed (e.g., nearest telephone, cell phone).
• Confirm and post emergency telephone numbers, evacuation routes, assembly areas and route to
hospital. Communicate the information to onsite personnel.
• Field Trailers: Post “Exit” signs above exit doors, and post “Fire Extinguisher” signs above locations of
extinguishers. Keep areas near exits and extinguishers clear.
• Review changed site conditions, onsite operations and personnel availability in relation to emergency
response procedures.
• Where appropriate and acceptable to the client, inform emergency room and ambulance and
emergency response teams of anticipated types of site emergencies.
• Inventory and check site emergency equipment, supplies and potable water.
• Communicate emergency procedures for personnel injury, exposures, fires, explosions and releases.
• Rehearse the emergency response plan before site activities begin, including the driving route to
hospital.
• Brief new workers on the emergency response plan.
• The SSR will evaluate emergency response actions and initiate appropriate follow-up actions.

A.9.2
30B

Emergency Equipment and Supplies

31B

The SSO should mark the locations of emergency equipment on the site map and post the map.

Emergency Equipment and Supplies Location

Fire extinguisher (A, B, and C classes) Gas powered Equipment
First aid kit Office trailer
Eye Wash Office trailer
Additional equipment (specify): Refer to boating/water related sections.

24
 A.9.3 Incident Response
32B

EMERGENCY PLANNING ASSEMBLE, ACCOUNT FOR ALL YOUR WORKERS, CALL BACK TO SWP WRITER

1. ALERT (one rise to maximum pitch) ASSEMBLY AREA 821 BUILDING FOR BARGE AREA.

680 BUILDING FOR PUMP

AND OPERATOR

2. EVACUATION (continuous rise and fall of siren) ASSEMBLY AREA 34 BUILDING FOR 2ND PUMP OPERATOR

1159 BUILDING FOR BAG AREA

3. CONTRACTOR'S RESPONSIBILITIES DURING AN ALERT OR EVACUATION

Stop all work, shut down all equipment, report to assembly area

All permits are void after an ALERT or EVACUATION and must be renewed after the ALL CLEAR

4. ALL CLEAR (two rises to maximum pitch of siren)

5. SIREN TEST - ALL CLEAR (Mondays at 10:55 am)

6. PERIMETER FLASHING LIGHTS (Do Not Enter)

7. SPECIAL EMERGENCY SIGNALS

8. SAFETY AND EYE SHOWER LOCATIONS

Locate the nearest Safety Shower and Eye Bath before starting work.

A.9.4 Emergency Medical Treatment

3B

EMERGENCY PROCEDURES FOR ACCIDENTS

USE DOW AMBULANCE (Midland Site) Dow Phone 123 or 6-4400, Non-Dow Phone 636-4400

1. CHEMICAL EXPOSURE OR
INJURY

2. FIRST AID TREATMENT

3. ANY AND ALL MEDICAL TREATMENTS

4. IF THERE IS A POTENTIAL FOR AN ADVERSE HEALTH EFFECT FROM ANY CAUSE OR ACTION THAT COULD HAPPEN

IMMEDIATELY, SAME DAY, OR IN THE FUTURE YOU MUST CALL DOW AMBULANCE ; 123 ON DOW PHONE OR 636-4400.

25
 5. IF YOU GET A BUG BITE OR STING FROM A BEE OR WASP OR SPIDER OR ANY OTHER INSECT OR ANIMAL

YOU MUST CALL DOW AMBULANCE; 123 ON DOW PHONE OR 636-4400.

6. REPORT ALL ACCIDENTS / INCIDENTS TO OWNER'S REP AND TO PERMIT SIGNER AS SOON AS POSSIBLE

7. SUBMIT PRELIMINARY WRITTEN REPORT WITHIN 24

HOURS

A.9.5 Evacuation
34B

To be determined by DOW contact person

• Evacuation routes and assembly areas (and alternative routes and assembly areas) are specified on
the site map.
• Evacuation route(s) and assembly area(s) will be designated by the SSR before work begins.
• Personnel will assemble at the assembly area(s) upon hearing the emergency signal for evacuation.
• The SSR and a “buddy” will remain on the site after the site has been evacuated (if safe) to assist
local responders and advise them of the nature and location of the incident.
• The SSR will account for all personnel in the onsite assembly area.
• A designated person will account for personnel at alternate assembly area(s).
• The SSR will write up the incident as soon as possible after it occurs and submit a report to the
Corporate Director of Health and Safety.

A.6.3 A.9.6 Incident Notification and Reporting

35B

• Upon any project incident (fire, spill, injury, near miss, death, etc.), immediately notify the PM and
HSD.
• For J.F. Brennan work-related injuries or illnesses, contact and help the HSD complete an Incident
Report Form (IRF). Attachment (A-12) IRF must be completed within 24 hours of incident.
• For J.F. Brennan subcontractor incidents, complete the Subcontractor Accident/Illness Report Form
and submit to the HSD.
• Notify and submit reports to client as required in contract.

A.10 Approval
8B

This site-specific Health and Safety Plan has been written for use by J.F. Brennan only. J.F. Brennan
claims no responsibility for its use by others unless that use has been specified and defined in project or
contract documents. The plan is written for the specific site conditions, purposes, dates, and personnel
specified and must be amended if those conditions change.

A.10.1 Original Plan

36B

Approved By: Date:

26
 A.11 Attachments
9B

Comment [kl1]: Please do not

modify or delete this- it is used to
automate the lettering in the page
J.F. BRENNAN HEALTH AND SAFETY PLAN numering. It is invisible and will
not print.
A.11.1 Employee Signoff Form
37B

EMPLOYEE SIGNOFF FORM

Health and Safety Plan
The J.F. Brennan project employees and subcontractors (and lower tier subcontractors) listed below have been
provided with a copy of this HASP, have read and understood it, and agree to abide by its provisions (including drug
U

testing and discipline protocols specified in Section A.2).

U

Project Name: Sediment Remediation Project Number: 431007

Contract # 93150816
EMPLOYEE NAME
(Please print) EMPLOYEE SIGNATURE COMPANY DATE

27
J.F. BRENNAN HEALTH AND SAFETY PLAN
A.11.2 Statement of Policy on Drug and Alcohol Abuse
38B

Policy on Drug and Alcohol Abuse

The use of alcohol or drugs can lead to serious health problems and frequently does affect an individual’s
judgment, work habits and personal relationships. An individual under the influence of alcohol or drugs
constitutes a potential safety hazard to themselves, their fellow workers, third parties and to property,
equipment and vessels. In short, and individual under the influence of alcohol or drugs can easily
undermine public confidence in the company. Alcohol and drug abuse are serious illnesses that require
diagnosis and treatment at the earliest possible stage. The following statement of policy is intended to
advise employees of their responsibilities in this area.
We believe that employees having drug and alcohol abuse problems make up only a small
fraction of the work force and the company regrets any inconvenience that may be caused to the many
non-abusers. The benefits to be derived from the reduction in number of accidents, the greater safety of
all employees, and the termination and treatment of those who, because of alcohol or drugs, are a burden
upon others, will more than outweigh the inconvenience to non-abusers. The company earnestly solicits
the cooperation of all employees in implementing the policies described below, many of which are
required by United States statutes and regulations.

Operational Policy
1. No alcohol. The use or possession of alcohol by any employee on a work site or while on
company property, equipment or vessels or the use of alcohol at any time that would manifest itself
while on a work site or while operating company equipment or while on company property, equipment
or vessels, is absolutely prohibited. Alcohol for purposes of this policy means any form or derivative
or ethyl alcohol (ethanol) including any beverage that may be legally sold and consumed and that has
alcohol content. Manifest for purposes of this policy shall include in addition to actually being under
the influence of alcohol while on duty, the use of alcohol, which affects performance, results in
excessive absenteeism or tardiness or is the cause of an accident. A person displays evidence of
intoxication by observation of manner, disposition, speech, general appearance, behavior or if such
person has a blood alcohol concentration (BAC) of .04% or greater. No vessel crewmember shall
perform any scheduled duties within eight (8) hours of consuming any alcohol, be intoxicated at any
time or consume any intoxicant while on duty. Intoxicant means any form of alcohol, drug or
combination thereof.

2. No unlawful drugs. The unlawful, manufacture, distribution, dispensation, use, sale or

possession of marijuana, narcotics or controlled substance at any time, on or off duty, is absolutely
prohibited. A controlled substance means a controlled substance in schedules through V of section
202 of the Controlled Substance Act (21 U.S. C. 812) an as further defined in regulation 21 cfr
1308.11-1308.15, which includes, but is not limited to marijuana, cocaine, opiates, narcotics,
phencyclidine (PCP), hallucinogens, amphetamines, barbiturates, and tranquilizers.

3. Prescription drugs. Employees undergoing prescribed medical treatment with a legal drug or
controlled substance must report this fact and present satisfactory written evidence from their treating
physician, that such drug or controlled substance will not adversely affect behavior or work
performance, to their supervisor prior to starting any work shift. Under these circumstances, it may be

28
necessary to restrict an employee’s work activity during the course of such treatment. No prescription
drug shall be brought upon a work site or upon company property, equipment or vessel by any person
other than the person for whom the drug is prescribed by a licensed medical practitioner, and shall be
used only in the manner, combination and quantity prescribed. No prescription drug shall be
contained in any container other than that in which it was originally obtained bearing the pharmacist’s
label. Abuse of prescription drugs which affects performance or results in excessive absenteeism or
tardiness or is the cause of an accident will result in disciplinary action up to and including discharge.
In this regard, the disciplinary action taken shall be solely determined by the company.

4. Supervisor Responsibility. Supervisors are required to monitor the behavior and work patterns
of their crew members and all other employees on the work site. Emotional mood or behavior
changes, repeated absenteeism or general behavior consistent with intoxication from alcohol or drugs
should be reported to Steven Stroschein. Failure to do so will result in disciplinary action up to and
U U

including discharge. In this regard, the disciplinary action taken shall be determined solely by the
company.

5. Work rules. In order to insure the safety of the work place and work force, the following work rules
will apply to all employees immediately upon their hiring.

A. Searches. Each employee, as a condition of employment, will be required, upon request of the
company supervisory personnel, too:
(I) Submit to a search of any vehicle brought upon or parked upon company
premises;
(II) Submit to a search of any pocket, package, purse, briefcase, toolbox, or other
container brought upon any work site, company premises or company vessel or
equipment.
(III) Submit to search of desk, locker, office, cabin, stateroom, berth or similar item or
place.

B. Random and reasonable cause testing. Each employee, as a condition of continued

employment will also be required, upon request of company supervisory personnel, to promptly
submit to a urinalysis and/or a blood alcohol concentration (BAC) test for determining use of alcohol
and/or drugs. Any employee whose blood and /or urine tests positive for a controlled substance or
alcohol shall be discharged.
Such testing may be done on a random basis or upon “reasonable cause.”

(i) Reasonable cause means a probability exists, based on some evidence, that a
crew member is intoxicated by or has used drugs, or is intoxicated by alcohol.
Alcohol intoxication on a commercial vessel is any BAC of .04% or greater. In the case of
drugs, there need not be evidence of intoxication per se; evidence of use is sufficient to
require testing.

(ii) Generally the following elements must be present to have “reasonable cause” to
require drug and/or alcohol testing.

(a) Direct observation of the suspected crew member and/or physical evidence by one
and where practicable, two persons in supervisory positions. This means the supervisor
must personally see the evidence.

(b) There must be some physical, behavioral or performance indication of use or

intoxication. Indicators include but are not limited to an individual’s person. Drugs and
drug paraphernalia as well as alcoholic beverage containers in clothing and personal
property, concealed in staterooms or elsewhere may also provide reasonable cause
since these too are physical indicators. An injury to any person or damage occurring to
any vessel, equipment or property may provide evidence sufficient for reasonable cause

29
 testing. Smoke, breath and body odors may provide evidence. Slurred and incoherent
speech, lack of coordination and balance, nodding and dozing off on watch, inability to
report for duty, frequent or extended unexplained absences from assigned duties, sudden
and wide changes of mood or attitude and many other observable variables are
examples of some conditions which could constitute reasonable cause. It should be
noted that a BAC of .04% or greater could be reach by consumption of less than three
drinks an hour. Observed odor of alcohol on a person’s body or breath is reasonable
cause to test.

(III) When it is determined that reasonable cause to require a test exists, the individual
will be informed of the fact and directed to test as soon as practicable. The company will
specify whether or not urine, BAC testing or both are being required.

C. Pre-Employment Testing. All applicants for employment may be required to take a pre-
employment physical examination including urinalysis and/or blood alcohol concentration (BAC)
tests. Applicants whose examinations and interviews, combined with general reference and
background checks, indicate present alcohol or drug abuse will not be hired. Whenever the
physical follows an individual’s hiring, the company reserves the right to discharge the employee
upon notification that such individual failed a urinalysis and/or blood alcohol concentration (BAC)
test. With respect to vessel members, no person shall be hired who has not passed a pre-
employment chemical test before the individual reports for work aboard a vessel. (Pre-
employment testing may be waived in accordance with 46 cfr 16.210 (b) (1) and (2).) A “chemical
test” means a test which analyzes an individual’s breath, blood, urine, saliva and/or bodily fluids
or tissues for evidence of drug or alcohol use.

Exhibit “A”
Certification and Declaration

1. I have been provided a written copy of the J. F. Brennan Co. Inc.’s Policy on Drug and Alcohol Abuse.
I am aware that this policy forbids the use of or dealing in illegal drugs, on or off duty and the violation of
this policy is cause for termination.

2. I understand that as a condition of my employment, I may from time to time, be required to promptly
submit to searches as outlined in section II.5.A of the J. F. Brennan Co. Inc.’s policy on Drug and Alcohol
Abuse or to urinalysis and/or blood alcohol concentration (BAC) tests. I hereby consent to said searches
and/or tests. However, I further, understand that I may refuse to submit to such searches or tests and if
so, such refusal shall constitute misconduct and be grounds for immediate dismissal.

30
 3. I understand that switching, tampering with or adulterating a urine, blood, saliva or breath specimen, or
otherwise interfering with the collection and testing process is prohibited.

4. I understand that violation of any of the provisions of the company policy shall constitute misconduct
and will result in disciplinary action up to and including termination.

5. I have read the J. F. Brennan Co. Inc.’s policy on Drug and Alcohol Abuse. I have been given the
opportunity to ask about any provisions that I don’t understand and I accept and agree to its provisions.

Print Name _______________________________________

Signed: __________________________________________

Date: ___________________________

J. F. BRENNAN HEALTH AND SAFETY PLAN

A.11.3 Project-Specific Chemical Product Hazard Communication Form
39B

Project-Specific Chemical Product Hazard Communication Form

94B

This form must be completed prior to performing activities that expose personnel to hazardous chemicals products. Upon
completion of this form, the SSR shall verify that training is provided on the hazards associated with these chemicals and
the control measures to be used to prevent exposure to J.F. Brennan and subcontractor personnel. Labeling and MSDS
systems will also be explained.
Project Number: 431007
Project Name: Tittabawassee River Sediment Remediation
Contract # 93150816
MSDSs will be maintained at
the following location(s): J.F. Brennan field office

• Hazardous Chemical Products Inventory

95B

MSDS Container Labels

Chemical Quantity Location
Available Identity Hazard
ppm levels
Dioxin Sediment
in sediment

31
J.F. BRENNAN HEALTH AND SAFETY PLAN
A.11.4 Applicable Material Safety Data Sheets
40B

MSDS file will be kept on site in J.F. Brennan’s field office and made
available for review by contacting the SSR

J.F. BRENNAN HEALTH AND SAFETY PLAN

A.11.5 Chemical Specific Training Form

41B

CHEMICAL-SPECIFIC TRAINING FORM

Location: Midland, MI Project #: 431007

Trainer:

TRAINING PARTICIPANTS:

NAME SIGNATURE NAME SIGNATURE

32
REGULATED PRODUCTS/CHEMICAL INVENTORY ON-SITE:

The trainer shall use the product MSDS to provide the following information concerning each of the
products listed above.

Physical and health hazards

Control measures that can be used to provide protection (including appropriate work practices,
emergency procedures, and personal protective equipment to be used)

Methods and observations used to detect the presence or release of the regulated product in the
workplace (including periodic monitoring, continuous monitoring devices, visual appearance or odor
of regulated product when being released, etc.)

Training participants shall have the opportunity to ask questions concerning these products and, upon
completion of this training, will understand the product hazards and appropriate control measures
available for their protection.

Copies of MSDSs, chemical inventories, and J.F. Brennan’s written hazard communication program shall
be made available for employee review in the facility/project hazard communication file.

33
J.F. BRENNAN HEALTH AND SAFETY PLAN
A.11.6 Activity Hazard Analysis
42B

34
 ACCIDENT PREVENTION PROGRAM
ACTIVITY HAZARD ANALYSIS
Contract No. Contract Name

Date Location Estimated Start Date

Activity Analyzed by Hazard Analysis Phase & Date

Principal Steps of Operation Potential Hazards Precautionary Actions or Controls To Be Implemented

Equipment to be Used Inspection Requirements Training Requirements

Contractor Superintendent or Safety Officer (Signature & Date) Contractor Project Manager or Representative (Signature & Date)

Employee sign off

35
 79B A.11.6.1 AHA Deployment of Turbidity Curtain
Project: DOW Sediment Remediation Reach D
Activity: Deployment of Turbidity Curtain
MAJOR STEPS POTENTIAL HAZARDS
1. Use of Barge and crane for a. Falling Overboard and/or a. Falling Overboard and/or Standing
deploying turbidity curtain. Standing
b. Struck By/Against
c. Severe Weather
d. Sinking Boat
e. Watercraft Operation
f. Flying objects and debris
g. LostEquipment
Overboard/crushed
h. Emergencies: Fire, Weather and
Medical /Spills/Releases
b. Struck By/Against
Location: Midland, MI
PROTECTIVE MEASURES/CONTROLS
• All persons on board will remain seated/standing securely
whenever a watercraft is moving,
• All personnel shall wear USCG Approved Type III Live Preservers
at all times while on water.
• All PFDs will be properly worn, snug, and fully zippered/buttoned.
• A USCG Approved Type IV flotation device (life ring) with 70 m
feet of line will be maintained on each tender boat.
• Personnel will ascertain the stability of the deck surfaces of the
derelict vessels on a vessel by vessel basis before going on board.
The use of planks/plywood/ladders and deck stabilization devices
will be available and used on a vessel by vessel basis.
• Any vessel deemed unsafe by the attendant, inspector, ESS, or
pilot of the tender boat will not be boarded.
• All means of boat access shall be properly secured, guarded, and
maintained free of slipping and tripping hazards.
• Maximum weight capacity for watercraft will not be exceeded.
• Watercraft will be operated with a minimum of two personnel on
board.
• Watercraft will not be used without shore support personnel.
• Personnel on board watercraft must be in contact with shore
personnel.
• Personnel deploying the turbidity curtain will not hang over the
sides of the boat.
• All heavy, over-the-side work shall be done with the aid of a winch
or crane.
• Personnel will understand and review hand signals.
• Watch for other boats in area, avoid close calls or collisions
• Watch for wake from other boats
• Caution will be used offloading the boat-personnel will ensure the
boat is securely docked before embarking. All supply transfer work

37
 A.11.6.2 AHA River Flash
80B

ACCIDENT PREVENTION PROGRAM

ACTIVITY HAZARD ANALYSIS
Contract No. Contract Name
93150816 DOW SEDIMENT REMEDIATION PROJECT
Date Location Estimated Start Date
5/11/2007 MIDLAND, MI 5/7/2007
Activity Analyzed By Hazard Analysis Phase & Date
ACTION PLAN FOR RIVER FLASH PREPARATORY
Principle Steps of Operation Potential Hazards Precautionary Actions or Controls to be Implemented
Move equipment to area above high water Fluid release to river Before leaving job site for the weekend, move equipment above
high water line.
Equipment swept down stream Walk Crane up ramp above high water line.
Secure floating plants, boats
Equipment submerged in river Secure floating plants mooring lines
Assure spuds are seated in river bottom.
Electrical components saturated shorted
out. Remove crew and rescue boats or secure on floating plant.
Assure floats are secured.

Equipment to be Used Inspection Requirements Training Requirements

Crane

Loader
Generator
Tool boxes
JLG

Contractor Superintendent of Safety Officer (Signature and Date) Contractor Project Manager or Representative (Signature and Date)

Employee Sign-Off

38
 A.11.6.3 AHA Bag Roll out
81B

ACCIDENT PREVENTION PROGRAM

ACTIVITY HAZARD ANALYSIS
Contract No. Contract Name
93150816 DOW Sediment Remediation Reach D
Date Location Estimated Start Date
4/20/2007 Midland, MI 6/7/2007
Activity Analyzed By Hazard Analysis Phase & Date
Bag roll out Steve Stroschein Prepetory
Principle Steps of Operation Potential Hazards Precautionary Actions or Controls to be Implemented
Transporting bag to location Tip over Inspect equipment prior to use
Rollig out bag on top of existing bags Striking, backing over, persons Use spotter if vision is obstructed
Fall from heights Communicate intentions with all people in the area
Wearing Hi Visibility vests will be required

Equipment to be Used Inspection Requirements Training Requirements

Material Handler Daily inspection of machine Use qualified operator familiar with all attachments
Cover AHA with all persons involved in bag roll out

Contractor Superintendent of Safety Officer (Signature and Date) Contractor Project Manager or Representative (Signature and Date)

Employee Sign-Off

39
 A11.6.4 AHA Clearing and Grubbing Barge Mounted Hoe
82B

ACCIDENT PREVENTION PROGRAM

ACTIVITY HAZARD ANALYSIS
Contract No. Contract Name
93150816 DOW SEDIMENT REMEDIATION REACH D

Date Location Estimated Start Date

04/19/2007 Midland, MI 06/2007

Activity Analyzed by Hazard Analysis Phase & Date

Clearing and Grubbing barge mounted hoe Steve Stroschein Preparatory

Principal Steps of Operation Potential Hazards Precautionary Actions or Controls To Be Implemented

Cuts, Ear Damage, Particle in eyes JFB required PPE: Hard hat, Safety glasses, Steel toed boots
Removing tree /debris parts from Struck by, caught between Ear plugs,
water/bank using barge mounted hoe Slips, Trips, Falls Watch for swing end of material
Drowning PFD properly fir, zipped and snapped

Stack removed materials on barge. Pinning, Crushing, falling on Be aware of possible rolling of stacked materials
Load on trucks or barge Maintain a safe distance while stacking materials

-Instruct workers on their roles before work begins.

Transport materials to new location. Follow safet boating rules

Equipment To Be Used Inspection Requirements Training Requirements

Barge or land based All equipment to be inspected upon arrival

Crane, Hydraulic Hoe and daily in accordance with JFB standard Use only trained and qualified operators.
equipment management practices Cover AHA with all persons involved
Barge Establish a positive means of communication
Boat for moving barge Hazwoper certified

Contractor Superintendent or Safety Officer (Signature & Date) Contractor Project Manager or Representative (Signature & Date)

40
 A.11.6.5 AHA Booster Pump Operation
83B

ACCIDENT PREVENTION PROGRAM

ACTIVITY HAZARD ANALYSIS
Contract No. Contract Name
93150816 DOW SEDIMENT REMEDIATION REACH D

Date Location Estimated Start Date

04-3-2007 Midland, MI 06/2007

Activity Analyzed by Hazard Analysis Phase & Date

Booster Pump Operation Steve Stroschein Preparatory

Principal Steps of Operation Potential Hazards Precautionary Actions or Controls To Be Implemented

Starting, Running, Shut down, and Falling into water Properly fastened PFD
Cleaning of barge mounted booster pump
Caught in Pump Radio communication, "buddy system"

Slip, Trip, Fall Following lockout/tagout procedures

Exposure to drowning
House keeping, removing trip hazards
Exposure to Hazardous chemicals Designated PPE worn when exposure exists

Follow lockout/tagout procedure

Equipment to be Used Inspection Requirements Training Requirements

Diesel engine coupled to a centrifugal Pre-Startup Component inspection Critical inspection check sheet
pump
Periodic monitoring of Fluid levels Operational and procedural Training
Boat to access barge Assure positive attachment Lockout/tagout procedures
Perscribed monitoring of presures,RPM's, Boater Safety
Portable generator flow, Fueling and GFI procedures
Communication Radio Radio check daily Radio communication training

Contractor Superintendent or Safety Officer (Signature & Date) Contractor Project Manager or Representative (Signature & Date)

LMV Form 359-R Jan 95 (Proponent: CELMV-SO)

41
A.11.6.6 Crane Assisted Barge/Equipment Launching
ACCIDENT PREVENTION PROGRAM
ACTIVITY HAZARD ANALYSIS
Contract No. Contract Name
93150816 DOW Sediment Remediation Reach D

Date Location Estimated Start Date

5/10/2007 Midland, MI 5/7/2007

Activity Analyzed by Hazard Analysis Phase & Date

Crane assissted barge/equipment launching Steven Stroschein Preparatory
Principal Steps of Operation Potential Safety/Health Hazards Recommended Controls
Set up Crane Contact with objects in boom radius Proper set up of Crane
Test swing for relief from objects
Establish proper communication with crane operator
Barges arrive by truck Traffic control Position persons for traffic control
Struck by Competent rigging person in charge
Rigging barges Pinched, caught between, struck by use.

Slips/Trips/Falls Use proper crane signals

Lift barge and place in water
Access barge for rigging removal
Struck by load
Never work under a suspended load
• Use tag line
Drowning, slip, trip, fall Monitor swing radius of load
• Provide pick access to floating barge

• PFD type III must be worn after entering the

gates to Reach D river site and while on the water

Equipment to be used Inspection Requirements Training Requirements

Crane Annual Only Qualified Crane operator
Daily

Contractor/Superintendent or Safety Officer Contractor/Project Manager or Representative

signature date date

42
 A.11.6.7 Driving Sheet Piling
84B

ACCIDENT PREVENTION PROGRAM

ACTIVITY HAZARD ANALYSIS
Contract No. Contract Name
93150816 Dow Sediment Remediation
Date Location Estimated Start Date
4/12/2007 Midland Michigan 5/1/2007
Activity Analyzed By Hazard Analysis Phase & Date
Driving Sheeting Steve Stroschein
Principle Steps of Operation Potential Hazards Precautionary Actions or Controls to be Implemented
Hoisting sheeting Struck by, Caught between, Control sheeting lay down area
Positive communication between hook up person and crane
operator
Fall protection required over 6'
Thread sheeting Struck by, Fall from heights, Caught Positive communication
between. Watch personal position
Drowning Wearing PFD whils working over the water
Wear hearing protection
Drive sheeting to grade Noise exposure No working under suspended loads.
Struck by
Equipment to be Used Inspection Requirements Training Requirements
Crane Annual Certified Crane Operator
Daily
JLG Daily Competent person on Make and Model

Hammer Daily Qualified person

Barge Daily
Rigging Before being placed into service Qualified rigger
Tug Boat All equipment inspected upon arrival.
Contractor Superintendent of Safety Officer (Signature and Date) Contractor Project Manager or Representative (Signature and Date)

Employee Sign-Off

43
 A.11.6.8 AHA Fuel Transfers
85B

ACCIDENT PREVENTION PROGRAM

ACTIVITY HAZARD ANALYSIS

Contract No. Contract Name

93150816 DOW Sediment Remediation Reach D

Date Location Estimated Start Date

4/20/2007 Midland, MI 5/7/2007

Activity Analyzed by Hazard Analysis Phase & Date

FUEL TRANSFERS Steven Stroschein Preparatory
Principal Steps of Operation Potential Safety/Health Hazards Recommended Controls

Transfer of fuel to Floating plant equipment Spill to water way. Deployment of spill/drip sorbents when doing any transfer
During Land to barge fueling, Trained persons will be
assigned to each end of fuel transfer system to shut down
transfer if needed.
Slip, trip Proper PPE worn to eliminate exposure to fuel.
No smoking, sparks, or open flames while fueling.
Personal exposure to fuel Equipment will be shut down during fueling.
An appropriate sized ABC rated fire extinguisher will
Fire, Explosion be positioned during fuel transfers
On board fueling Spill to water way.
Slip, trip All portable gas cans are to be filled over secondary
Personal exposure to fuel containment or absorbent materials
Fire, Explosion Hoses, connections and fittings will be inspected prior
to any fueling operations
Double walled fuel tanks will be used
Fuel hoses will not constitute a trip hazard
Flammable liquids will be stored in specialized containers
No smoking, open flames or sparks permited in area
An appropriate ABC rated fire extinguisher will be
positioned during liquid fuel transfers

Equipment to be used Inspection Requirements Training Requirements

Absorbent materials Upon arrival Site specific orientation training
Spill kit before fueling Fire extinguisher training
Fire extinguisher

Contractor/Superintendent or Safety Officer Contractor/Project Manager or Representative

signature date date

44
 A.11.6.9 AHA General Site Hazards
86B

ACCIDENT PREVENTION PROGRAM

ACTIVITY HAZARD ANALYSIS

Contract No. Contract Name

93150816 DOW Sediment Remediation Reach D

Date Location Estimated Start Date

4/20/2007 Midland, MI 5/7/2007

Activity Analyzed by Hazard Analysis Phase & Date

General Site Hazards
Principal Steps of Operation
Construction activities working on the water Strains, Struck by, Eye injuries
Operating Chemical plant
Equipment to be used
Hard hats, Safety glasses, Hi-Vis clothing Upon use
Steel toed work boots, PFD, Face Sheilds
Steven Stroschein Preparatory
Potential Safety/Health Hazards Recommended Controls
• Watch personnel position while lifting.
• Site personnel will be instructed on proper lifting techniques (keep
back straight, lift with legs, limit twisting, etc).
• Mechanical devices should be used to reduce manual handling of
materials. Team lifting should be utilized if mechanical devices are not
available.
Contact with Hazardous chemicals An individual will not lift loads greater than 50 pounds.
• Visually inspect work areas and mark, barricade, or eliminate slip,
trip and fall hazards if feasible.
Inclement weather on even terrain.
• Watch and prepare for uneven terrain, stumps, and vegetation in
Slips, Trips, Falls walk areas.
• Replace work boots when worn out or the tread on the sole does
not provide traction.
Tools and supplies/equipment will be properly stored.
Steel toe boots meeting ANSI Standard Z41 will be worn
• Evaluate high noise operations to determine if hearing protective
Noise devices should be worn.
• Hearing protection with a noise reduction rating capable of
maintaining personal exposure below 85 dBA (ear muffs or plugs) will be
worn during high noise operations.
Inspection Requirements Training Requirements
Site specific orientation

Contractor/Superintendent or Safety Officer Contractor/Project Manager or Representative

signature date date

45
 A.11.6.10 AHA Marine Equipment Operations
87B

ACCIDENT PREVENTION PROGRAM

ACTIVITY HAZARD ANALYSIS
Contract No. Contract Name
93150816 DOW Sediment Remediation Reach D

Date Location Estimated Start Date

4/18/2007 Midland, MI 5/7/2007

Activity Analyzed by Hazard Analysis Phase & Date

Marine Equipment Operations Steven Stroschein Preparatory
Principal Steps of Operation Potential Safety/Health Hazards Recommended Controls

Vessel movement Drowning, crushing, hypothermia, fires Pre-inspection of all equipment

Lines breaking Indoctrination of all employees
Wear proper fit and fastened PFD
Hard hats, Safety glasses, Gloves
Stay out of lines of action of wire and ropes
Do not allow flammable material to accumulate in
uncontrolled areas
Ventilate engine spaces properly
Stay clear of lifting equipment
Check for vessel lists and compartment flooding
Keep decks clear of ice
Ensure anti-skid on decks where applicable
Use proper gangways
Ensure fire suppression equipment is available in close
proximity
Keep clear of spuds
Use caution in ice breaking operations
Cover emergency response plan for these operations

Equipment to be used Inspection Requirements Training Requirements

Tow Boat, Barges, work boats Per Coast Guard Qualified pilots for tow boat operation
Boating safety certified operators
PPE & PFD use and fit
Contractor/Superintendent or Safety Officer Contractor/Project Manager or Representative

signature date signature date

46
 A.11.6.11 AHA MOB/Demobilization
8B

ACCIDENT PREVENTION PROGRAM

ACTIVITY HAZARD ANALYSIS
Contract No. Contract Name
93150816 DOW Sediment Remediation Reach D

Date Location Estimated Start Date

04/18/2007 Midland, MI 05/07/2007

Activity Analyzed by Hazard Analysis Phase & Date

MOB/Demobilization Steven Stroschein Preparatory

Principal Steps of Operation Potential Hazards Precautionary Actions or Controls To Be Implemented

Tugboat Operations - Position marine assets Water hazards, struck by, caught between -All employees must wear PFDs at all times on water.
- Watch personnal position

Connect equipment for temporary electrical Shock/electrocution -Only trained electricians shall perform hook-ups
service.

Receive equipment and position materials. Traffic Accident - Designated person for traffic control

Equipment to be Used Inspection Requirements Training Requirements

Tug Boat All equipment to be inspected daily in Use only licensed pilots
accordance with JFB standard equipment Only approved operators in the equipment.
Semi Truck management practices
All drivers must hold current DOT license

Pre-task planning session with all persons involved.

Contractor Superintendent or Safety Officer (Signature & Date) Contractor Project Manager or Representative (Signature & Date)

Employee sign off

47
 A.11.6.12 AHA Mobile Equipment on Barges
89B

ACCIDENT PREVENTION PROGRAM

ACTIVITY HAZARD ANALYSIS
Contract No. Contract Name
93150816 DOW Sediment Remediation Reach D

Date Location Estimated Start Date

5/10/2007 Midland, MI 5/14/2007

Activity Analyzed by Hazard Analysis Phase & Date

Mobil Equipment on barges
Principal Steps of Operation
Excavator, cutter head dredge equiped
Mobile work platform, JLG for accessing
elevations
Steven Stroschein Preparatory
Potential Safety/Health Hazards Recommended Controls
Mobile equipment will be restrained by cable system or
Running off Barge bumpers while on barge.
PFD will be worn while on the barge, with the exception of
the operator while in the confines of the cab if wearing a
PFD would constitute a greater hazard. The operator will
Drowning have a PFD available and accessable to them.

Swing barricades will be erected to prevent access to

Crane, lifting and sheeting operations. Struck by, caught between pinch points of mobile equipment.
No one is allowed to be under a susspended load.

Equipment to be used Inspection Requirements Training Requirements

Excavator Daily Qualified operator
JLG Daily Qualified operator
Crane Daily, annual Certified crane operator

Contractor/Superintendent or Safety Officer Contractor/Project Manager or Representative

signature date date

48
 A.11.6.13 AHA River Access/Transportation
90B

ACCIDENT PREVENTION PROGRAM

ACTIVITY HAZARD ANALYSIS
Contract No. Contract Name
93150816 DOW Sediment Remediation Reach D
Date Location Estimated Start Date
5/10/2007 Midland, MI 5/7/2007
Activity Analyzed by Hazard Analysis Phase & Date
River Access/Transportation Steven Stroschein Preparatory
Principal Steps of Operation Potential Safety/Health Hazards Recommended Controls
Crew/work boat boarding Slips, Trips, Drowning • Boats must be secured to bank or dock before loading.
• PFD type III must be worn inside the reach D access
gates and while on the water. While inside of trucks or
equipment where wearing a PFD would constitute a greater
hazard They will be available but need not be worn.
• Keep boats will organized, to eliminate trip hazards.
• Never exceed boats rated capacity for weight and # of
persons.
• Required safety devices must meet USCG
requirements.
• Provide radio for communication.
• Assure fuel tank has sufficient gas before departure.
Transportation Drowning • Boat Operators must hold Boater Safety certification.

• Boats occupants must remain seated while under way.

• Kill switch tether must be used.

Docking Pinched • Keep hands inside boat when approaching dock

Falls • Do not disembark until boat is secured
• Properly Secure boat

Floating Life Line deployed out and down stream of barge

Equipment to be used Inspection Requirements Training Requirements
Small Work Boats Upon arrival Site Safety Orientation
Gangways Daily

Contractor/Superintendent or Safety Officer Contractor/Project Manager or Representative

signature date date

49
 A.11.6.14 AHA Welding and Cutting
91B

ACCIDENT PREVENTION PROGRAM

ACTIVITY HAZARD ANALYSIS
Contract No. Contract Name
93150816 DOW Sediment Remediation Reach D

Date Location Estimated Start Date

4/20/2007 Midland, MI 5/7/2007

Activity Analyzed by Hazard Analysis Phase & Date

Welding, Cutting Steven Stroschein Preparatory
Principal Steps of Operation Potential Safety/Health Hazards Recommended Controls
Welding Ultraviolet Radiation Wear peoper PPE for hot work
Burns Welding sheild
Cuts Esatablish fire watch for all hot work
Long sleeve shirts
Grinding Eye injuries Safety glasses and face sheild
Caught in No loose clothing
Struck by Watch personnel position
No flammables in hot work area
Torch work Burns Flame retardent clothing will be worn
Fire Use cutting sheild and safety glasses

Equipment to be used Inspection Requirements Training Requirements

Torch Before use Qualified persons only
Welder
Grinder
Fire extinguisher Fire extinguisher trained
Contractor/Superintendent or Safety Officer Contractor/Project Manager or Representative

signature date date

50
 A.11.6.15 AHA Working from Mobile Work Platforms
92B

ACCIDENT PREVENTION PROGRAM

ACTIVITY HAZARD ANALYSIS
Contract No. Contract Name
93150816 DOW Sediment Remediation Reach D

Date Location Estimated Start Date

5/10/2007 Midland, MI 5/7/2007

Activity Analyzed by Hazard Analysis Phase & Date

Working from mobile work platforms Steven Stroschein Preparatory
Principal Steps of Operation Potential Safety/Health Hazards Recommended Controls
Harness will be worn and secured to the proper
Travel Tip over basket attachment
Use only qualified operators for the make and model
used.
Striking Inspect equipment prior to it being put into service.
Travel only on sloped terrain within the manufacturers
recommendations.
causing a tip over.
Running off barge Secure mobile equipment with cable while on barge.
Keep personnel away from path of travel and swing
radius.

Harness will be worn and secured to the proper

Raising personnel basket attachment
PFD will be worn in aerial lift when working over
water.

Stay within the confines of the basket.

No standing on the top or mid rail.
Keep body parts within the hand rails.
Never over load the work platform.
Equipment to be used Inspection Requirements Training Requirements
JLG Upon arrival Qualified training on make and model of lift
Daily
Barge Upon arrival Qualified persons

Contractor/Superintendent or Safety Officer Contractor/Project Manager or Representative

signature date date

51
 A.11.6.16 AHA Working from Small Boats
93B

ACCIDENT PREVENTION PROGRAM

ACTIVITY HAZARD ANALYSIS
Contract No. Contract Name
93150816 DOW Sediment Remediation Reach D

Date Location Estimated Start Date

4/18/2007 Midland, MI 5/7/2007

Activity Analyzed by Hazard Analysis Phase & Date

Working from small boats Steven Stroschein Preparatory
Principal Steps of Operation Potential Safety/Health Hazards Recommended Controls

Traveling, Survey, Sampling
Back injuries and strains
Watch personnel positioning while sounding
Site personnel will be instructed in proper lifting
techniques, (keeping back straight, lifting with legs,
limit twisting, etc.
PDF type III will be worn while working on the water
Monitor weather before leaving and visually while on
the water
Have onboard method of communicating with other
jobsite personnel
Each boat will be equiped with the required USCG
safety equipment
Never exceed the boats rated capacity for weight or
persons
Only persons holding a USCG Boating Safety
Certifgicate will be allowed to operate these boats

Maintain good house keeping to reduce trip hazards

Equipment to be used Inspection Requirements Training Requirements

Only persons holding a USCG Boating Safety
Aluminum work boats upon arrival Certifgicate will be allowed to operate these boats
Outboard motors Daily

Contractor/Superintendent or Safety Officer Contractor/Project Manager or Representative

signature date date

52
A.12. Incident Report
43B

J.F. BRENNAN INCIDENT REPORT

J. F. BRENNAN
INCIDENT REPORT

COMPLETE THIS FORM FOR, NEAR MISS SITUATIONS, PROPERTY DAMAGE, AND INJURIES WITHOUT MEDICAL
ATTENTION.

SUPERVISORS MUST FILL OUT THIS FORM AND FORWARD IT TO THEIR DIVISION MANAGER

DIVISION MANAGERS WILL SUBMIT A COPY TO THE HEALTH AND SAFETY DEPARTMENT

PLEASE CHECK WHICH TYPE OF INCIDENT IS BEING REPORTED

PROPERTY/EQUIPMENT INCIDENT NEAR MISS PHYSICAL INCIDENT

1. DATE/TIME OF INCIDENT ______________________________

2. SUPERVISOR IN CHARGE ______________________________

3. JOB SITE LOCATION / JOB #

_______________________________________________________________________________________________________
_______________________________________________________________________________________________________

4. PERSON(S)/EQUIPMENT INVOLVED
__________________________________________________________________________________________________________
__________________________________________________________________________________________________________
5. NAMES OF WITNESSES
__________________________________________________________________________________________________________
__________________________________________________________________________________________________________

6. PROPERTY/EQUIPMENT INCIDENT DESCRIPTION

__________________________________________________________________________________________________________
__________________________________________________________________________________________________________

7. PHYSICAL INCIDENT DESCRIPTION

__________________________________________________________________________________________________________
__________________________________________________________________________________________________________
__________________________________________________________________________________________________________

8. WAS THE PERSON INVOLVED IN THE PHYSICAL INCIDENT ADVISED TO SEEK MEDICAL ATTENTION
__________________________________________________________________________________________________________
__________________________________________________________________________________________________________

WHAT WAS THE TASK BEING PERFORMED

__________________________________________________________________________________________________________
__________________________________________________________________________________________________________

__________________________________________________________________________________________________________

10. WAS PERSON INVOLVED PROPERLY TRAINED (DESCRIBE)

__________________________________________________________________________________________________________

__________________________________________________________________________________________________________
__________________________________________________________________________________________________________

11. WHAT COULD HAVE BEEN DONE TO PREVENT THIS INCIDENT

__________________________________________________________________________________________________________

__________________________________________________________________________________________________________

12. WHAT STEPS HAVE BEEN TAKEN TO PREVENT A RECURRENCE

__________________________________________________________________________________________________________

37
 __________________________________________________________________________________________________________
______________________________________________________________________________________________

SUPERVISORS SIGNATURE __________________________________________ DATE ________________________

I AGREE WITH THE INFORMATION PROVIDED:

PERSON INVOLVED SIGNATURE _____________________________________

A.13. Emergency Contacts

4B

Emergency Contacts

Medical Emergency—911 Medical Consultant

DOW 636-4400 Dr. Bowman 800-362-5454

Fire/Spill Emergency—911 Health and Safety Director (HSD)

DOW 636-4400 Name: Steve Stroschein
Phone: 608-784-7173 x245
Cell: 608-792-5819
Security & Police—911 Human Resources Department
Name: Bob Brague
Phone: 608-784-7173-Ext 250
Cell: 608-317-9265
Site Safety Coordinator (SSO) Worker’s Compensation:
J.D. Dohrn
Name: Steve Stroschein 608-792-5819
Cell Phone 608-792-0031
Automobile Accidents:
Name: Steve Stroschein 608-792-5819
Project Manager Federal Express Dangerous Goods Shipping
Name: Matt Binsfeld Phone: 800/238-5355
Cell Phone: 608-792-5831

Contact the Project Manager. Generally, the Project Manager will contact relevant government agencies.
Facility Alarms: Plant alarm and Mobile radio Evacuation Assembly Area(s): Established at start-up.
broad cast will prompt going to designated
assembly point for that area.

Facility/Site Evacuation Route(s): Established at start-up with subcontractors.

Once Alarm is sounded go Immediately to assembly point for that area.

Hospital Name/Address: Hospital Phone #

Directions to Hospital
1.

A.14 Lock out/Tag out

45B

Lockout /Tagout Policy

10B

38
1. Policy:
Equipment will be removed from service via Lockout/Tagout when the unexpected or inadvertent
movement of machine or materials or energizing of circuits poses a threat to worker safety.

2. Purpose:
This procedure establishes the minimum safety requirements to ensure the proper deactivation of
movable, electrically energized, pressurized equipment and systems, and systems containing
hazardous materials prior to repairing, cleaning, oiling, and adjusting or similar work.

3. Scope:
This procedure applies to all equipment that receives its energy from electrical power, hydraulic fluid
under pressure, compressed air, steam, energy stored in springs, potential energy from suspended
parts, or any other source that may cause unexpected movement when it is necessary to perform
work on the system. It also applies to similar functions performed on systems containing hazardous
materials.

4. Definitions;
a. Authorized personnel is the person or persons who lockout/tagout equipment and their immediate
supervisor. NO ONE is permitted to remove a lock or a tag except the authorized personnel.

b. Lockout is the use of a locking device, usually unlocked by a key, that is affixed to the prime source
of energy of a piece of equipment or the source of systems containing hazardous materials. The
locking device shall be used to prevent undesired movement or flow of materials.

c. Tagout is the use of a DANGER TAG (DANGER DO NOT OPERATE) that is always to be affixed
to the prime source of energy of a piece of equipment or source of systems containing hazardous
materials in such a manner that it cannot be accidentally removed. On the tag should be written the
reason for shutdown and must contain the name of the person hanging the tag and date it is hung.
The tag only is sufficient when the equipment is incapable of being locked out provided the
equipment is disconnected from its source of energy.

d. Low voltage is voltage below 600volts. Where applicable to energized circuits, this procedure
applies to low Voltage only.

5. Requirements:

a. The supervisor having jurisdiction over personnel assigned to perform maintenance function has
the responsibility to provide lockout devices and hanger tags and to train personnel in their use.

b. Employees are responsible for installing their locks in order to perform servicing, maintenance or
other procedures on that equipment and for removing their locks once the job is completed, and/or
after being relieved from their job.

c. Where the job requires more than one craft or employee to accomplish, each employee is required
to hang their own lock and/or tag.

d. All employees must be notified of a shutdown requiring lockout/tagout.

e. Unauthorized removal of lock or danger tag is a serious breach of this safety regulation.

37
f. Machinery or equipment capable of movement must be stopped and the power source de-
energized or disengaged, and if possible, the moving parts that may present a hazard shall be
mechanically blocked or locked to prevent inadvertent movement during any work on the system.

g. All electrical equipment and systems are to be treated as energized until tested or otherwise
proven to be de-energized.

h. Work on energized parts of equipment or systems may be performed only after the following
conditions have been met:
I. Responsible supervision has determined that it is necessary to work on energized equipment or
systems, and the Health and Safety Director has approved of the operation.

II. Involved personnel have received instructions on the work techniques and hazards involved in the
particular task to be performed.

III. Suitable personal protective equipment is provided and used.

j. Pipes or lines that convey pressurized substances shall be bled to atmospheric pressure
prior to opening the system.

k. Once the system has been bled to atmospheric pressure the pipe or line shall be
disconnected, blinded, or closed by valve and locked and/or tagged accordingly.

l. Some equipment may have several sources of energy, such as electrical motors, hydraulic
pressure, and may contain hazardous materials. Each source of energy must be considered
separately and de-energized Appropriately.

m. If an employee leaves work prior to the removal of their lock, the supervisor who has overall
responsibility of the job will initiate the following procedure:

I. The supervisor will verify that the employee has left the work site by, visual inspection of
the work site, check for the completion of the employee daily time sheet, absence of the
employee vehicle from the employee parking lot etc.
II. The supervisor will then try contacting the employee by phone. If the individual is
contacted and time permits, the employee must return, on their own time and remove
their lock.
III. If the employee cannot be contacted, the supervisor who has overall responsibility prior
to lock removal must complete a lock removal request form.

n. The supervisor who has overall responsibility of the job is responsible to ensure that all locks
and/or tags have been removed prior to re-activating the system or equipment.

38